Privacy Policy

1. Who we are

Fluentale is operated by the Fluentale team (“we”, “us”). When you use the Fluentale mobile app, website, or any related service (the “Service”), Fluentale acts as the “controller” of your personal data under the General Data Protection Regulation (GDPR) and similar laws.

2. Summary of the data we collect

Below is a plain-English summary of the data we collect. The categories below match the App Store and Google Play privacy disclosures for the Fluentale app.

• Identifiers: email address, anonymous user ID, device identifiers (used only inside the app, never linked to advertising profiles).
• Account & profile: display name, native language, target languages, hero choice, profile picture, optional age range.
• Learning data: lessons completed, words learned, XP, streak, hearts, gems, quests, combat results.
• Usage data: app screens viewed, features used, session length, anonymous performance metrics.
• Diagnostics: crash logs and error reports.
• Purchase data: the fact that you have an active Premium subscription. Apple or Google tells us this directly. We do not receive your full payment card details.
• Support data: messages you send to us and our replies.

We do not collect your contacts, your photos library, your location, your microphone audio, your health data, or your financial information, beyond what is described above.

3. How we use your data

• To provide the Service: sync your progress, schedule reviews, run combat and quest mechanics.
• To personalize lessons and recommend content adapted to your level and goals.
• To process your subscription, prevent fraud, and detect abuse.
• To send you optional notifications, such as streak reminders or new content alerts. You can turn these off at any time in your device settings.
• To improve the Service through anonymous analytics, A/B tests, and crash reports.
• To respond to your support requests.
• To comply with our legal obligations.

4. Tracking and advertising

Fluentale does not use your data to track you across other companies’ apps and websites. Where Apple’s App Tracking Transparency framework applies, the app will not access your device’s advertising identifier without your explicit permission. If we ever change this practice, we will ask for your consent first and update this Privacy Policy.

The Service may show non-personalized advertising. Ads are served based on the language and country of your device, not on your personal profile.

5. Legal bases (GDPR)

If you are in the European Union, the European Economic Area, or the United Kingdom, we rely on the following legal bases:

• Performance of a contract with you, when we operate your account and your subscription.
• Legitimate interests in keeping the Service safe, working well, and improving it.
• Your consent, when we use optional analytics, marketing communications, or push notifications.
• Legal obligations, for example to keep proper accounting records.

6. Who we share data with

We do not sell your personal data and we do not share it for advertising purposes. We share it only with carefully selected providers who help us run the Service:

• Hosting and database: Firebase / Google Cloud, for storage and authentication.
• App store providers: Apple and Google, for sign-in and subscription billing.
• Analytics and crash reporting: Firebase Analytics and Crashlytics, configured to use anonymous identifiers.
• Customer support: our email provider, only when you contact us.

These providers are bound by contracts that require them to protect your data and only use it on our instructions. Some of them may process data outside the European Union. Where this is the case, we rely on appropriate transfer mechanisms such as the European Commission’s Standard Contractual Clauses.

7. How long we keep your data

We keep your account data for as long as your account is active. When you delete your account (from inside the app, in Settings > Account > Delete account, or by emailing us), we delete or anonymize your personal data within 30 days, except for data we are legally required to keep (for example billing records, kept for up to 10 years).

8. Your rights

If you are in the EU, the EEA, the UK, or a country with similar laws, you have the right to:

• Access the personal data we hold about you.
• Correct your data if it is inaccurate.
• Delete your data, subject to legal exceptions.
• Restrict or object to certain types of processing.
• Receive a copy of your data in a portable format.
• Withdraw your consent at any time, where processing is based on consent.
• Lodge a complaint with your local data protection authority.

To exercise any of these rights, write to us at contact@fluentale.com. We may ask for proof of identity before replying. We aim to respond within 30 days.

Residents of California, Colorado, Virginia, Connecticut, Utah, and similar US states have additional rights under their state privacy laws (right to know, right to delete, right to opt-out of sale or sharing). We do not sell or share personal data as defined under those laws. To exercise your rights, use the same contact email above.

9. Children

Fluentale is not directed at children under 13, and we do not knowingly collect personal data from them. If you believe a child has provided us with personal data, please contact us at contact@fluentale.com so we can delete it.

10. Security

We use industry-standard measures to protect your data: encryption in transit (TLS 1.2+), secure authentication, limited access for our team on a need-to-know basis, and regular security reviews. No system is perfectly secure, so we encourage you to use a strong password and to keep your device up to date.

11. Changes to this policy

We may update this Privacy Policy from time to time. If the changes are significant, we will let you know in the app or by email at least 14 days before they take effect. The “effective date” at the top tells you when this version was published.

12. Contact

For any question about this Privacy Policy or about your data, you can reach us at contact@fluentale.com. We aim to respond within 5 business days.