Privacy Policy

Effective Date: August 26, 2026

NovaLingua Labs LLC (“Company”, “we”, “our”, or “us”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our Solingua mobile application, our websites (including solingua.app and novalingualabs.com), and services that link to this policy (our “Services”) and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party that does not link to this policy; or
• Any third party, including through any application or content that may link to or be accessible from or through the Services. For example: (i) when you download the Solingua app or purchase a subscription, Apple (App Store) and Google (Google Play) collect account and payment information directly from you under their own privacy policies (available at https://www.apple.com/legal/privacy/ and https://policies.google.com/privacy); they pass on to us only the limited subscription information described in this policy, such as your subscription status, plan, and renewal date, and never your full payment card details; and (ii) if you create your account using a third-party sign-in service, such as Sign in with Apple or Google Sign-In, that provider's handling of your login credentials is governed by its own privacy policy, and it passes on to us only the information described in this policy, such as your name and email address.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children's and Minors' Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, or any other identifier we may use to contact you online or offline.

The types and categories of personal data we collect or process include:

• Account and contact information, including your name, email address, password, time zone, and other contact information you provide us.
• Payment and subscription information. We do not collect or store full payment card numbers. When you subscribe through the Apple App Store or Google Play, Apple or Google processes your payment and provides us with basic subscription information, such as your subscription status, plan, and renewal date.
• Account history, including information about your subscription, account, transactions, and purchases.
• Learning profile information, including your native language, the language(s) you are learning, your proficiency level, your learning goals, and your progress, streaks, and practice history.
• Conversation data, including the text messages you exchange with our AI conversation partner, voice recordings of your practice sessions, transcripts of those recordings, and the feedback (including pronunciation feedback) we generate from them. Your conversations may include any information you choose to share with the AI conversation partner during a practice session.
• Device information, including your IP address, device identifiers, operating system and version, preferred language, browser type and settings, and other device information.
• Location information, limited to general geographic location (such as country, state or province, or city) inferred from your IP address. We do not collect precise geolocation (GPS) data.

We do not ask you to provide sensitive personal data through the Services, and we ask that you not share any in your conversations. Please avoid including information such as health, financial, or government identification details in your practice sessions; the AI conversation partner does not need this information, and the Services work just as well without it. Because conversations are free-form, anything you choose to say may nevertheless be stored as part of your conversation data. We treat all conversation content the same way, whether or not it is sensitive: we use it only to provide the Services as described in this policy; we do not use it for analytics, marketing, or advertising; we do not use it to train AI models; and it is deleted when you delete your account. We do not use your voice recordings to identify you, and we do not create biometric identifiers, such as voiceprints, from them.

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users practicing a specific language.
• Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as the features that you view or use, session lengths, response times, download errors, and crash logs.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, subscribe, have text or voice conversations with the AI conversation partner, or contact us with questions or support requests.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies and software development kits (SDKs) embedded in our app, including details of your interactions with our Services, such as the features that you access and use, session lengths, and crash and error logs.

We do not use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). To be clear, we do use analytics SDKs within our own app, as described below, to understand how you use Solingua itself. However, neither we nor our analytics providers use that information to track you across other companies' websites, apps, or services, to build advertising profiles about you, or for targeted or cross-context behavioral advertising. Our analytics providers act as our service providers and may use your information only to provide their services to us (see Personal Data Sales and Targeted Advertising below).

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• Software Development Kits (SDKs). Our app includes SDKs provided by our analytics and crash reporting service providers, currently Mixpanel for product analytics (privacy policy: https://mixpanel.com/legal/privacy-policy/) and Sentry for crash and error reporting (privacy policy: https://sentry.io/privacy/), that permit the Company, for example, to understand how users interact with app features and to diagnose crashes and errors. You can turn off product analytics at any time in the app's settings, as described in Your Rights and Choices About Your Information.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties may include:

• Analytics and crash reporting companies (currently Mixpanel and Sentry, which collect usage, device, and error information within our Services on our behalf).
• Your device manufacturer.
• Your internet or mobile service provider.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about content provided by a third party, you should contact the responsible provider directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, if you sign in using a third-party sign-in service, such as Sign in with Apple or Google Sign-In, we receive information such as your name and email address from that service. We also receive subscription information from the app stores that process your purchases, and we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, analytics and crash reporting services, cloud hosting providers, and the AI service providers described in this policy. We do not purchase personal data from data brokers.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Services and any contents, features, information, products, or services that we make available through the Services, including enabling text and voice conversations with our AI conversation partner, generating transcripts, and providing feedback on your vocabulary, grammar, and pronunciation.
• Personalize your learning experience, including tailoring conversations, feedback, and content to your language level, goals, and progress.
• Fulfill and manage subscriptions and payments.
• Fulfill any other purpose for which you provide it.
• Provide you with notices about your account and subscription, including expiration and renewal notices.
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information, to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when Services updates are available and about changes to any products or services we offer or provide though them.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
• Recognize you when you return to our Services.

We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to use your information in this way, please use the unsubscribe link included in each marketing email or adjust your preferences in your account profile. For more information, see Your Rights and Choices About Your Information.

We use the general location information we collect to set appropriate defaults for the Services (such as time zone and interface language) and for aggregate analytics.

How Our AI Features Process Your Data

The Services are built around conversations with an artificial intelligence (AI) language partner. To provide these features, we transmit your conversation data, including your text messages and voice audio, to third-party AI service providers that perform speech recognition, speech generation, and language processing on our behalf. These providers currently include OpenAI, Anthropic, and ElevenLabs, and we may engage other similar providers in the future.

We do not collect, use, or sell your personal data for the purpose of training large language models or other AI models. Our agreements with our AI service providers restrict them from using your personal data to train their models, and they are permitted to process your personal data only to provide their services to us.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. These include:
  • Our AI service providers (currently OpenAI, Anthropic, and ElevenLabs).
  • Cloud hosting and data storage providers.
  • Analytics and crash reporting providers (currently Mixpanel and Sentry).
  • Subscription management providers (currently RevenueCat, which processes subscription and purchase information on our behalf).
  • Email delivery providers (such as SendGrid).
  • Payment processors (Apple and Google, which process app store purchases).
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of NovaLingua Labs LLC's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by NovaLingua Labs LLC is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We do not sell personal data, and we do not disclose personal data to any third party for that third party's own marketing or advertising purposes.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use [INSERT AS LINK TO TERMS OF USE] and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

The categories of personal data we may disclose include:

• Account and contact information.
• Payment and subscription information.
• Account history.
• Learning profile information.
• Conversation data (disclosed only to the service providers that process it on our behalf).
• Device information.
• Location information (general geographic location only).

Personal Data Sales and Targeted Advertising

We do not sell your personal data, as the term “sale” is defined under applicable state consumer privacy laws, whether for monetary or other valuable consideration. We do not process or share your personal data for targeted advertising or cross-context behavioral advertising, and we do not use your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. If our practices change, we will update this policy and provide you with any legally required notices and opt-out rights before engaging in those activities.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other browser tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because we do not track our users over time and across third-party websites or online services, and do not permit third parties to do so through our Services, there is no tracking for a DNT signal to turn off; our Services treat all users the same regardless of the DNT signal. For a description of the analytics SDKs we use within our own Services, see How We Collect Your Personal and Other Data above.
• Promotions by the Company. If you do not wish us to use your information to promote our own products or services, you can opt out by using the unsubscribe link included in each marketing email or by sending us an email stating your request to [email protected].

Analytics choices:

• In-App Analytics Toggle. You can turn off product analytics at any time in the app's settings (Home > Settings > Data > Share Usage Analytics). When analytics is turned off, we stop sending analytics events about your use of the app to our analytics provider, both from your device and from our servers. Crash and error reporting is not affected by this toggle and cannot be turned off separately, because we need it to keep the Services reliable and secure.

Voice and microphone choices:

• Microphone Access. Voice conversations require access to your device's microphone. You can choose whether or not to allow the Services to access your microphone through your device's privacy settings. If you block microphone access, voice features will become inaccessible, but you can continue to use text-based features.

Your State Privacy Rights

State consumer privacy laws may provide their residents with rights regarding their personal data. We extend the following rights to all of our users in the United States, regardless of the state where you live:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law. You may also delete your account and the personal data associated with it at any time using the account deletion option in the app (Home > Settings > Delete Account).

State laws also provide rights to opt out of the sale of personal data, its use for targeted advertising, and certain profiling. As described in Personal Data Sales and Targeted Advertising above, we do not engage in any of these activities, so these opt-out rights have no processing to apply to. If our practices ever change, we will update this policy and provide the legally required opt-out mechanisms before engaging in them.

We will not discriminate or retaliate against you for exercising any of these rights.

To exercise any of these rights, please email us at [email protected] or, for deletion, use the in-app account deletion option described above. Email is our strongly preferred contact method and will receive the fastest response. We will need to verify your identity before fulfilling your request; we typically do so by confirming that you control the email address associated with your account. An authorized agent may submit a request on your behalf; we will require proof of the agent's authorization and may need to verify your identity directly. To appeal a decision regarding a consumer rights request, reply to our decision or email us at [email protected] with the subject line “Privacy Rights Appeal” within a reasonable period after receiving our decision. We will inform you in writing of the action taken or not taken in response to your appeal, including a written explanation of the reasons. If your appeal is denied, you may contact your state's Attorney General to submit a complaint.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. Because we do not sell personal data or process it for targeted advertising, there is currently no such processing to opt out of. If our practices change, we will process GPC signals as required by applicable law.

Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sale opt-out rights may submit a request to [email protected]. However, please know we do not currently sell data triggering that statute's opt-out requirements.

If you are a California resident, the rights and request methods described in this section apply to you and are intended to satisfy the disclosure requirements of the California Consumer Privacy Act. California residents have the right not to receive discriminatory treatment for exercising their privacy rights and may designate an authorized agent as described above.

Users Outside the United States

We offer the Services globally. NovaLingua Labs LLC, located in the United States, is the controller of the personal data described in this policy. Wherever you live, we handle your personal data as this policy describes, and the access, correction, deletion, and portability rights described above are available to all of our users worldwide through the same channels.

Your personal data is processed in the United States and in the countries where our service providers operate, which may not provide the same level of data protection as the laws of your home jurisdiction. Where required by law, we rely on appropriate safeguards for these transfers, such as the European Commission's Standard Contractual Clauses or a provider's certification under the EU-U.S. Data Privacy Framework (including the UK Extension) and the Swiss-U.S. Data Privacy Framework. Analytics data for our Services is stored on our analytics provider's servers in the European Union.

Your European privacy rights. If you are in the European Economic Area, the United Kingdom, or Switzerland, data protection law provides you the following rights: to access, correct, or delete your personal data; to receive a copy of your personal data in a portable format; to restrict or object to certain processing; to withdraw your consent at any time where our processing is based on consent (without affecting the lawfulness of processing before the withdrawal); and to lodge a complaint with your local data protection supervisory authority (in the UK, the Information Commissioner's Office). To exercise these rights, contact us as described in this policy; we will respond within the time required by applicable law.

Legal bases for processing. We process your personal data: to perform our contract with you, including providing AI conversations, transcripts, feedback, and your subscription; for our legitimate interests, including securing and improving the Services, crash and error reporting, and preventing fraud and abuse; with your consent, where we ask for it, including for product analytics (which you can turn off at any time in the app's settings) and marketing emails (which you can unsubscribe from at any time); and to comply with our legal obligations.

We do not use your personal data for automated decision-making that produces legal or similarly significant effects concerning you.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

In general, we retain your personal data, including your conversation transcripts, voice recordings, and learning progress, for as long as your account is active so that we can provide you with conversation history, progress tracking, and personalized feedback. If you delete your account, we will delete or deidentify the personal data associated with it, including conversation data held by our service providers, within 30 days of your request, except where retention is legally required or permitted (for example, records needed for tax, accounting, dispute resolution, or fraud prevention purposes). Residual copies may remain in our encrypted backups for a limited additional period until those backups are overwritten in the ordinary course of business.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Services, and, if the changes are material, by email to the address associated with your account or through a notice in the app. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at:

We strongly prefer to be contacted by email. Requests and questions submitted by email will receive the fastest response.