Privacy Policy

1. INTRODUCTION

Welcome to Speak Up ("we," "our," or "us"). This Privacy Policy explains how Savvy Solutions Ltd collects, uses, discloses, and protects your personal information when you use our mobile application ("App") and related services.

By using Speak Up, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies, please do not use our services.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

When you use Speak Up, we collect information that you voluntarily provide:

• Account Information: Name, email address, password, phone number (optional), profile photo
• Language Preferences: Native language, target language(s), proficiency level, learning goals
• Avatar Creation: Photos you upload to create your personalized AI tutor avatar
• Learning Content: Vocabulary words, conversation transcripts, practice session recordings, test results, progress data
• Communications: Feedback, support requests, correspondence with us, in-app messages
• Payment Information: Processed securely through Apple App Store or Google Play Store (we do not store your payment card details)

2.2 Information Collected Automatically

When you use the App, we automatically collect certain information:

• Usage Data: Time spent in app, conversation duration, features accessed, practice frequency, lesson completion rates
• Device Information: Device type, operating system version, unique device identifiers, mobile network information
• Performance Data: App crashes, error logs, performance metrics
• Location Data: General location based on IP address (not precise GPS location)
• Voice Data: Audio recordings during voice practice sessions (processed for speech recognition and feedback)

2.3 Information from Third Parties

• Social Media: If you sign in with Google or Apple, we receive basic profile information (name, email, profile picture)
• Payment Providers: Subscription status and transaction information from App Store/Google Play
• Analytics Partners: Aggregated usage statistics from Firebase Analytics

3. HOW WE USE YOUR INFORMATION

3.1 To Provide and Improve Our Services

• Create and manage your account
• Generate personalized AI tutor avatars from your photos
• Process voice conversations and provide pronunciation feedback
• Track your learning progress and recommend personalized lessons
• Save vocabulary words and test results
• Enable speech recognition for language practice
• Improve app features, content, and user experience

3.2 To Communicate With You

• Send important service updates and notifications
• Respond to your support requests and feedback
• Provide tips and recommendations to improve your learning
• Send promotional offers (you can opt out at any time)
• Notify you about subscription status and renewals

3.3 To Ensure Security and Prevent Misuse

• Detect, prevent, and address fraud and abuse
• Monitor for violations of our Terms and Conditions
• Verify identity and prevent unauthorized access
• Protect against legal liability

3.4 For Analytics and Research

• Analyze app usage patterns and user engagement
• Conduct research to improve language learning effectiveness
• Generate aggregated, anonymized statistics
• Test new features and optimize user experience

3.5 Legal and Compliance

• Comply with legal obligations and government requests
• Enforce our Terms and Conditions
• Protect our rights, property, and safety

4. HOW WE SHARE YOUR INFORMATION

We may share your information in the following circumstances:

4.1 Service Providers

We share data with trusted third-party service providers who help us operate our business:

• Cloud Hosting: Firebase (Google) for data storage and authentication
• AI Services: OpenAI for language processing and conversation generation
• Analytics: Firebase Analytics, Crashlytics for app performance
• Payment Processing: Apple App Store, Google Play Store, RevenueCat for subscription management
• Avatar Generation: Third-party API for creating AI tutor avatars from photos

These providers are contractually obligated to protect your data and use it only for providing services to us.

4.2 Legal Requirements

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

• Legal processes (subpoenas, court orders)
• Government investigations
• Requests from law enforcement
• Protection of our rights, property, or safety

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred to the new entity. We will notify you via email and/or prominent notice in the app.

4.4 With Your Consent

We may share your information with other parties when you give us explicit consent to do so.

5. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

Retention Periods:

• Account Data: Until you delete your account, plus 30 days for backup purposes
• Learning Content: Stored while your account is active; deleted within 30 days of account deletion
• Voice Recordings: Processed in real-time; temporarily stored for quality improvement (up to 90 days), then deleted
• Analytics Data: Aggregated and anonymized data may be retained indefinitely
• Support Communications: Retained for 2 years for customer service purposes

6. YOUR RIGHTS AND CHOICES

6.1 Access and Update

You can access and update your personal information through:

• App settings → Profile section
• Contacting us at info@app-speakup.com

6.2 Delete Your Account

You can delete your account at any time:

• Go to Settings → Account → Delete Account
• Or email us at info@app-speakup.com

When you delete your account, we will permanently delete your personal data within 30 days, except where retention is required by law.

6.3 Marketing Communications

You can opt out of promotional emails by:

• Clicking "Unsubscribe" in any marketing email
• Adjusting notification settings in the app
• Emailing us at info@app-speakup.com

6.4 Do Not Sell My Information (CCPA)

We do not sell personal information. California residents have additional rights under the CCPA (see Section 10).

6.5 Data Portability

You can request a copy of your data in a machine-readable format by emailing info@app-speakup.com.

7. DATA SECURITY

We implement industry-standard security measures to protect your personal information:

Technical Measures:

• Encryption in transit (TLS/SSL) and at rest (AES-256)
• Secure authentication with hashed passwords
• Regular security audits and vulnerability assessments
• Firewalls and intrusion detection systems
• Access controls and logging

Organizational Measures:

• Employee training on data protection
• Strict access controls (need-to-know basis)
• Data processing agreements with third-party providers
• Incident response procedures

8. CHILDREN'S PRIVACY

Speak Up is intended for users aged 13 and older (or the age of digital consent in your country). We do not knowingly collect personal information from children under 13.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at info@app-speakup.com. We will promptly delete such information.

9. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence, including:

• United States (Firebase, OpenAI servers)
• European Union (cloud storage providers)
• Azerbaijan (our headquarters)

We ensure appropriate safeguards are in place for international transfers, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Privacy Shield frameworks (where applicable)
• Adequacy decisions by relevant authorities

10. REGION-SPECIFIC RIGHTS

10.1 European Union (GDPR)

If you are in the EU/EEA, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time
• Right to Lodge a Complaint: File a complaint with your local data protection authority

Legal Basis for Processing:

• Performance of a contract (providing app services)
• Consent (voice recordings, marketing communications)
• Legitimate interests (analytics, fraud prevention)
• Legal obligations (compliance with laws)

10.2 California (CCPA/CPRA)

California residents have the right to:

• Know what personal information we collect, use, and share
• Delete personal information (with certain exceptions)
• Opt-out of the sale of personal information (we do not sell)
• Non-discrimination for exercising your rights

To exercise your rights, email info@app-speakup.com with "California Privacy Rights" in the subject line.

10.3 Other Regions

We comply with applicable data protection laws in all jurisdictions where we operate, including Brazil (LGPD), Canada (PIPEDA), and others.

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to enhance your experience:

Types of Cookies:

• Essential Cookies: Required for app functionality (authentication, session management)
• Analytics Cookies: Track usage patterns (Firebase Analytics)
• Preference Cookies: Remember your settings and language preferences

You can manage cookie preferences through your device settings. Disabling certain cookies may limit app functionality.

12. THIRD-PARTY LINKS

Our App may contain links to third-party websites or services (e.g., social media, language resources). We are not responsible for the privacy practices of these third parties. Please review their privacy policies before providing any information.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service features.

How We Notify You:

• We will post the updated policy in the app with a new "Last Updated" date
• For material changes, we will send you an email notification
• Continued use of the app after changes constitutes acceptance

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. CONTACT US

15. SPECIAL PROVISIONS

15.1 Voice Data Processing

When you use voice conversation features:

• Your voice is processed in real-time for speech recognition
• Recordings are temporarily stored for quality improvement (up to 90 days)
• You can disable voice recording in Settings → Privacy
• Voice data is encrypted during transmission and storage

15.2 Avatar Photo Processing

When you create an AI tutor avatar:

• Your uploaded photo is used solely to generate the avatar
• Original photos are not permanently stored after avatar creation
• Avatar images are stored securely in your account
• We do not use your photos for any purpose other than avatar generation

15.3 Subscription Data

For subscription management:

• We receive subscription status from Apple/Google
• We do not store your payment card details
• Subscription data is used only for access control and billing
• You can manage subscriptions through your App Store/Play Store account