Privacy Policy

Welcome

Thank you for choosing Eloquendi.

Eloquendi LLC ("Eloquendi," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, store, and protect information when you use the Eloquendi mobile application, our website, and any related products and services (collectively, the "Services").

Our goal is to help people become more confident and effective communicators while handling personal information responsibly and transparently.

By creating an Account or using the Services, you acknowledge that you have read and understood this Privacy Policy.

Privacy at a Glance

• We collect only the information reasonably necessary to provide, improve, and secure the Services.
• We use your information to personalize your learning experience, deliver AI-powered coaching, provide customer support, and maintain the security and reliability of the Services.
• We do not sell your Personal Information.
• We do not use your information for third-party behavioral advertising.
• Subscription payments are processed by Apple or Google. Eloquendi does not receive or store your payment card information.
• You may delete your Account and AI conversation history through the Services.
• We work with trusted service providers to help operate and improve the Services.

Our Privacy Principles

These principles guide how we design and operate the Services.

Transparency

We clearly explain what information we collect, why we collect it, and how it is used.

Purpose Limitation

We collect and use information only for legitimate purposes related to providing, improving, securing, and supporting the Services, or as otherwise permitted by law.

Data Minimization

We seek to collect only the information reasonably necessary for the intended purpose. Where feasible and appropriate, we use de-identified, pseudonymized, or aggregated information instead of identifiable information.

User Control

We provide tools that allow you to access, manage, correct, and delete your information, subject to applicable law.

Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect the information entrusted to us.

Continuous Improvement

We regularly review our privacy and security practices as technology, legal requirements, and our Services evolve.

Who We Are

Eloquendi LLC, 7901 4th St N Ste 300, St. Petersburg, Florida 33702, United States

Website: https://eloquendi.com

Email: support@eloquendi.com

Scope of This Privacy Policy

This Privacy Policy applies whenever you:

• Create an Account.
• Use the Eloquendi mobile application.
• Visit our website.
• Purchase or manage a subscription.
• Use the AI Coach.
• Contact customer support.
• Otherwise interact with the Services.

It does not apply to third-party websites, applications, or services that we do not own or control.

Definitions

For purposes of this Privacy Policy:

• Account means your registered Eloquendi user account.
• AI Coach means the artificial intelligence-powered coaching and conversational learning features available through the Services.
• AI Interaction Data means prompts, responses, conversation history, voice interactions, and related information generated through your use of the AI Coach.
• AI Service Providers means trusted third-party providers that process AI requests on behalf of Eloquendi.
• Learning Data means information generated through your educational use of the Services, including lesson progress, learning preferences, listening history, search history, achievements, and saved vocabulary.
• Personal Information means information that identifies, relates to, describes, or can reasonably be linked to an identifiable individual.
• Services means the Eloquendi mobile application, website, and related products and services provided by Eloquendi.
• User Content means information you voluntarily submit through the Services, including profile information, support requests, AI prompts, and voice interactions.

Information We Collect

The information we collect depends on how you use the Services.

Personal Information

When you create an Account or otherwise interact with the Services, we may collect:

• Name.
• Email address.
• Password (stored securely using encryption or hashing).
• Profile photograph.

If you sign in using Google or Apple, we may receive profile information that you authorize those providers to share, such as your name, email address, and profile picture.

Learning Data

To personalize your learning experience, we collect Learning Data such as:

• Lessons completed.
• Practice sessions.
• Learning progress.
• Saved vocabulary.
• Listening history.
• Search history.
• Achievement history.
• Learning preferences.
• Other educational activity within the Services.

AI Interaction Data

When you use the AI Coach, we collect AI Interaction Data, including:

• Text prompts.
• AI-generated responses.
• Conversation history.
• Voice interactions used for speech coaching.
• Speech-recognition results.
• AI coaching feedback.

This information enables us to provide conversational practice, personalized coaching, phrasing feedback, and continuity across coaching sessions.

Device and Technical Information

We automatically collect certain technical information, including:

• IP address.
• Device model.
• Operating system.
• Device language.
• Time zone.
• Application version.
• Crash reports.
• Diagnostic information.
• Performance metrics.
• Operating system device identifiers.

This information helps us maintain security, improve reliability, diagnose technical issues, and better understand how the Services are used.

Customer Support Information

If you contact us, we may collect:

• Your name.
• Email address.
• Communications with our support team.
• Files or attachments you voluntarily provide.
• Information reasonably necessary to investigate and resolve your request.

Information We Do Not Intentionally Collect

Unless we clearly disclose otherwise, Eloquendi does not intentionally collect:

• Precise GPS location.
• Contacts.
• Photo library contents (other than a profile photo you choose to upload).
• Continuous microphone recordings outside active voice interactions.
• Payment card information. Subscription payments are processed exclusively by Apple or Google.

How We Use Information

We use Personal Information, Learning Data, and AI Interaction Data to:

• Create and manage your Account.
• Authenticate your identity.
• Deliver the Services.
• Personalize your learning experience.
• Synchronize learning progress across devices.
• Provide AI-powered coaching.
• Process and recognize spoken language.
• Recommend lessons and educational content.
• Respond to customer support requests.
• Improve the quality, reliability, security, and educational effectiveness of the Services.
• Develop and test new features.
• Conduct research, analytics, and quality assurance.
• Detect fraud, abuse, and unauthorized activity.
• Enforce our agreements.
• Comply with legal obligations.

Where feasible and appropriate, we use de-identified, pseudonymized, or aggregated information for research, analytics, testing, and product improvement.

AI Coach

The AI Coach uses AI Interaction Data to deliver conversational practice, phrasing feedback, personalized coaching, and educational recommendations.

Your interactions may be securely processed by trusted AI Service Providers solely for the purpose of providing AI-powered functionality and supporting the Services. We may change AI Service Providers over time, provided they process information in a manner consistent with this Privacy Policy and applicable law.

Review of AI Interaction Data

To improve the quality, safety, and educational effectiveness of the Services, AI Interaction Data may be reviewed using automated systems and, where reasonably necessary, by authorized personnel. Reviews may be conducted to:

• Improve AI-generated responses.
• Improve speech recognition.
• Evaluate educational effectiveness.
• Investigate technical issues.
• Detect fraud, abuse, or misuse.
• Maintain system security.
• Investigate support requests.
• Conduct testing and quality assurance.
• Develop and improve new features.

Where feasible and appropriate, we seek to minimize access to identifiable Personal Information through the use of de-identified, pseudonymized, or aggregated information. Access to identifiable information is limited to personnel with a legitimate business need and appropriate confidentiality obligations.

AI Service Providers

To provide AI-powered features, we use trusted third-party AI Service Providers that process AI Interaction Data on our behalf. These providers process information only as necessary to deliver the requested functionality, maintain the Services, and support authorized operational purposes. We require them to protect information through appropriate contractual, technical, and organizational safeguards. We may replace or add AI Service Providers as our Services evolve, provided their use remains consistent with this Privacy Policy and applicable law.

These AI Service Providers process your information under their own privacy policies and terms of service. While we select providers we consider reputable and rely on the data-protection commitments in their applicable terms, we do not control, and are not responsible for, their independent data practices. We encourage you to review the privacy policies of the third-party providers that help power these features.

Conversation History

Your AI conversation history is stored so you can continue previous conversations, review coaching sessions, and receive a more personalized learning experience. You may delete your AI conversation history through the Services. Once deleted, it will no longer be available to you, although limited copies may remain in secure backups for a reasonable period before being automatically overwritten.

Voice Interactions

Voice features are activated only when you choose to use them.

Audio is processed to provide speech recognition, conversational coaching, and related educational features. Eloquendi does not continuously monitor or record your microphone outside active voice interactions. Voice recordings are used only to recognize and process what you say for language practice; we do not use voice data to identify you or to create a voiceprint.

To perform speech recognition and provide coaching feedback, your voice recordings and the text transcribed from them may be transmitted to and processed by trusted third-party AI and speech-recognition providers.

AI Model Training

Eloquendi does not authorize AI Service Providers to use your AI Interaction Data to train general-purpose foundation models unless we clearly disclose such use and obtain any consent required by applicable law.

AI Limitations

AI-generated responses are intended solely for educational purposes. Although we strive to provide accurate and helpful content, AI responses may occasionally be incomplete, inaccurate, or inappropriate. You remain responsible for evaluating AI-generated content before relying on it, particularly for professional, legal, financial, medical, or other important decisions.

Analytics and Diagnostics

We use analytics and diagnostic tools to understand how the Services are used, improve performance, identify technical issues, and maintain security. These tools may collect information such as:

• Device information.
• App version.
• Feature usage.
• Crash reports.
• Performance metrics.
• Session information.
• Diagnostic data.

Analytics information is used to improve the quality, stability, and educational effectiveness of the Services. Where practical, we use de-identified or aggregated information for long-term analysis.

Notifications

If you grant permission, we may send notifications related to the Services, including:

• Practice reminders.
• Learning progress updates.
• New lessons or features.
• Account and security notifications.
• Important service announcements.

Where required by law, marketing communications will be sent only with your consent. You may manage notification preferences through your device settings or within the Services where available.

Subscription Payments

Paid subscriptions are processed through the Apple App Store or Google Play.

Eloquendi does not receive or store your payment card information. Payment processing, billing, renewals, cancellations, and refunds are governed by the applicable app store's terms and privacy practices.

When We Share Information

We do not sell your Personal Information.

We share information only when necessary to operate the Services, comply with legal obligations, protect our rights, or with your authorization.

Service Providers

We may share information with trusted service providers that perform services on our behalf, including providers of:

• Cloud hosting and infrastructure.
• AI processing.
• Authentication.
• Analytics.
• Crash reporting.
• Customer support.
• Security and fraud prevention.
• Communications and notifications.

These providers may access information only as necessary to perform services for Eloquendi and are required to protect it appropriately.

Legal Requirements

We may disclose information if we reasonably believe disclosure is necessary to:

• Comply with applicable law or legal process.
• Respond to lawful requests from public authorities.
• Protect the rights, property, or safety of Eloquendi, our users, or others.
• Detect, investigate, or prevent fraud, abuse, security incidents, or illegal activity.
• Enforce our agreements or defend legal claims.

Business Transactions

If Eloquendi is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction, subject to applicable legal requirements. Where appropriate, we will provide notice before your Personal Information becomes subject to a different privacy policy.

With Your Consent

We may share information for other purposes when you direct us to do so or otherwise provide your consent.

Data Retention

We retain information only for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests. Retention periods vary depending on the type of information.

Account Information

We retain Account information while your Account remains active. If your Account remains inactive for 24 consecutive months, we may delete or de-identify it and its associated Personal Information, except where retention is required or permitted for legal, accounting, tax, fraud-prevention, security, or dispute-resolution purposes. If you delete your Account, we will delete or de-identify your Personal Information within a reasonable period, unless we are required or permitted to retain certain information for legal, accounting, tax, fraud prevention, security, or dispute resolution purposes.

Learning Data

Learning Data is retained while your Account is active so we can personalize your learning experience, track your progress, and recommend relevant educational content. After Account deletion, Learning Data will be deleted or de-identified, subject to limited backup retention and applicable legal obligations.

AI Interaction Data

AI Interaction Data is retained until you delete it or delete your Account. This allows you to continue conversations, review prior coaching sessions, and maintain personalized learning. Deleted information may remain in secure backups for a limited period before being automatically overwritten.

Customer Support Information

Support communications may be retained for as long as reasonably necessary to respond to requests, improve the Services, resolve disputes, protect our legal interests, and comply with applicable law.

Analytics and Diagnostic Information

Analytics and diagnostic information is retained in accordance with our operational needs and the retention practices of our service providers. Where practical, long-term analytics rely on de-identified or aggregated information.

Privacy by Design

Protecting your privacy is a core principle in the design and operation of the Services. We strive to incorporate privacy considerations throughout the product development process by:

• Collecting only the information reasonably necessary for the intended purpose.
• Limiting access to information to authorized personnel with a legitimate business need.
• Using de-identified, pseudonymized, or aggregated information where feasible for research, analytics, quality assurance, and product improvement.
• Implementing safeguards appropriate to the sensitivity of the information we process.
• Regularly reviewing and improving our privacy and security practices.

Data Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect Personal Information, Learning Data, and AI Interaction Data from unauthorized access, disclosure, alteration, loss, misuse, or destruction. These safeguards may include:

• Industry-standard encryption for data transmitted between your device and our systems.
• Encryption of sensitive data at rest where appropriate.
• Authentication and identity verification controls.
• Role-based access controls that restrict access to authorized personnel.
• Secure cloud infrastructure.
• Security monitoring and logging.
• Software updates and vulnerability management.
• Internal policies governing access to information.

Access to Personal Information is limited to employees, contractors, and service providers who require it to perform authorized responsibilities and who are subject to appropriate confidentiality obligations.

While we take reasonable measures to protect your information, no method of electronic transmission or storage is completely secure. Accordingly, we cannot guarantee absolute security.

International Data Transfers

Eloquendi is based in the United States.

If you access the Services from outside the United States, your information may be transferred to, processed, and stored in the United States or other countries where Eloquendi or its service providers operate. Those countries may have data protection laws that differ from those of your country of residence.

Where required by applicable law, we implement appropriate safeguards for international transfers of Personal Information.

By using the Services, you acknowledge that your information may be processed as described in this Privacy Policy.

Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• Access your Personal Information.
• Correct inaccurate or incomplete information.
• Delete your Personal Information.
• Obtain a copy of certain Personal Information.
• Object to or restrict certain processing activities where permitted by law.
• Withdraw consent where processing is based on consent.
• Opt out of promotional communications.

To protect your privacy, we may request information necessary to verify your identity before processing a request.

Certain information may be retained where required or permitted by law, including for fraud prevention, security, legal compliance, dispute resolution, or enforcement of our agreements.

To exercise your privacy rights, please contact us at support@eloquendi.com. We will respond within the time required by applicable law.

California Privacy Rights

If you are a California resident, you may have additional rights under applicable California privacy laws.

Subject to those laws, California residents may have the right to:

• Know what Personal Information we collect.
• Access their Personal Information.
• Correct inaccurate Personal Information.
• Request deletion of Personal Information.
• Obtain information about our privacy practices.

Eloquendi does not sell Personal Information.

Eloquendi does not share Personal Information for cross-context behavioral advertising as those terms are defined under applicable California law.

California residents may exercise applicable rights by contacting us using the information provided below.

European Economic Area, United Kingdom, and Similar Jurisdictions

If you are located in the European Economic Area (EEA), the United Kingdom, or another jurisdiction with similar privacy laws, we process Personal Information only where we have a lawful basis for doing so. Depending on the circumstances, those lawful bases may include:

• Performance of a contract.
• Compliance with legal obligations.
• Legitimate interests that are not overridden by your rights and freedoms.
• Your consent, where required by applicable law.

Where applicable, you also have the right to lodge a complaint with your local data protection authority.

Children's Privacy

The Services are intended for individuals who are at least 18 years of age.

We do not knowingly collect Personal Information from individuals under 18. If we become aware that we have collected such information without appropriate authorization, we will take reasonable steps to delete it.

If you believe someone under 18 has provided Personal Information to us, please contact us at support@eloquendi.com.

Cookies and Similar Technologies

Our website and certain features of the Services may use cookies, local storage, pixels, and similar technologies to:

• Operate and maintain the website.
• Remember your preferences.
• Improve functionality.
• Analyze traffic and usage.
• Enhance security.
• Support the performance of the Services.

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of portions of the website.

If we publish a separate Cookie Policy in the future, it will be incorporated into this Privacy Policy by reference.

Do Not Track Signals

Some web browsers transmit "Do Not Track" ("DNT") signals. Because there is currently no universally accepted standard for responding to DNT signals, Eloquendi does not currently respond to them.

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 business practices.

When we make material changes, we will update the Effective Date at the beginning of this Privacy Policy and provide additional notice where required by applicable law.

Your continued use of the Services after an updated Privacy Policy becomes effective constitutes your acknowledgment of the revised Privacy Policy.

Our Commitment

We appreciate the trust you place in Eloquendi.

Our mission is to help people communicate with greater confidence, and protecting your privacy is an essential part of that mission.

As our Services evolve, we remain committed to handling your information responsibly, strengthening our privacy and security practices, and being transparent about how your information is collected and used.

Contact Us

If you have questions about this Privacy Policy, our privacy practices, or wish to exercise your privacy rights, please contact us:

Eloquendi LLC, 7901 4th St N Ste 300, St. Petersburg, FL 33702, United States

Website: https://eloquendi.com

Email: support@eloquendi.com