Lovable App

1. Introduction

SYNCWAVE LTD ("Talkrly", "we", "us", "our") is the data controller for personal information processed through the Talkrly website, applications, and related services (collectively, the "Service"). This Privacy Policy explains what information we collect, how we use it, with whom we share it, and the rights and choices you have. It applies whenever you interact with Talkrly, whether you have an account or not.

2. Information We Collect

2.1 Account Information

When you create an account we collect your name, email address, password (hashed), language preferences, learning goals, and any optional profile details you provide.

2.2 Voice Recordings and Conversation Data

Talkrly is a voice-based product, so handling your voice data responsibly is core to how we operate. When you speak to the AI tutor:

We capture an audio recording of your speech and transmit it securely (TLS) to our AI providers for transcription, pronunciation scoring, and conversational response generation.
The audio and the transcript are linked to your account so we can surface feedback, track progress, and let you replay past sessions.
We use voice data only to provide and improve the Service. We do not sell your voice recordings, and we do not use them to identify you biometrically or to train third-party advertising models.
Voice recordings are retained for the period described in Section 7 and can be deleted earlier on request.

2.3 Usage Data

We collect data about your activity in the Service, including lessons completed, scenarios practiced, streaks, time spent, scores, mistakes corrected, and aggregated learning progress.

2.4 Payment Information

Payments are processed by PCI-DSS-compliant third-party payment processors. We receive billing metadata (plan, last 4 digits of card, country, transaction ID) but do not see or store full card details.

2.5 Device and Technical Information

We collect technical data such as IP address, browser type and version, operating system, device identifiers, language settings, referrer URL, and timestamps of access.

2.6 Cookies and Tracking Technologies

We use cookies, local storage, and similar technologies to keep you signed in, remember preferences, measure performance, and (with your consent) for limited marketing. See our Cookie Policy for details.

3. How We Use Your Information

To provide, personalize, and operate the Service.
To generate pronunciation feedback, lesson recommendations, and progress reports.
To improve our AI models and lesson content (using aggregated or de-identified data wherever practical).
To process payments, manage subscriptions, and handle billing inquiries.
To send transactional notifications and, with your consent, product updates.
To detect, prevent, and respond to fraud, abuse, and security incidents.
To comply with legal obligations and enforce our Terms.

4. Legal Basis for Processing (GDPR / UK GDPR)

Contract: to deliver the Service you subscribed to.
Consent: for optional features such as marketing emails and non-essential cookies. You may withdraw consent at any time.
Legitimate interests: to secure the Service, prevent fraud, improve quality, and run our business - balanced against your rights.
Legal obligation: to comply with tax, accounting, and regulatory requirements.

5. Sharing Your Information

We do not sell your personal information to advertisers and we do not share voice recordings with third parties for marketing. We share data only with:

Service providers acting on our behalf under written data-protection agreements, including cloud hosting, AI/ML providers, payment processors, analytics, customer support, and email delivery.
Legal authorities when required by applicable law, court order, or to protect our rights, users, or the public.
Business transfers: if Talkrly is involved in a merger, acquisition, financing, or sale of assets, your data may be transferred under continued protection consistent with this Policy.

6. International Data Transfers

Talkrly operates globally and your data may be processed in countries outside the UK/EEA, including the United States. Where data is transferred internationally, we rely on appropriate safeguards such as the UK International Data Transfer Addendum, EU Standard Contractual Clauses, or equivalent legal mechanisms.

7. Data Retention

Account data is retained for as long as your account is active and for a reasonable period afterwards to comply with legal, tax, and accounting obligations.
Voice recordings and transcripts are retained for up to 24 months from creation to support your learning history and progress, after which they are deleted or anonymized. You may request earlier deletion at any time.
Billing records are retained as required by applicable tax law (typically 6-7 years).
Backups are rotated regularly and purged in line with our retention schedule.

8. Your Rights

Depending on where you live - including under the EU GDPR, UK GDPR, and California CCPA - you may have the following rights regarding your personal data:

Right to access the personal data we hold about you.
Right to rectification of inaccurate or incomplete data.
Right to deletion ("right to be forgotten").
Right to restrict processing in certain circumstances.
Right to data portability in a structured, machine-readable format.
Right to object to processing based on legitimate interests or direct marketing.
Right to withdraw consent at any time where processing is based on consent.
Right to lodge a complaint with your local data protection supervisory authority (in the UK, the Information Commissioner's Office; in the EEA, your national authority).

9. How to Exercise Your Rights

To exercise any of these rights, email privacy@talkrly.app from the email address associated with your account. We will respond within 30 days (extendable by up to 60 days for complex requests, in which case we'll let you know). We may need to verify your identity before fulfilling certain requests.

10. Children's Privacy

Talkrly is intended for users 13 years of age and older (or the minimum age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under that age. If you believe a child has provided us data, contact us and we will delete it promptly.

11. Cookies

For information about the cookies and similar technologies we use, how long they last, and how to control them, please review our Cookie Policy.

12. Data Security

We implement administrative, technical, and physical safeguards designed to protect your data, including encryption in transit (TLS) and at rest, strict access controls, least-privilege permissions, regular security reviews, and audit logging. No system is 100% secure, but we work continuously to reduce risk and respond quickly to incidents.

13. Third-Party Links

The Service may contain links to third-party websites or services that are not operated by Talkrly. We are not responsible for the privacy practices of those third parties; please review their privacy policies before providing any information.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by email or in-app notice prior to taking effect. The "Last updated" date at the top reflects the most recent revision.

15. Contact

Data Controller: SYNCWAVE LTD
18th & 19th Floors, 100 Bishopsgate
London, United Kingdom, EC2N 4AG
Privacy: privacy@talkrly.app
Support: support@talkrly.app