Privacy Policy

1. Information We Collect

We collect the following types of information when you use Eloquent:

• •Account information: email address, first name, age range, and sign-in provider (Apple or Google)
• •Learning profile: native language, target language, level, goals, and chosen coach
• •Practice content: voice recordings, conversation transcripts, messages you write to the coach, scores, and corrections
• •Usage data: practice sessions, streaks, vocabulary progress, and completed lessons
• •Device information: device type, operating system, app version, and timezone
• •Analytics and diagnostic data: app interactions, feature usage, performance, and crash reports, linked to your account ID

2. Voice Data and AI

Eloquent records your voice during conversations and pronunciation exercises. To run these features, your voice, the transcript of what you say, the messages you write to the coach, your first name, and your learning profile are sent to third-party AI services (see section 4), which transcribe your voice, generate your coach's replies and corrections, and give your coach a voice. Your pronunciation is assessed by our own service. These transfers are necessary to provide the service you use. We store each recording, with its transcript and scores, in our cloud storage in the European Union. We use them to let you replay your attempts, to review the quality of the service, and to train and improve our pronunciation assessment and speech models. We don't use your voice data for advertising, and we only share it with third parties for their own purposes if you agree (see section 12).

3. How We Use Your Information

We use your information to:

• •Provide and personalize your learning
• •Run conversations with your AI coach, spoken and written
• •Assess your pronunciation and track your progress
• •Generate corrections, exercises, and lessons suited to your level
• •Review the quality of conversations with the AI coach and improve the product
• •Send practice reminders (with your permission)
• •Manage your subscription and payments
• •Measure app usage, and diagnose and fix technical issues
• •Prevent fraud and keep the platform secure

4. Third-Party and AI Services

We rely on the following providers to run Eloquent. Each one receives only the data it needs for its function:

• •Google Cloud: hosts our servers and the storage of your recordings
• •Google (Gemini models) and Anthropic (Claude models), called through Google Cloud Vertex AI in the European Union region: generate your coach's replies, spoken and written, as well as corrections, summaries, exercises, custom scenarios, and vocabulary translations, from your transcripts, your messages and the text you enter, your first name, and your learning profile. As a backup, a Gemini request may also go through Google Cloud's global location, which can process it outside the European Union
• •ElevenLabs, with Soniox as a backup: transcribe your voice into text during conversations
• •Inworld: turns the text of your coach's replies into speech
• •PostHog: product analytics (feature usage, performance), linked to your account ID
• •Sentry: crash reports and error diagnostics, linked to your account ID
• •RevenueCat, Apple, Google, and Stripe: subscription and payment management
• •Apple and Google: signing in to your account

5. Data Shared with AI

Conversations and exercises with your coach send your data to the AI services described in sections 2 and 4. These transfers are necessary to provide the service you use and serve only to make these features work.

6. Data Retention

We keep your account data, progress, conversations with the AI coach, and voice recordings with their transcripts for as long as your account is active so we can provide, review, and improve the service. You can delete your account at any time from Profile > Delete account: we then delete your personal data, including your voice recordings, within 30 days. Deletion also revokes the authorization you gave through Sign in with Apple, if you used it, and erases the audio recordings and images stored for your account, in all their versions; their backup copies expire within about 7 days. Anonymized data that can no longer be linked to you, such as pronunciation scores without any audio, may be kept to improve the service and our assessment models.

7. Your Rights

You have the right to:

• •Access: request a copy of the personal data we hold about you
• •Correction: update or correct your profile information from the app
• •Deletion: delete your account and associated data from Profile > Delete account
• •Portability: request your data in a portable format
• •Objection: object to certain processing, such as product analytics, by writing to us
• •Withdraw consent: withdraw your consent to licensing your conversations at any time in Profile > Share my conversations, and permissions (microphone, notifications) in your device settings

8. Children's Privacy

Eloquent is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we discover that a child under 13 has created an account, we will promptly delete it and its associated data.

9. Data Security

We implement industry-standard security measures to protect your data, including encryption in transit and at rest, secure authentication, and regular security audits. While no system is completely secure, we are committed to protecting your personal information.

10. International Data Transfers

Your data may be processed in countries other than your own, including in the United States by some of the providers listed in section 4. We ensure appropriate safeguards are in place for these transfers in compliance with applicable data protection laws.

11. Changes to This Policy

We may update this policy from time to time. We will notify you of material changes in the app.

12. Licensing your conversations (optional)

If you agree when Clara offers this in the app, Eloquent licenses your past and future conversations to companies that train AI models (speech recognition, speech synthesis, language): your voice recordings, their transcripts, and your scores, along with your native language and level. Your name, email, and contact details are never shared; your voice, however, isn't anonymous. Contracts prohibit buyers from cloning your voice, trying to identify you, reselling the data, or using it for anything other than training models. They keep it for no more than 3 years; transfers outside the European Union are governed by the European Commission's standard contractual clauses. This option is only available to adults and doesn't affect your subscription; you keep the hours offered in exchange. You can withdraw your consent anytime in Profile > Share my conversations, and deleting your account also counts as withdrawing consent: your conversations are then excluded from future batches, and buyers must delete any they've already received within 30 days. Models already trained on them aren't retrained. Legal basis: your consent.