Privacy Policy

Introduction

This Privacy Policy describes how Schirm Technologies LLC ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use the Speakle mobile application (available on the Apple App Store and Google Play) and website (collectively, the "Service").

By using Speakle, you agree to the collection and use of information as described in this policy. If you do not agree, please do not use the Service.

1. Information We Collect

1.1 Information you provide directly

• Account information: name, email address, password (or authentication credentials if you sign in via a third-party provider)
• Profile information: language preferences, learning goals, proficiency level, and profile picture/avatar (if you choose to upload one)

1.2 Information collected through your use of the Service

• Chat logs: text transcripts of your conversations with the AI tutor
• Voice/audio recordings: audio captured through your device's microphone when you use speaking-practice features. This may include your speech, background audio picked up during recording, and derived data such as pronunciation or fluency scoring
• Voice embeddings: numerical representations ("embeddings") derived from your audio and text, used to power personalization, retrieval, and tutoring features. Embeddings are generated from your voice and speech data and are treated as personal (and, in some jurisdictions, biometric) information
• Usage and device data: device type, operating system, crash logs, and general analytics events
• Product interaction data: within the Speakle mobile app and web application, we log selected in-product events (for example, translation lookups, unknown-word marks, and related learning interactions) with timestamps, tied to your account or device session. This data is sent directly to our own first-party systems via our own APIs and is used for product analytics. It is not sent to Google Analytics, Google Tag Manager, or any other third-party analytics platform

1.3 Information from third parties

• Authentication data from Auth0, our identity and access management provider, if you register or log in through it
• Payment and subscription data: if you purchase a subscription, we (or our payment processors) receive limited billing and transaction information:
  • Stripe (web/direct purchases): billing name, email, and payment confirmation. We do not store your full card number — Stripe processes and stores this directly.
  • Apple App Store (iOS in-app purchases) and Google Play (Android in-app purchases): if you subscribe through your device's app store, Apple or Google processes your payment directly and shares with us your purchase/subscription status (e.g., active, renewed, canceled), not your payment details.
  • RevenueCat: we use RevenueCat to reconcile and manage subscription status across Stripe, the App Store, and Google Play. RevenueCat receives purchase receipts and entitlement data to keep your subscription status in sync across platforms.

2. Microphone and Voice Data — Additional Disclosures

Speakle's core functionality requires access to your device's microphone. We want to be specific about what this means:

• What we capture: raw audio of your speech during practice sessions.
• What we derive: transcripts (via speech-to-text), pronunciation/fluency feedback, and voice embeddings used for personalization and tutoring accuracy.
• Consent: your device will prompt you to grant microphone permission before any recording begins. You may revoke this permission at any time in your device settings, though doing so will disable speaking-practice features.
• Biometric data notice: in certain jurisdictions (e.g., Illinois, Texas, Washington), voice data used to generate unique identifiers may be classified as biometric information. Where applicable law requires it, we obtain your affirmative, informed consent before collecting or processing this data, and we will not sell, lease, or otherwise profit from your biometric identifiers. See retention below for how long this data is kept.
• Storage: audio and embeddings are stored on Amazon Web Services (AWS S3) and processed by OpenAI as described in Section 4. Profile pictures/avatars you upload are also stored on AWS S3.
• Retention: we retain voice recordings and derived voice embeddings for up to 2 years from your last interaction with the Service. After this period, or upon account deletion (whichever is sooner), voice recordings and embeddings are permanently deleted, except where retention is required by law or an active legal obligation.

3. How We Use Your Information

We use the information we collect to:

• Provide and personalize your language-learning experience
• Generate AI tutor responses and speaking feedback
• Improve and train our own product features (not to train OpenAI's foundation models — see Section 4)
• Maintain account security and authenticate users (via Auth0)
• Monitor, debug, and improve app performance and reliability
• Communicate with you about your account or the Service
• Comply with legal obligations

4. Third Parties We Share Data With

We do not sell your personal information. We share data with the following categories of service providers, solely to operate the Service:

On OpenAI specifically: we access OpenAI's models via their API/business offering. Data sent to OpenAI through this API is not used to train OpenAI's models. OpenAI may retain API inputs for a limited period for abuse-monitoring purposes under its own data retention terms.

We may also disclose information if required by law, to protect our rights, or in connection with a merger, acquisition, or sale of assets (in which case we will notify you).

5. Cookies and Analytics

We use two separate tracking systems, scoped differently:

• Landing/marketing site (speakle.xyz and its marketing pages): uses Google Analytics (GA4) via cookies to understand visitor traffic and page performance. This data is shared with Google as a third-party analytics provider, subject to Google's own privacy practices.
• Mobile app and web application (the product itself): uses a first-party analytics pipeline. Selected product events are timestamped and sent directly to our own APIs, and stored in our own product events database. This data is used internally for product analytics to inform product decisions, and is not shared with Google Analytics or other third parties for advertising purposes.

For users in the EU/UK, we request your consent before setting non-essential cookies (on the landing site) or firing non-essential first-party tracking (in the app and web product), via a consent banner or in-app prompt, in each case before tracking begins. You can withdraw consent at any time through the banner/settings, your browser settings, or your device's tracking/privacy settings.

6. App Store Disclosures (iOS)

Speakle is distributed on the Apple App Store. Our App Privacy ("nutrition label") disclosures in App Store Connect are maintained to reflect the data practices described in this policy, including data linked to your identity (contact info, audio data, usage data) and data used for app functionality vs. analytics. If you have questions about how a specific data type is labeled, contact us using the details in Section 14.

We do not use the Advertising Identifier (IDFA) for tracking; if this changes, we will request permission via Apple's App Tracking Transparency framework before doing so.

7. Data Security

We implement industry-standard technical and organizational measures — including encryption in transit, access controls, and least-privilege data access — to protect your personal information. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

8. Data Retention

• Account and profile data: retained for the life of your account. Accounts that remain inactive for an extended period (typically 36 months with no login or activity) may be purged or anonymized.
• Chat logs: retained for the life of your account, subject to the same inactivity-based purging described above.
• Voice recordings and embeddings: retained for up to 2 years from your last interaction with the Service — see Section 2.
• Analytics data (both GA4 and our first-party product analytics): retained only as long as needed for the purposes described in Section 5, and reviewed periodically; not retained indefinitely.

Upon account deletion, we delete or anonymize your personal data within 30 days, except where retention is required for legal, security, or fraud-prevention purposes.

9. Your Rights

Depending on your location, you may have the right to:

• Access, correct, or delete your personal information
• Port your data to another service
• Restrict or object to certain processing
• Withdraw consent (e.g., for microphone access or analytics) at any time
• Opt out of the "sale" or "sharing" of personal information (no such sale currently occurs)

To exercise these rights, email support@speakle.xyz. We will respond within the timeframe required by applicable law (e.g., 45 days under CCPA, extendable once by 45 days; 30 days under GDPR).

California Residents (CCPA/CPRA)

You have the right to know what personal information we collect, request deletion, correct inaccurate information, opt out of sale/sharing (we do not sell personal information), and limit use of sensitive personal information (including biometric/voice data). We will not discriminate against you for exercising these rights.

EEA/UK Residents (GDPR)

Our legal bases for processing include your consent (e.g., microphone access, cookies), performance of a contract (providing the Service), and legitimate interests (improving the Service, security). International transfers to the U.S. are made under Standard Contractual Clauses or another valid transfer mechanism. You have the right to lodge a complaint with your local data protection authority.

10. Cross-Border Data Transfers

Our servers and service providers are located in the United States. If you access Speakle from outside the U.S., your information will be transferred to, stored, and processed in the U.S., which may have different data protection laws than your jurisdiction. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) for these transfers.

11. Children's Privacy

Speakle is intended for users 18 years of age or older and is not directed at children. We do not knowingly collect personal information — including voice data — from anyone under 18. If we learn we have collected such data, we will delete it promptly. If you believe a child has provided us with personal information, contact us at support@speakle.xyz.

12. Data Breach Notification

In the event of a data breach affecting your personal information, we will notify affected users by email without undue delay, and in any case within the timeframe required by applicable law (e.g., 72 hours' notice to regulators under GDPR where applicable; state-specific timeframes under U.S. breach notification laws).

13. Changes to This Policy

We may update this policy periodically. Material changes will be communicated via in-app notice or email, and the "Last updated" date above will be revised. Continued use of the Service after changes take effect constitutes acceptance of the updated policy.

14. Governing Law

This Privacy Policy is governed by the laws of the State of Delaware, without regard to conflict-of-law principles. Any disputes arising from this policy or the Service will be subject to the exclusive jurisdiction of the state and federal courts located in Delaware, except where applicable consumer protection law (e.g., for EU/UK or California residents) gives you the right to bring a claim in your local jurisdiction, which is not overridden by this clause.

15. Contact Us

Questions about this Privacy Policy or your data:

• Email: support@speakle.xyz
• Entity: Schirm Technologies LLC