Privacy Notice

1. Who we are

SpeaksFluent is operated by Johnny Efrain Ortega ("we", "us"), who acts as the data controller for personal data processed through the Service.

2. Data we collect

• Account data: email address, login credentials, display name.
• Learning data: placement results, lesson progress, XP, streaks, tutor conversations, pronunciation recordings, roleplay messages.
• Usage & device data: pages viewed, feature interactions, IP address, browser/device identifiers, approximate location derived from IP.
• Support data: messages you send us.
• Billing data: handled by Paddle (see section 5). We receive a customer/subscription ID, plan, status, and billing period — not your full card details.

3. Why we use it (purposes & legal bases)

• Provide the Service — account creation, tutoring, progress tracking. (Contract performance.)
• Improve the Service — aggregated analytics, debugging. (Legitimate interests.)
• Security & fraud prevention — rate limiting, abuse detection. (Legitimate interests / legal obligation.)
• Customer support — responding to your requests. (Contract / legitimate interests.)
• Transactional emails — receipts, payment failure alerts, account notifications. (Contract performance.)
• Marketing emails — only with your consent; you can unsubscribe at any time.

4. Who we share data with

• Paddle — our Merchant of Record. Paddle processes payments, manages subscriptions, calculates and remits taxes, issues invoices, and handles refunds. See Paddle's privacy notice.
• Hosting & database providers — to operate the Service.
• AI providers — content you submit to the AI tutor, pronunciation tests, or roleplay is sent to AI model providers to generate responses. Providers process it only to return results to you.
• Email delivery providers — to send transactional emails.
• Professional advisers — legal, accounting, where necessary.
• Authorities — when required by law.

We do not sell your personal data.

5. Payments

Payments are handled by Paddle.com as Merchant of Record. When you check out, your payment details are submitted directly to Paddle. We never see or store your full card number. Paddle is the controller for the payment data it collects.

6. International transfers

Personal data may be processed in countries outside your own, including the United States and the European Economic Area. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms.

7. Retention

We keep personal data only as long as needed for the purposes above: typically for the life of your account plus a reasonable period afterwards for legal, accounting, and security purposes. You can request deletion at any time (see section 8).

8. Your rights

Depending on your location, you may have rights to access, rectify, delete, restrict, or port your personal data, to object to processing, and to withdraw consent. You may also have the right to lodge a complaint with your local data protection authority. To exercise your rights, contact us through the app.

9. Security

We use appropriate technical and organisational measures including encryption in transit, access controls, and audit logging. No system is perfectly secure; if we become aware of a breach affecting you, we will notify you as required by law.

10. Cookies

We use cookies and similar technologies that are strictly necessary to operate the Service (e.g., authentication, session). Where we use analytics or marketing cookies, we will request your consent and let you manage preferences.

11. Children

The Service is not directed to children under 13. If you believe a child has provided personal data, contact us and we will delete it.

12. Changes

We may update this notice. Material changes will be communicated through the Service or by email.

13. Contact

For privacy questions, contact us through the in-app support channel.