Privacy Policy

1. The essentials

• We use your account information, learning work, and progress to provide language practice and feedback.
• AI tutoring involves sending relevant text to third-party providers. Speech transcription sends audio to third-party providers. These are external services.
• Tutor memory is optional. You can turn it off and separately delete stored tutor memories. Ordinary progress tracking still works without it.
• We do not sell personal information or share it for cross-context behavioral advertising. The iOS app does not track you across other companies' apps and websites for advertising.
• You can export account data and request account deletion in Settings. Some financial, security, backup, and analytics records are handled separately, as explained below.

2. Information we collect and where it comes from

Account and sign-in information. We receive the email address, name, and account details you provide, together with authentication records needed to secure your account. If you choose a third-party sign-in method, we exchange the information needed to authenticate you with your chosen identity provider. That provider also processes information under its own privacy policy.

Learning content and activity. We process your selected languages, learning preferences, interests, written answers, conversation messages, speech transcripts, activity attempts, corrections, scores, practice schedules, and progress. We also create derived information, such as estimated proficiency, concepts to practice, and personalized recommendations.

Audio. When you choose a speaking feature and permit microphone access, we process your recording to transcribe or assess your practice. Audio submitted for ordinary transcription is handled transiently by Convo rather than stored as a lasting recording. The Voice Capsule feature deliberately stores a recording and its transcript so you can revisit them. A speech provider may retain data under its own service terms. Convo does not create voiceprints or use recordings to identify you biometrically.

Optional tutor memory. If you enable it, we derive and store short observations from tutoring interactions to help future conversations remember your learning needs. These observations may be inaccurate or include personal information from your conversations. Avoid sharing sensitive information, such as health details, religious or political beliefs, or information you do not want processed.

Purchase and consent records. Your payment provider or app marketplace handles payment details. We receive transaction and subscription information, such as the purchased plan, transaction reference, purchase and renewal dates, subscription status, price, and currency, and associate the purchase with your Convo account. We do not receive your complete payment-card number. Consent records may include the notice you received, your choice, the date and time, your account identifier, and IP address.

Technical, security, and usage information. Servers and service providers receive information such as IP addresses, request times, device or browser information, error details, account identifiers, service usage, and processing costs. We use our own service-usage records to understand activity, subscription revenue, reliability, and campaign performance. These analytics records do not contain conversation transcripts, audio, or the text of your learning submissions.

Support and reports. We receive information you send in support messages. Where you choose to submit a report with a screenshot, the report may include your email address, account identifier, description, the affected page, and the screenshot. The screenshot may contain your learning content.

TestFlight beta testing. If you install Convo through TestFlight, Apple shares beta crash and usage information with us. Feedback you submit through TestFlight can include your name or email address, device and operating-system information, comments, and screenshots containing learning content. We use this information to investigate reports, improve the beta, and respond to testers. Apple's TestFlight notices explain the information that its testing service collects and shares.

Visitor and acquisition information. We may receive referral and campaign information from a link you follow, our cookies, or attribution information from an app marketplace. This helps us understand which campaigns lead to subscriptions. We do not request precise location or your contacts. IP addresses can indicate an approximate region even without a location permission.

You provide most of this information directly or generate it while using Convo. Other sources include your chosen sign-in provider, payment providers, app marketplaces, other service providers, and people who contact us about an account or security issue.

3. Why we use information

• Create and secure accounts, authenticate users, and deliver requested features.
• Generate lessons, transcribe speech, provide feedback, track progress, and select useful practice.
• Provide optional continuity between tutoring conversations when you enable memory.
• Verify subscriptions, provide paid access, handle billing events, and send service and billing messages.
• Investigate errors, answer support requests, prevent abuse, control service costs, and improve reliability.
• Measure first-party service use and campaign performance.
• Record consent, respond to privacy requests, comply with legal obligations, and establish or defend legal claims.

Where applicable law requires a legal basis, we rely on performance of our agreement for the service you request; consent for the AI transfers and optional memory covered by our consent screens; legitimate interests in proportionate security, operations, support, and service measurement; and legal obligations for records and requests required by law. We balance legitimate interests against your rights. Where a local law requires consent for a particular activity, a general reference to legitimate interests does not replace that requirement.

We do not use your private learning conversations to train a general-purpose AI model of our own. We use them to generate responses and, according to your settings, to personalize your learning. Personalization and progress estimates are not employment, credit, insurance, or other decisions with comparable legal effects. If an automated restriction or recommendation affects you, you can request human review through our contact address.

4. Service providers and other disclosures

We disclose information needed for the purposes described here to the following categories of recipients:

• Third-party providers of AI and speech services: text tutoring, feedback, relevant conversation context, and learning information used to generate or personalize content. Speech transcription sends audio to third-party providers. Speech synthesis and generated illustrations use content prepared by the Service. Different providers may serve different features, and the providers we use may change over time, subject to the disclosures and consent required by applicable law. We do not deliberately add your account email or name to learning content shared with these providers for identification purposes, but information you put into your content may itself identify you.
• Hosting, storage, and content-delivery providers: account and learning information needed to operate the Service, and technical request information such as IP addresses and device details needed to deliver content.
• Communication providers: your contact details and message content needed to deliver sign-in messages, billing notices, support responses, and other service communications.
• Diagnostics, analytics, and support providers: technical, usage, and error information used to maintain reliability, measure service use, and investigate problems. Routine diagnostic information is filtered to limit content and may include an account identifier. Reports you approve may include your email, description, and screenshot.
• Payment providers and app marketplaces: purchase and account information needed for app distribution, payment processing, transaction verification, subscription management, and refunds, together with applicable campaign-attribution information. These providers also process information under their own terms and privacy notices.
• Identity providers: authentication information when you choose a supported third-party sign-in method.

Service providers may change over time. We will provide additional information and obtain consent where required by applicable law. You can contact us for more information about the recipients of your personal information.

AI providers may keep data for security, abuse prevention, legal compliance, or service operations under the arrangements governing their services and applicable law. Their retention periods may differ from those for Convo's account records. Deleting a Convo account does not necessarily cause immediate deletion of information held by a provider. Contact us for information about retention and available privacy rights.

Authorized personnel may access information when needed to operate, secure, support, or investigate the Service. Account identifiers are not a promise that information is anonymous to us. We may disclose information to professional advisers, courts, regulators, or other parties when reasonably necessary to comply with law, protect rights or safety, or investigate misuse, subject to applicable safeguards.

If a merger, financing, reorganization, or sale involves the Service, information may be disclosed under appropriate confidentiality protections and transferred as part of the transaction. A successor remains subject to applicable privacy obligations. We will provide notice or obtain consent when required. We may also disclose information at your direction or with a separate consent.

5. Cookies, device storage, and advertising

The web service uses cookies and local storage for sign-in, security, preferences, and app functionality. The iOS app stores session and preference information and may cache learning content locally. Clearing device or browser storage may sign you out or remove cached information; it does not delete your server account.

We use a cookie lasting 30 days to remember campaign information, such as which referral or campaign brought you to the Service. You can block or delete cookies in your browser; blocking essential cookies can prevent sign-in. Where applicable law requires consent for nonessential cookies, this Policy does not replace that consent.

Some web content is delivered by third-party content providers. They receive technical request information, such as your IP address, browser details, and the resource requested, when delivering that content.

We do not sell personal information, rent contact lists, or share personal information for cross-context behavioral advertising. The iOS app does not track you across other companies' apps and websites for advertising. We measure the performance of our own campaigns, including through app-marketplace attribution. We do not change our no-sale or no-cross-context-sharing practice based on a browser's Global Privacy Control or Do Not Track signal; those activities remain off. Do Not Track does not disable necessary service logging.

6. Retention and deletion

We keep account information and the derived learning record while your account remains active and the information is needed to provide the Service. Other retention decisions depend on the purpose, sensitivity, security needs, legal obligations, and the availability of deletion or de-identification.

Our retention targets are 24 months for learning transcripts and saved Voice Capsule recordings, and 12 months for sign-in delivery records. These are targets rather than guaranteed deletion dates; information may remain beyond them while removal is pending or where the retention grounds described in this section apply. You can request deletion without waiting for a retention period to end.

Deleting your account removes its active account and learning records and your stored recordings through the account-deletion process. Shared lesson and homework material may remain after its association with your account is removed. Cost, revenue, and billing-consent records may also remain for reconciliation and evidence, with direct account associations removed where possible. Information that can still identify you remains subject to applicable personal-information protections.

Analytics information. We prefer to preserve anonymous statistical information where we can remove the connection to a person. Account-deletion requests include follow-up processing of account-linked analytics, preserving monthly usage and financial totals while removing identifying source records. This processing may take additional time to cover information received after the initial request and records held by service providers. Information that can still be linked to you is treated as personal information. Our target retention period for detailed analytics is 90 days, subject to the qualifications above. Contact us if you need help with a request or its completion status.

Backups, operational logs, support records, and service-provider copies are separate from active account records and are not instantly erased by deleting an account. Their retention depends on recovery, security, support, and applicable legal needs. We restrict use of retained copies to the purpose that justifies retention. Legal holds, fraud investigations, and accounting or dispute obligations may require particular records to be retained longer.

You can delete tutor memories separately and turn off future memory creation. Turning memory off does not by itself delete existing memories or your ordinary learning history. Uninstalling the app is not an account-deletion request. Account deletion is also not subscription cancellation; manage an Apple subscription separately.

7. Your choices and rights

In Settings, you can update available preferences, manage AI and memory consent, export account data, and delete your account. Device settings control microphone access. Withdrawing AI consent may make AI-dependent features unavailable; withdrawing optional memory consent does not remove ordinary progress tracking. Withdrawal does not invalidate processing lawfully performed before it.

Depending on where you live and which laws apply, you may have rights to:

• Confirm whether we process your information, obtain access and a copy, and receive information about its use and recipients.
• Correct inaccurate information and request deletion, anonymization, restriction, or blocking where applicable.
• Receive portable data and, where applicable, request its transfer to another provider.
• Withdraw consent and object to processing based on legitimate interests or to direct marketing.
• Opt out of sale, targeted advertising, or certain profiling, and limit certain uses of sensitive information where the law provides those rights.
• Request review of qualifying automated decisions, appeal a refused request where available, and complain to a competent regulator.

Send requests to support@convergic.io, preferably from your account email, and tell us the action you want. An authorized agent may contact us with proof of authority. We may verify identity or authority proportionately before disclosing or changing information; do not send government identification unless we specifically explain why it is necessary and how to send it safely.

We respond within the deadlines required by applicable law. Rights are subject to lawful exceptions. If we deny or limit a request, we will explain the reason and any available appeal or complaint route. To appeal, reply with “Privacy appeal” and the request reference. We do not penalize you for exercising privacy rights, although a feature cannot operate without information essential to it. Requests are normally free; any legally permitted fee or refusal for excessive or unfounded requests will be explained.

EEA and United Kingdom: you may complain to your local data-protection authority, including the UK Information Commissioner's Office where applicable. Brazil: you may exercise applicable LGPD rights and contact the ANPD or relevant consumer authorities. Our contact address above receives Brazilian privacy requests. You may contact us for information about applicable local privacy contacts. United States: state privacy rights apply where the relevant law covers our processing. California residents may request the categories, sources, purposes, and disclosures described in this Policy, and applicable access, correction, deletion, and nondiscrimination rights. We do not sell or share information for cross-context behavioral advertising, including information about minors.

8. International processing and security

Convergic is based in the United States. Hosting and service providers may process information in the United States and other countries where they operate. Those countries may have different privacy protections and rules for government access. Where law requires a transfer safeguard, an applicable contractual or other lawful transfer mechanism is required; accepting this Policy is not a blanket waiver of those requirements. Contact us for information about safeguards applicable to your data.

We use technical and organizational measures, including encryption, access restrictions, and security monitoring, to protect information. No system can guarantee absolute security. Protect your sign-in credentials and devices, and contact us promptly about a suspected incident. If a personal-data breach requires notice, we will notify affected people and authorities as applicable law requires.

9. Children and sensitive information

Convo is a general language-learning service, not a service directed to children under 13. Users must meet applicable age and consent requirements. Where parental authorization is legally required and cannot be obtained through a supported process, the child should not use the Service.

If you believe a child has provided information without required authorization, contact us so we can investigate, restrict relevant processing, and delete information where required. A parent or guardian may request assistance with the child's information, subject to verification and applicable law. Storefront ratings do not establish a person's age or prove parental consent.

Do not submit payment-card numbers, government identifiers, medical records, passwords, or other highly sensitive information in learning conversations. Language practice may reveal personal matters; we process content you submit to deliver the feature, even when you include information we did not request.

10. Changes and contact

We update this Policy when our practices change. The effective date identifies the current version. We will provide additional notice for material changes and seek consent when required before using information for a materially different purpose. A new version does not remove rights relating to information already collected.

For privacy questions, rights requests, accessibility assistance, or complaints, contact Convergic, LLC at support@convergic.io. Please avoid including sensitive learning content in the initial message. We can arrange an appropriate way to obtain information needed to resolve your request.