Privacy Policy

Last Updated: 30/03/2025

1. Introduction

Welcome to lingly.ai ("lingly", "we", "us", "our"). Lingly Limited provides language screening, real-time conversation assistance, and personalised language training services aimed primarily at care workers and other frontline professionals, often procured by their employers (our "Customers"). Our services include our website (lingly.ai), our web-based training platform, our iOS Conversation Helper application, and our Language Screening service (collectively, the "Services").

This Privacy Policy explains what personal data we collect when you (an individual "User", which may include employees or candidates of our Customers) use our Services, how we use and share that data, and your rights concerning your data.

This Privacy Policy forms part of our Terms of Use. By using our Services, you acknowledge you have read and understood this Privacy Policy. If you do not agree, please do not use the Services.

2. Information We Collect

We collect information to provide and improve our Services. This includes:

a. Information You Provide Directly:

  • Account Registration & Onboarding: When you or your employer creates an account or you onboard onto our training platform, we may collect your name, email address, native language, the language you are learning, your assessed language level, desired language level, timezone, locale preference, job role, employer name, industry, phone number (primarily for Language Screening), self-identified language difficulties, learning goals, daily commitment level, and how you heard about us (`acquisition_route`). If you sign up using Google, we may receive your name, email address, and Google avatar URL.

  • Payment Information: If you purchase services directly, our payment processor (e.g., Stripe) collects your payment card details. We do not store your full card details ourselves.

  • Communications: If you contact us directly (e.g., via email support at hello@lingly.ai), we collect your name, email address, and the content of your communication.

b. Information Provided by Employers (Our Customers):

  • Language Screening: For our Language Screening service, your potential or current employer (the Data Controller) may provide us with your name and phone number to facilitate the screening call.

c. Information Collected During Service Use:

  • Language Training Platform (`/learn`): We collect data about your learning progress, including lessons started/completed, performance in exercises (text and voice inputs for roleplays), vocabulary words learned and reviewed, quiz scores, fluency tip interactions, and learning streaks.

  • Language Screening Service: When conducting a screening call initiated by an employer, our telephony provider (e.g., Twilio) temporarily processes and stores audio recordings and raw transcripts to enable the assessment. This audio and raw transcript data is deleted by us shortly after processing. We retain the candidate's phone number (provided by the employer) and the generated assessment results (including scores, analysis descriptions, and recommendations) to provide the report to the requesting employer. We retain this assessment data as instructed by the employer or delete it after a reasonable period if no instruction is given.

  • Conversation Helper (iOS App):

    • Microphone Access: The app requires your explicit permission through iOS settings to access the microphone for its core functionality.

    • Real-time Audio Processing: When you activate the recording feature, audio is captured and processed in real-time for speech-to-text transcription and translation. This processing may occur on our servers and involves sending data to third-party AI service providers (e.g., Google Speech-to-Text, potentially PlayHT). The original audio recording is not stored by lingly.ai after real-time processing.

    • Transcript Storage: The text *transcriptions* and *translations* generated during a Conversation Helper session **are stored** in our database, linked to your user account, and encrypted. We store this to provide you with conversation history within the app, to debug issues, and potentially to improve the underlying AI models (often using anonymized or aggregated data). This data is retained until you request its deletion or your account is closed, subject to our general retention policies (see Section 7).

  • Automatically Collected Data (Website & Platform):

    • Log & Device Data: When you access our website or platform, we automatically collect your IP address, browser type, operating system, device identifiers, settings, and the date/time of your visit.

    • Usage Data: We collect information about how you interact with our website and platform, such as pages visited, features used, and session duration. We do not currently implement detailed analytics tracking within the iOS Conversation Helper app or the Language Screening service itself beyond basic operational logging.

  • Cookies and Tracking Technologies (Website): We use cookies and similar technologies (like Google Analytics, Hotjar) on our website to operate the site, understand how visitors use it, and for marketing purposes. You can manage cookie preferences through your browser settings and our website's cookie consent tool.

3. How We Use Your Information

We use the information we collect for purposes including:

  • Providing and Maintaining Services

  • Personalizing Language Training

  • Conducting Language Screening (as a processor for employers)

  • Enabling Conversation Helper functionality

  • Improving Services (analyzing usage, diagnosing issues, developing features)

  • Communication (service updates, support, marketing with consent)

  • Reporting to Employers (as per contractual agreements, often aggregated/anonymized)

  • Security and Fraud Prevention

  • Legal Compliance

4. Legal Basis for Processing (UK GDPR)

We rely on the following legal bases to process your personal data:

  • Contractual Necessity: To provide the core Services.

  • Legitimate Interests: For service improvement, personalization, security, analytics, screening, and transcript storage, ensuring these don't override your rights.

  • Consent: For marketing emails, non-essential cookies, and microphone access.

  • Legal Obligation: To comply with legal duties.

5. How We Share Your Information

We do not sell your personal data. We may share it with:

  • Service Providers: Third parties assisting with our operations, categorized as: Cloud Hosting (e.g., Render.com, Vercel), Authentication & Database (e.g., Supabase), Payment Processing (e.g., Stripe), AI Processing (e.g., Google Cloud AI, PlayHT), Telephony (e.g., Twilio), Email Delivery (e.g., Resend), Internal Communications (e.g., Slack). These providers are contractually obligated to protect data.

  • Employers (Our Customers): Language Screening results are shared with the requesting employer. Training platform progress reports (potentially including individual progress as contractually agreed, otherwise aggregated/anonymized) may be shared with the employer providing access.

  • Legal Requirements: When required by law or to protect rights and safety.

  • Business Transfers: In case of merger, acquisition, or asset sale.

6. Data Security

We implement technical and organizational measures like encryption (at rest and in transit), access controls, and secure authentication to protect your data. However, no system is 100% secure.

7. Data Retention

We retain personal data as long as needed for the purposes described, to provide Services, or as required by law. Account data is generally deleted upon request or account closure. Audio data is ephemeral. Screening results are retained as instructed by the employer or deleted after a reasonable period. Conversation Helper transcripts are retained until deletion request or account closure.

8. Your Data Protection Rights (UK GDPR)

You have rights to access, correct, delete, restrict, port, or object to the processing of your data, and withdraw consent. To exercise these rights, please contact us at hello@lingly.ai. You can also complain to the ICO.

9. Children's Privacy

Our Services are not intended for or directed at individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we learn we have collected such data, we will delete it.

10. International Data Transfers

Your data may be processed outside the UK/EEA (e.g., in the US). We use appropriate safeguards like the UK Addendum to EU Standard Contractual Clauses or Adequacy Decisions for such transfers. Our primary data storage is currently located in Frankfurt (EU).

11. Third-Party Links

Our Services may link to third-party sites. We are not responsible for their privacy practices. Please review their policies.

12. Changes to This Privacy Policy

We may update this policy. Significant changes will be notified via our website and/or email. Continued use after changes implies acceptance.

13. Contact Us

For questions about this policy or our data practices, please contact us at hello@lingly.ai.