Privacy Policy
Last updated: October 7, 2026
This policy explains what data Learnes collects, why, who processes it and how you can delete it.
1. Data controller
[Company name], [address], [contact email]. Data protection contact: [privacy email].
2. What we collect
- Account data: email, name, and your sign-in method (email or Google).
- Profile and learning data: goals, exam, target score, exam date, level, native language, interface language, timezone, theme.
- Practice data: practice sessions, lesson and game progress, XP and achievements.
- Voice recordings of your answers.
- Generated from your recordings: transcripts, scores, corrections, and saved mistakes and phrases.
- Talk live: conversation transcripts.
- Logs: usage, AI cost and security logs, including rate-limit records with hashed IP addresses.
- Payments: handled by Stripe. We never see or store your card number.
3. Why we use it and the legal basis (GDPR and KVKK)
- To provide the service: contract.
- For security, abuse prevention and improving the service: legitimate interest.
- For optional analytics and marketing emails: consent, which you can withdraw at any time.
4. AI processing
- Speech-to-text: your recordings go through fal.ai to ElevenLabs Scribe v2.
- Feedback: the text goes through fal.ai's OpenRouter router to OpenAI GPT-6 Luna for feedback, hints and game answer checks.
- Tutor and examiner voices: generated with Google Gemini TTS via fal.ai.
- Talk live: conversations stream through fal.ai to xAI Grok Voice.
Scores are generated automatically. You can retry an answer or ignore the feedback. Whether these providers may use data to train their models: [CHECK provider terms].
5. Other service providers
- Lovable Cloud: hosting, database, sign-in and file storage.
- Stripe: payments.
- [Analytics provider]: the site currently uses no third-party analytics [CHECK before launch].
6. International transfers
Some providers process data outside your country, including in the United States. We rely on [Standard Contractual Clauses / adequacy decisions / KVKK transfer mechanisms] [CHECK].
7. How long we keep data
- Voice recordings: [__ days]
- Transcripts and feedback: [__]
- Talk live transcripts: [__]
- Account data: until you delete your account
- Rate-limit counters: 2 days
- Other security logs: [__]
8. Your rights
Under GDPR and KVKK you may access, correct, delete or export your data. You may also object to or restrict processing, withdraw consent, and complain to your data protection authority (in Turkey, the KVKK Board). Email [privacy email]. We reply within [30] days.
How to delete your data yourself
- Open Settings.
- "Delete my recordings" removes all recordings, transcripts, scores and saved mistakes.
- "Delete my account": type DELETE to confirm. This removes your data and your login.
9. Children
Learnes is not for anyone under [16] [CHECK].
11. Changes and contact
We will post updates here and tell you about important changes. Contact: [privacy email].
This draft is provided for your review and should be checked before publication.