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1. Who We Are

UniFluent is operated by EmesOrd Ltd, a company registered in England and Wales.

• Registered address: 50 Westfield Avenue, Watford, WD24 7EH, England
• Privacy contact: unilingo.help@gmail.com
• Data controller: EmesOrd Ltd

We are the data controller responsible for your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. What Data We Collect

We collect the following categories of personal data:

Account Information

• Email address
• First name
• Password (encrypted)

Educational Information

• Native language and target language
• Proficiency level
• Subjects and learning goals
• Daily time commitment preference

User-Generated Content

• Course notes and documents you upload
• Essay text you submit for evaluation
• Flashcards you create

Voice and Audio Data

• Pronunciation recordings (processed temporarily for assessment, then deleted)
• Voice chat audio (streamed in real-time for AI conversation, not stored)
• Generated audio lessons (stored for your playback)

Learning Progress

• Lesson completions and scores
• Flashcard study progress
• Streaks and daily goals
• Game scores

Payment Information

• Subscription status and transaction identifiers from Apple App Store or Google Play
• We do not receive or store your credit card details — these are handled directly by Apple or Google

Device and Technical Data

• Push notification tokens
• Device type and operating system
• App version

Marketing Preferences

• Whether you opt in to email notifications
• How you heard about UniFluent

3. How We Use Artificial Intelligence

UniFluent uses AI technology to provide personalised language learning. It is important you understand how your data is used with AI:

Lesson generation: When you upload notes or documents, the text content is sent to OpenAI's API to generate personalised lessons, flashcards, and translations.

Essay evaluation: Essay text you submit is sent to OpenAI for assessment and feedback.

Voice conversation: When you use voice chat, your audio is streamed to OpenAI's Realtime API for AI-powered conversation practice. Audio is not stored after the session.

Pronunciation assessment: Pronunciation recordings are sent to Microsoft Azure Speech Services for scoring. Recordings are deleted immediately after assessment.

Audio lessons: Lesson text is sent to Google Cloud or AWS for text-to-speech conversion.

Your data is never used to train AI models. We have confirmed with all AI providers that your content is not used to improve or train their models. See Section 8 for details of our third-party providers.

4. Why We Process Your Data (Lawful Bases)

Under UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following:

Contract (Article 6(1)(b)): Processing necessary to provide the UniFluent service, including account management, AI lesson generation, pronunciation assessment, voice chat, learning progress tracking, and payment processing.

Consent (Article 6(1)(a)): Email marketing communications (you can opt out at any time) and advertising attribution (iOS App Tracking Transparency prompt).

Legitimate interest (Article 6(1)(f)): Push notifications for task completion, app analytics for service improvement, and fraud/abuse prevention.

5. Children and Young People

UniFluent is designed as an educational tool suitable for users of all ages, including students under 18.

Users aged 13–17: May use UniFluent with parental or guardian awareness. We recommend that parents review this Privacy Policy with their child.

Users under 13: Must have parental or guardian consent before creating an account. If you are a parent or guardian and believe your child under 13 has created an account without your consent, please contact us at unilingo.help@gmail.com and we will delete the account.

We are committed to complying with the ICO's Children's Code (Age Appropriate Design Code) and apply the following principles:

• We collect only data necessary for the educational service
• We do not use children's data for marketing purposes
• We do not profile children for commercial purposes
• Learning progress data is used solely to improve the educational experience

6. How Long We Keep Your Data

We retain your personal data for as long as your account is active. Specific retention periods:

• Account data (email, name, preferences): retained while your account is active; deleted when you delete your account
• User-generated content (notes, flashcards, lessons): retained while your account is active
• Voice recordings (pronunciation): deleted immediately after processing — not stored
• Voice chat audio: streamed in real-time only — not stored
• Learning progress: retained while your account is active
• Payment records: retained for 7 years after the transaction for legal and tax obligations
• Marketing data (Brevo): deleted when you unsubscribe or delete your account

When you delete your account, we delete your personal data from our systems. Some data may be retained in encrypted backups for up to 30 days before permanent deletion.

7. International Data Transfers

Your primary data is stored in the United Kingdom (London, eu-west-2). However, to provide AI-powered features, some data is transferred to service providers in the United States.

We protect these transfers using:

• Data Processing Agreements with Standard Contractual Clauses (SCCs)
• The EU-US/UK Data Privacy Framework (where providers are certified)
• Encryption in transit and at rest
• Confirmed no-training policies with all AI providers

We have conducted a Transfer Impact Assessment for all international transfers, which is available on request.

8. Third-Party Service Providers

We share your data with the following categories of providers, all of whom have Data Processing Agreements in place:

AI and language processing

• OpenAI (USA) — lesson generation, translations, voice chat
• Google Cloud (USA/EU) — text-to-speech
• Microsoft Azure (USA) — document scanning, pronunciation assessment
• Amazon Web Services (UK) — text-to-speech

Data storage and hosting

• Supabase (UK — London) — database, authentication, file storage
• Railway (USA) — backend application hosting

Communications

• Brevo (France/EU) — email marketing
• Expo (USA) — push notifications

Payments

• Apple (USA/EU) — iOS in-app purchases
• Google Play (USA/EU) — Android in-app purchases

Analytics and advertising

• Meta/Facebook (USA/EU) — advertising attribution (with your consent)
• Firebase Analytics (USA/EU) — app usage analytics

None of these providers use your data to train their AI models. A full subprocessor list is available on request.

9. Your Rights

Under UK GDPR, you have the following rights:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate data
• Right to erasure: Request deletion of your data (you can delete your account in Settings)
• Right to restrict processing: Request that we limit how we use your data
• Right to data portability: Request your data in a machine-readable format
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent for marketing or tracking at any time

To exercise any of these rights, contact us at unilingo.help@gmail.com. We will respond within one month.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you are unhappy with how we handle your data.

10. Security

We take the security of your data seriously and implement appropriate technical and organisational measures including:

• Encryption in transit (TLS 1.2+) for all data transfers
• Encryption at rest for stored data
• Row-level security on our database
• Secure authentication via Supabase Auth
• Regular security reviews of our service providers

While we strive to protect your data, no method of transmission over the internet is 100% secure. If you become aware of any security issues, please contact us immediately at unilingo.help@gmail.com.

11. Cookies and Tracking

UniFluent is a mobile application and does not use cookies. We use the following tracking technologies:

• Firebase Analytics: Anonymous app usage data to improve the service
• Meta SDK: Advertising attribution (only with your explicit consent via iOS App Tracking Transparency)

You can opt out of Meta tracking by declining the App Tracking Transparency prompt or through your device settings.

For information about cookies and similar technologies used on this website, please see our Cookie Policy.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or an in-app notice before the changes take effect.

The "Last updated" date at the top of this policy indicates when it was most recently revised.