Privacy Policy

Effective Date: December 3, 2024 | Last Updated: December 3, 2024

1. Introduction

Welcome to LinguaFlow ("we," "our," "us," or the "Company"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile applications, website, and related services (collectively, the "Service").

By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Service.

This Privacy Policy applies to all users of the Service globally. Additional terms may apply to users in specific jurisdictions as described in Sections 13-15.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide when you:

Account Registration

• Email address
• Display name or username
• Password (stored in encrypted form only)
• Profile photo (optional)

Social Sign-In

If you sign in using Google, Apple, or Facebook, we receive:

• Name and email address
• Profile picture URL
• Unique identifier from the provider

We only receive information you authorize during the sign-in process. We do not receive your social media passwords.

Learning Profile

• Native language
• Target language(s) you wish to learn
• Current proficiency level
• Learning goals and motivations
• Daily learning time preferences

User-Generated Content

• Voice recordings for pronunciation practice
• Text responses to exercises
• Messages in conversation practice
• Feedback and support requests

Payment Information

Payment processing is handled by Apple App Store or Google Play Store. We do not directly collect or store credit card numbers, bank account information, or other financial data. We receive only:

• Subscription status (active, cancelled, expired)
• Subscription type and billing period
• Transaction identifiers for support purposes

2.2 Information Collected Automatically

When you use our Service, we automatically collect:

Usage Data

• Lessons completed and scores achieved
• Time spent learning and session duration
• XP (experience points) earned
• Streak data and learning patterns
• Features used and interactions within the app
• Errors encountered and crash reports

Device and Technical Information

• Device type, model, and manufacturer
• Operating system and version
• Unique device identifiers (e.g., IDFA, Android ID)
• App version installed
• Language and timezone settings
• Screen resolution

Network and Log Data

• IP address
• Browser type (for web access)
• Referring/exit pages
• Date and time stamps
• Clickstream data

2.3 Information from Third Parties

• Authentication Providers: Profile data from Google, Apple, or Facebook when you use social sign-in
• Analytics Services: Aggregated usage data from analytics providers
• App Stores: Subscription and purchase status

3. How We Use Your Information

3.1 To Provide and Improve the Service

• Create and manage your account
• Generate personalized learning curricula using AI
• Deliver lessons, exercises, and learning content
• Provide pronunciation feedback and coaching
• Track your learning progress and maintain streaks
• Sync your data across devices
• Improve our AI models and educational content

3.2 To Communicate With You

• Send learning reminders and streak notifications (if enabled)
• Provide customer support
• Send important service announcements
• Notify you of changes to our policies
• Respond to your inquiries and feedback

3.3 To Personalize Your Experience

• Adapt lesson difficulty to your level
• Recommend content based on your progress
• Customize the learning path to your goals
• Provide relevant practice exercises

3.4 For Analytics and Research

• Understand how users interact with our Service
• Measure the effectiveness of our teaching methods
• Identify and fix technical issues
• Develop new features and improvements

3.5 For Legal and Safety Purposes

• Comply with legal obligations
• Enforce our Terms of Service
• Protect against fraud and abuse
• Ensure the security of our Service

4. AI and Data Processing

4.1 How We Use AI

LinguaFlow uses artificial intelligence (specifically Google's Gemini AI) to enhance your learning experience:

• Curriculum Generation: Creating personalized learning paths based on your goals and level
• Conversation Practice: Powering real-time AI tutor conversations
• Pronunciation Analysis: Evaluating your speech and providing feedback
• Adaptive Learning: Adjusting difficulty and content based on your performance
• Content Creation: Generating exercises and examples tailored to your needs

4.2 Voice Recording Processing

4.3 AI Limitations

While we strive for accuracy, AI-generated content may occasionally contain errors. The AI is a learning tool and should not be considered a replacement for professional language instruction when precision is critical.

5. Data Sharing and Disclosure

5.1 Service Providers

We share information with trusted third-party service providers who assist us in operating our Service:

Provider	Purpose	Data Shared
Firebase (Google)	Authentication, database, cloud storage	Account data, learning progress
Google Gemini AI	AI-powered learning features	Learning context, voice recordings (not stored)
Cloudflare	Website hosting, security, CDN	IP address, request data
Apple/Google	App distribution, payments	Subscription status

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Valid legal process (subpoenas, court orders)
• Government requests that meet legal requirements
• Situations involving potential threats to safety
• Protection of our legal rights

5.3 Business Transfers

If LinguaFlow is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice in the app before your information becomes subject to a different privacy policy.

5.4 With Your Consent

We may share your information for other purposes with your explicit consent.

5.5 Aggregated and De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you for research, analytics, or business purposes.

6. Cookies and Tracking Technologies

6.1 What We Use

• Essential Cookies: Required for authentication and core functionality
• Analytics: To understand how you use our Service
• Preferences: To remember your settings and choices

6.2 Mobile App Tracking

Our mobile apps may use:

• Device identifiers for analytics
• Push notification tokens (if you enable notifications)
• Local storage for offline functionality

6.3 Your Choices

You can control cookies through your browser settings. Note that disabling essential cookies may affect functionality. On mobile, you can reset advertising identifiers through your device settings.

7. Data Retention and Deletion

7.1 Retention Periods

Data Type	Retention Period
Account information	Until you delete your account
Learning progress	Until you delete your account
Voice recordings	Real-time processing only; not stored unless saved by you
Usage logs	12 months
Support communications	3 years after resolution
Payment records	7 years (legal requirement)

7.2 Account Deletion

You can delete your account at any time:

1. In-App: Go to Settings → Account → Delete Account
2. By Email: Send a request to [email protected]

Upon account deletion:

• Your personal data will be deleted within 30 days
• Some anonymized/aggregated data may be retained for analytics
• Backup copies may persist for up to 90 days
• Data required for legal compliance will be retained as required by law

7.3 Data Export

You can request a copy of your data by contacting [email protected]. We will provide your data in a commonly used, machine-readable format within 30 days.

8. Data Security

8.1 Security Measures

We implement industry-standard security measures including:

• Encryption in Transit: All data transmitted using TLS 1.2+
• Encryption at Rest: Sensitive data encrypted in storage
• Access Controls: Role-based access with multi-factor authentication
• Infrastructure Security: Hosted on secure cloud platforms (Google Cloud/Firebase)
• Regular Audits: Security assessments and vulnerability testing
• Employee Training: Security awareness and data handling procedures

8.2 Password Security

Passwords are never stored in plain text. We use industry-standard hashing algorithms (bcrypt) to protect your credentials.

8.3 Incident Response

In the event of a data breach affecting your personal information, we will:

• Notify you within 72 hours of discovery
• Inform relevant regulatory authorities as required
• Take immediate steps to contain and remediate the breach
• Provide guidance on protective measures you can take

8.4 Limitations

While we take extensive measures to protect your data, no system is 100% secure. We cannot guarantee absolute security of information transmitted over the internet.

9. Your Rights and Choices

9.1 All Users Have the Right To:

• Access: Request a copy of your personal data
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your account and data
• Portability: Receive your data in a portable format
• Opt-Out: Disable marketing communications and certain data collection

9.2 Communication Preferences

You can manage your communication preferences:

• Push Notifications: Manage in app Settings or device settings
• Email: Unsubscribe links in all marketing emails
• Learning Reminders: Adjustable in app Settings

9.3 How to Exercise Your Rights

Contact us at [email protected] with your request. We will respond within 30 days (or sooner if required by applicable law).

10. Children's Privacy

10.1 COPPA Compliance

We comply with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13 years of age.

10.2 If You Are a Parent or Guardian

If you believe your child under 13 has provided us with personal information, please contact us immediately at [email protected]. We will promptly delete such information.

10.3 Teen Users (13-17)

Users between 13 and 17 may use the Service with parental or guardian consent. Parents may contact us to:

• Review their child's information
• Request deletion of their child's account
• Withdraw consent for future data collection

11. International Data Transfers

11.1 Where Your Data Is Processed

Your information may be transferred to and processed in:

• United States (primary data center)
• Other countries where our service providers operate

11.2 Safeguards

For transfers outside your country of residence, we ensure appropriate safeguards:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data processing agreements with all service providers
• Compliance with applicable data protection laws

12. Third-Party Links and Services

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal information.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

13.1 Your California Rights

• Right to Know: Request disclosure of personal information collected, used, and shared
• Right to Delete: Request deletion of your personal information
• Right to Correct: Request correction of inaccurate information
• Right to Opt-Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising
• Right to Non-Discrimination: Equal service regardless of exercising privacy rights
• Right to Limit Sensitive Personal Information: We only use sensitive information for providing our Service

13.2 Categories of Information Collected

Category	Collected	Sold
Identifiers (email, name)	Yes	No
Commercial information	Yes (subscription status)	No
Internet activity	Yes	No
Geolocation data	No (IP-based only)	No
Audio/visual information	Yes (voice recordings)	No
Inferences	Yes (learning level)	No

13.3 How to Submit a Request

California residents may submit requests via:

• Email: [email protected]
• Subject line: "California Privacy Rights Request"

We will verify your identity before processing requests and respond within 45 days.

14. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), United Kingdom, or Switzerland:

14.1 Legal Basis for Processing

Purpose	Legal Basis
Providing the Service	Contract performance
Account management	Contract performance
Analytics and improvement	Legitimate interests
Marketing communications	Consent
Legal compliance	Legal obligation

14.2 Your GDPR Rights

• Access (Art. 15): Obtain confirmation and access to your data
• Rectification (Art. 16): Correct inaccurate data
• Erasure (Art. 17): Request deletion ("right to be forgotten")
• Restriction (Art. 18): Limit processing in certain cases
• Portability (Art. 20): Receive data in machine-readable format
• Object (Art. 21): Object to processing based on legitimate interests
• Withdraw Consent (Art. 7): Withdraw consent at any time

14.3 Supervisory Authority

You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe we have violated your privacy rights.

14.4 Data Controller

LinguaFlow is the data controller for your personal information. Contact: [email protected]

15. Other Regional Privacy Rights

15.1 Brazil (LGPD)

Brazilian users have rights under the Lei Geral de Proteção de Dados including access, correction, deletion, and data portability.

15.2 Canada (PIPEDA)

Canadian users have rights under the Personal Information Protection and Electronic Documents Act.

15.3 Australia

Australian users have rights under the Privacy Act 1988 and Australian Privacy Principles.

16. Changes to This Policy

We may update this Privacy Policy periodically. When we make material changes:

• We will update the "Last Updated" date at the top
• We will notify you via email (for significant changes)
• We may display a notice in the app
• Continued use after changes constitutes acceptance

We encourage you to review this Privacy Policy regularly.

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices:

Privacy Inquiries

• Email: [email protected]

General Support

• Email: [email protected]

Legal Matters

• Email: [email protected]

Website

• https://lingua-flow.app

We aim to respond to all inquiries within 30 days.