Privacy Policy

Last updated: 15 September 2026

This Privacy Policy explains how Fluenly (“Fluenly”, “we”, “our” or “us”) collects, uses, shares and protects personal information when you use our website, web application and related services (collectively, the “Service”).

1. Who We Are

Fluenly is the controller responsible for the personal information described in this Policy.

2. Information We Collect

Depending on how you use the Service, we may collect:

• Account information: your name, email address, user ID, verification status, account creation date and plan or subscription status.
• Preferences and progress: your selected language, proficiency level, interface language, voice and speed settings, completed scenario steps and related learning preferences.
• Voice and conversation information: microphone recordings, speech transcripts, conversation text, translations, AI responses and generated audio.
• Content you provide: custom scenarios, prompts, learning goals and images you choose to upload.
• Subscription information: your plan, payment status and limited billing or transaction information received from our payment provider. We do not store complete payment-card numbers or security codes.
• Technical and usage information: IP address, browser and device information, session identifiers, feature usage, timestamps, errors, security events and server logs.
• Support information: messages, attachments and other information you provide when contacting us.
• Cookie information: information collected through cookies, local storage and similar technologies, subject to your available consent choices.

Some account and transaction information may be provided to us by authentication and payment providers rather than collected directly from you.

3. Microphone and Image Access

We request microphone access only when you choose to use a voice feature. Recording begins only when you activate the relevant recording control. You may deny or withdraw microphone permission through your browser or device settings, but voice features may then be unavailable.

We access an image only when you choose to upload it for an image-based feature. Do not submit confidential information or personal information about another person unless you have permission to do so.

4. How and Why We Use Information

We process personal information for the following purposes:

• Providing the Service: to create and manage your account, provide voice conversations, process speech and images, generate scenarios, translations and AI responses, remember your settings and maintain your progress. We generally rely on performance of our agreement with you.
• Payments and subscriptions: to administer plans, trials, subscriptions, payments and usage limits. We generally rely on performance of our agreement and applicable legal obligations.
• Security and support: to authenticate users, prevent misuse, investigate errors, protect the Service and respond to support requests. We generally rely on our legitimate interests in operating a secure and reliable service.
• Service improvement: to understand how the Service is used, diagnose problems and improve its performance and features. We rely on legitimate interests or consent where consent is required.
• Analytics: to measure use and performance of the Service. We rely on consent where required by law.
• Legal compliance: to comply with applicable law, respond to lawful requests, resolve disputes and enforce our terms.

You are not required to provide optional information. However, information marked as required is necessary to create an account or provide the requested feature.

5. AI Processing

The Service uses automated systems to transcribe speech, translate content, interpret submitted images, generate scenarios and conversation responses, and produce synthetic speech.

AI output may be inaccurate, incomplete or inappropriate and should not be relied upon as professional advice. We do not use these systems to make decisions about you that produce legal or similarly significant effects.

Do not include unnecessary sensitive, confidential, medical, financial or identifying information in recordings, conversations, scenarios or images.

6. When We Share Information

We share personal information only where reasonably necessary to operate the Service, comply with law or protect our rights. Providers used by the Service may include:

• Authentication and account-management providers;
• Cloud hosting, database, storage and security providers;
• AI, transcription, translation and speech providers;
• Payment and subscription providers;
• Analytics providers, subject to consent;
• Customer-support and communication providers; and
• Professional advisers and legal or regulatory authorities.

Depending on the feature used, these providers may receive account information, technical information, recordings, transcripts, conversation text, prompts, scenario information or uploaded images needed to perform the requested service.

Our current principal providers include Kinde, Google Cloud and Firebase, OpenAI, Deepgram, Cartesia, Stripe, Cloudflare, Google Analytics, and tawk.to. This list may change as the Service develops.

We may also disclose information in connection with a merger, financing, restructuring, acquisition or sale of all or part of our business, subject to appropriate confidentiality and legal protections.

We do not sell personal information for monetary payment.

7. Data Retention

We retain personal information only for as long as reasonably necessary to provide the Service and satisfy security, support, accounting, tax, fraud-prevention and legal requirements.

• Account information, preferences and saved progress are generally retained while your account remains active.
• Recordings, transcripts, conversation content and uploaded images are retained only for the time needed to provide the requested feature and for limited security or troubleshooting purposes.
• Temporary session information may expire automatically after the session or applicable temporary-storage period ends.
• Support records are retained for as long as reasonably necessary to respond to requests and maintain an appropriate support history.
• Billing and transaction records may be retained as required for accounting, tax, fraud prevention, disputes and legal compliance.
• Technical, analytics and security records are retained according to our operational settings and applicable provider retention periods.

Deleted information may remain temporarily in restricted backups or be retained where required by law or necessary to establish, exercise or defend legal claims.

8. International Transfers

Our providers may process information in the European Economic Area, the United States and other countries. Where required, we use recognized transfer safeguards, such as adequacy decisions, the European Commission’s Standard Contractual Clauses or another lawful transfer mechanism.

You may contact us for more information about the safeguards applicable to your personal information.

9. Cookies and Similar Technologies

We use necessary cookies and similar technologies to operate, secure and remember settings for the Service. With your consent where required, we may also use analytics and customer-support technologies.

You can accept, reject or change your non-essential cookie choices through our cookie-preferences controls. You may also use your browser settings, although disabling necessary storage may prevent parts of the Service from working.

Withdrawing consent does not affect processing that occurred before consent was withdrawn.

10. Security

We use reasonable technical and organizational measures designed to protect personal information, including encryption in transit, access controls, restricted permissions, monitoring and security services. No internet transmission or storage system can be guaranteed to be completely secure.

You are responsible for protecting access to your account and should notify us if you believe your account has been accessed without authorization.

11. Your Privacy Rights

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

• Request access to your personal information;
• Correct inaccurate or incomplete information;
• Request deletion of personal information;
• Restrict or object to certain processing;
• Receive certain information in a portable format;
• Withdraw consent at any time;
• Opt out of direct marketing;
• Change your analytics choices; and
• Complain to an applicable data-protection authority.

These rights may be subject to legal exceptions. To exercise a right or request account deletion, email [email protected]. We may request information reasonably necessary to verify your identity.

If you are located in Ireland, you may lodge a complaint with the Data Protection Commission.

12. Children

The Service is not intended for anyone under 16, and people under 16 may not create an account or use the Service. We do not knowingly collect personal information from anyone under 16.

If you believe a person under 16 has provided personal information, contact us so that we can investigate and, where appropriate, delete the information and close the account.

13. Changes to This Policy

We may update this Policy to reflect changes to the Service, our providers or applicable law. We will post the updated version with a revised “Last updated” date and provide additional notice where required.

14. Contact Us

Questions, privacy requests and account-deletion requests may be sent to: