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 includes 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.

To deliver these features we rely on the following categories of third-party processors:

• Speech-to-text (transcription) providers — process the audio of your voice recording to produce a written transcript. Located in the United States.
• Large language model (conversation and feedback) providers — receive your transcript and conversation history to generate coach replies, corrections, and written feedback. Located in the United States.
• Text-to-speech (voice synthesis) providers — receive the text of coach replies to produce spoken audio. Located in the United States.
• Cloud database and storage providers — host your account, transcripts, progress data, and (for a limited retention window) your raw speaking recordings. Hosted in the European Union.
• Cloud application hosting providers — run the application code that orchestrates the above. Hosted in the European Union.

See section 9 for the country and safeguard details that apply to transfers outside Switzerland. A current list of the named third-party processors we use in each of these categories is available on request from the contact in section 17.

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. We share personal data only with the categories of recipients reasonably necessary to operate the Services:

• cloud database, storage, and application hosting providers;
• speech-to-text, large language model, and text-to-speech providers (see section 5);
• payment processors;
• email and transactional messaging providers;
• analytics and product-performance providers;
• authentication and account-security providers;
• video meeting platforms (where you join a live coaching session);
• customer support tools;
• 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.

A current list of the named providers we use in each category is available on request from the contact in section 17.

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

We are based in Switzerland and store the bulk of your personal data — including your account, transcripts, and progress data — with hosting providers located in the European Union. The European Union is recognised by the Swiss Federal Council as providing an adequate level of data protection.

Some of the AI processors we rely on to deliver speech transcription, conversation, and voice-synthesis features are located in the United States. The United States is not on the Federal Council's list of countries with an adequate level of data protection. We rely on the following safeguards for those transfers, in line with Articles 16 and 17 of the Swiss Federal Act on Data Protection (FADP):

• where the recipient is enrolled in the Swiss-U.S. Data Privacy Framework, we rely on that participation;
• where the recipient is not enrolled, we put in place Standard Contractual Clauses approved or recognised by the Swiss Federal Data Protection and Information Commissioner (FDPIC);
• in addition, the transfers we make to deliver AI coaching features to you fall within Art. 17(1)(b) FADP, because they are directly connected with the performance of the contract under which we provide the Services to you.

You can request a copy of the safeguards in place for a specific provider by contacting us using the details in section 17.

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.

Voice recordings: raw audio recordings you submit during a speaking assessment are kept only as long as needed to generate and review your results. They are automatically deleted within 30 days of your assessment being reviewed. Written transcripts of your speech, which we use for scoring, feedback, and progress tracking, are retained for the lifetime of your account.

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