Privacy Policy

1. Who we are

EnglishFluencyOnline is operated by:

Digital Professionals Academy sagl

For the purposes of applicable data-protection law, Digital Professionals Academy sagl is the controller of the personal data described in this Privacy Policy, unless stated otherwise.

2. What personal data we collect

Depending on how you use the Services, we may collect the following categories of personal data.

a. Information you provide directly

This may include:

• your name;
• email address;
• phone number;
• billing address or country;
• login credentials;
• profile details;
• messages you send to us;
• support requests;
• responses to forms, quizzes, surveys, or assessments;
• recordings, transcripts, written submissions, exercises, or voice inputs you provide through the platform;
• information you provide when joining a course, membership, challenge, live session, or community.

b. Payment and transaction information

If you make a purchase, we may collect information related to the transaction, such as:

• the product or plan purchased;
• payment status;
• billing amount;
• currency;
• subscription status;
• renewal and cancellation information.

Payments are typically processed by third-party payment providers. We generally do not store full payment card details ourselves.

c. Learning and usage data

When you use the Services, we may collect information about your activity, such as:

• course progress;
• lesson completion;
• quiz results;
• practice activity;
• AI coaching interactions;
• language-learning preferences;
• timestamps;
• session duration;
• feature usage;
• content viewed or accessed;
• feedback generated within the app.

d. Device and technical data

We may collect technical information automatically, including:

• IP address;
• browser type;
• device type;
• operating system;
• app version;
• language settings;
• referral URLs;
• log data;
• approximate location derived from IP;
• cookie identifiers and similar technologies.

e. Communications data

If you contact us or we send you service or marketing communications, we may collect information such as:

• your email engagement;
• SMS or messaging engagement, where used;
• communication preferences;
• records of support conversations or service notices.

3. How we collect personal data

We collect personal data:

• directly from you when you create an account, make a purchase, fill in a form, submit content, contact us, or use the Services;
• automatically through cookies, analytics tools, logs, and similar technologies;
• from service providers that help us process payments, host the platform, run analytics, send communications, or support platform functionality;
• from integrations or third-party tools you choose to connect or use with the Services.

4. Why we use your personal data

We use personal data for the following purposes:

• to provide, operate, and maintain the Services;
• to create and manage your account;
• to process purchases, subscriptions, renewals, and cancellations;
• to deliver courses, coaching, AI features, and community access;
• to analyze pronunciation, speaking, writing, usage patterns, and learning activity where relevant to the Services;
• to personalize your experience;
• to generate learning feedback, progress information, and recommendations;
• to provide support and respond to inquiries;
• to improve the Services, features, content, and user experience;
• to protect the security, integrity, and reliability of the Services;
• to detect fraud, misuse, unauthorized access, and policy violations;
• to send service-related notices;
• to send marketing communications where permitted by law or where you have opted in;
• to comply with legal, accounting, tax, regulatory, and contractual obligations;
• to enforce our Terms and protect our legitimate business interests.

5. AI, speech, and learning-related processing

EnglishFluencyOnline may include AI-powered tools, speech analysis, transcription, feedback systems, and simulated conversation features.

When you use those features, we may process:

• voice recordings;
• audio streams;
• transcripts;
• written prompts and responses;
• pronunciation data;
• fluency-related performance signals;
• interaction history with AI coaching features.

We use this information to provide the feature itself, generate feedback, improve user experience, troubleshoot problems, maintain safety, and improve the performance of our Services.

Because AI-generated outputs can vary, you should not treat them as professional advice or rely on them for high-stakes decisions.

6. Legal bases for processing

Depending on where you are located and the law that applies, we may process your personal data on one or more of the following bases:

• to perform a contract with you or take steps at your request before entering into a contract;
• to comply with legal obligations;
• for our legitimate interests, where those interests are not overridden by your rights and freedoms;
• based on your consent, where consent is required.

Our legitimate interests may include operating the business, improving the Services, securing the platform, preventing abuse, understanding usage, communicating with users, and marketing our Services in a proportionate way.

7. Cookies and similar technologies

We may use cookies, pixels, SDKs, local storage, and similar technologies to:

• keep the website or app functioning properly;
• remember preferences;
• understand usage and performance;
• measure traffic and campaign effectiveness;
• improve the user experience;
• support security and fraud prevention;
• deliver or measure marketing, where applicable.

You may be able to control certain cookies through your browser settings, device settings, or any cookie management tools we make available on the site.

8. How we share personal data

We do not sell your personal data in the ordinary sense of the term. We may share personal data with trusted third parties where reasonably necessary to operate the Services, including:

• hosting and cloud infrastructure providers;
• payment processors;
• analytics and performance providers;
• customer support tools;
• email, SMS, or communication platforms;
• authentication and security providers;
• video, meeting, or community platforms;
• AI, speech-processing, transcription, or infrastructure providers;
• professional advisers, such as lawyers, accountants, auditors, and insurers;
• regulators, authorities, courts, or law enforcement where legally required;
• actual or potential buyers, investors, or transaction advisers in connection with a merger, acquisition, financing, restructuring, or sale of assets.

We may also share information where necessary to enforce our Terms, investigate misuse, protect users, protect our rights, or respond to lawful requests.

9. International data transfers

Because we may work with service providers in different countries, your personal data may be processed outside Switzerland or outside the country where you are located.

Where required, we take reasonable steps to ensure that international transfers are subject to appropriate safeguards under applicable law.

10. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• provide the Services;
• maintain your account;
• comply with legal, tax, accounting, or regulatory obligations;
• resolve disputes;
• enforce agreements;
• maintain security and business records.

Retention periods may vary depending on the type of data and the reason we hold it. When data is no longer needed, we will delete it, anonymize it, or securely retain only what is legally required.

11. Security

We take reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

However, no system is completely secure, and we cannot guarantee absolute security.

You are also responsible for protecting your account credentials and using the Services securely.

12. Your rights

Depending on your location and applicable law, you may have rights in relation to your personal data, including the right to:

• request information about how your data is processed;
• access personal data we hold about you;
• correct inaccurate or incomplete data;
• request deletion of certain data;
• request restriction of processing in certain cases;
• object to certain processing;
• withdraw consent where processing is based on consent;
• request portability of certain data, where applicable;
• challenge certain automated decision-making, where applicable.

To exercise any of these rights, contact us using the details below. We may need to verify your identity before responding.

If you are unhappy with how we handle your request, you may also have the right to contact the relevant supervisory authority.

13. Marketing communications

We may send you marketing emails or similar communications where permitted by law.

You can opt out of marketing communications at any time by:

• clicking the unsubscribe link in an email;
• adjusting your account preferences, where available;
• contacting us directly.

Even if you opt out of marketing, we may still send important service messages relating to your account, purchases, subscriptions, or the functioning of the Services.

14. Third-party websites and services

The Services may contain links to third-party websites, apps, or services. This Privacy Policy does not apply to third-party services, and we are not responsible for their privacy practices.

You should review their privacy policies separately.

15. Children's privacy

The Services are not directed to children unless explicitly stated otherwise for a particular offering.

We do not knowingly collect personal data from children in violation of applicable law. If you believe a child has provided personal data without appropriate authorization, contact us and we will review the matter.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the Services, technology, legal requirements, or our data practices.

When we do, we will update the "Last updated" date above. If changes are material, we may also provide additional notice where appropriate.

Your continued use of the Services after the updated Privacy Policy takes effect means that the new version will apply to your ongoing use of the Services.

17. Contact us

If you have questions, requests, or concerns about this Privacy Policy or our handling of personal data, please contact:

Digital Professionals Academy sagl

app.englishfluency.online