1. Introduction
Luma Speak (“Luma”, “we”, “us”) is an AI language learning app. We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains what we collect, how we use it, and the choices you have when using our mobile apps and website (collectively, the “Services”).
2. Information We Collect
- Account Information: Name, email, and authentication details (including when you sign in with Apple or Google).
- Subscription & Purchases: Records related to in-app purchases and subscriptions processed by the App Store or Google Play (we do not receive your full payment card number).
- Learning & Usage Data: Lessons started/completed, roleplays and tutoring selections, progress and streaks, vocabulary you save, session timestamps, in-app settings, and feature interactions.
- Audio & Speech Data (if you grant microphone access): Short-term audio snippets for speech recognition and AI feedback, derived transcripts, pronunciation scores, and language detection. We process audio to deliver real-time feedback; audio may be streamed to our speech/AI providers for processing.
- Device & Diagnostics: App version, device model, OS version, language/locale, crash logs, and performance data to help us troubleshoot and improve stability.
- Cookies & SDKs: On the web we use cookies; in the app we use mobile SDKs (e.g., analytics, crash reporting) to understand usage and improve the experience.
- Approximate Location: We may infer coarse location from your IP or app store region for language, pricing, and legal compliance. We do not collect precise GPS data.
3. How We Use Your Information
- Provide the Service: Deliver lessons, real-time conversations, speech recognition, feedback, and progress tracking.
- Personalize Learning: Adapt difficulty, content, hints, and recommendations based on your activity and goals.
- Maintain & Improve: Analyze usage, fix bugs, enhance performance, and develop new features.
- Subscriptions & Billing: Manage entitlements and subscription status via the App Store or Google Play.
- Safety & Compliance: Detect misuse, enforce our Terms, and comply with legal obligations.
- Communications: Send essential service messages. With your consent or as permitted by law, send tips, product updates, and offers (you can opt out anytime).
4. Legal Bases (EEA/UK Users)
We process personal data under legitimate interests (to provide and improve the app), contract (to deliver subscribed features), consent (e.g., microphone permissions, marketing), and legal obligations.
5. Sharing Your Information
We do not sell your personal information. We may share:
- Service Providers: Cloud hosting, speech/AI processing, analytics, crash reporting, customer support, and email delivery partners—only as needed to operate the Service.
- App Stores & Payment Processors: Apple App Store and Google Play to validate purchases and manage subscriptions.
- Legal & Safety: When required by law or to protect rights, safety, and security.
- Business Transfers: In connection with a merger, acquisition, or asset sale, in which case we will notify you where required.
6. Data Retention
We retain personal data for as long as necessary to provide the Service, for legitimate business purposes, and to comply with legal requirements. You may request deletion of your account and personal data in-app (where available) or by contacting support@lumaspeak.com.
7. Security
We use technical and organizational measures to protect your data. No method of transmission or storage is completely secure, but we work to protect your information against unauthorized access, alteration, disclosure, or destruction.
8. Your Choices
- Permissions: You can enable/disable microphone and notification access in your device settings.
- Marketing: Opt out of marketing emails via the unsubscribe link or by contacting us.
- Access, Correction, Deletion: Request a copy of your data, ask us to correct inaccuracies, or delete your data by contacting support@lumaspeak.com.
- In-App Controls: Manage preferences like translation toggles, voice options, and lesson settings within the app.
9. Children’s Privacy
Luma is not directed to children under 13 (or the minimum age required in your country). We do not knowingly collect personal data from children under that age. If you believe a child has provided personal data, please contact us so we can take appropriate action.
10. International Data Transfers
We may process and store information in countries outside of your own. Where required, we implement appropriate safeguards for cross-border transfers.
11. Region-Specific Rights
Depending on your region (e.g., EEA/UK, certain U.S. states), you may have additional rights regarding access, portability, restriction/objection, and non-discrimination. We will honor applicable legal requests.
12. Third-Party Links
The Services may link to third-party sites or services. Their privacy practices are governed by their own policies. We encourage you to review those policies.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be notified in-app or by email. The “Last Updated” date above will reflect the latest version.
14. Contact Us