Privacy Policy — Octolingo

Last updated: August 12, 2026

This Privacy Policy explains how Octolingo ("we", "us", "the App") collects, uses, and protects your information when you use our mobile application. Octolingo is operated by TIE d.o.o., Rudarska cesta 6, 3320 Velenje, Slovenia, European Union ("we", "Data Controller").

If you have questions about this policy, contact us at octolingoapp@gmail.com.

1. Information We Collect

1.1 Information you provide

• Account information, if you create an account: email address, username, display name (optional)
• Google account information, if you sign in with Google: your Google identifier, name, and profile picture as provided by Google
• Password (if registering with email/username), stored only in one-way hashed form — never stored or accessible in readable form, including by us
• Onboarding responses (e.g. vocabulary level, known grammar tenses, daily learning goals)
• Voice recordings, when you use the AI conversation practice feature
• Payment information, if you purchase a subscription (processed by our payment provider — see Section 3; we do not store your card details)

1.2 Information collected automatically

• App usage data: cards reviewed, listening time, streak/progress statistics, feature interactions
• Device information: device type, operating system version, app version
• Approximate performance/diagnostic data (crash logs, errors), if applicable

1.2b Cloud backup (signed-in users only)

If you are signed in, your learning progress (cards, review history, streak, achievements) is periodically backed up to our server, so it is not lost if you change devices or reinstall the App. This backup is accessible only through your authenticated account. If you are not signed in, no backup occurs — your device is the only place your progress is stored.

When you are signed in, some app usage events are linked to your account (instead of an anonymous device identifier) to help us understand usage and improve the App.

1.3 Guest use

You can use the App without creating an account. If you choose not to sign in, we do not collect any of the account information described in Section 1.1, and your learning progress remains only on your device. We do not access your contacts, photos, or other apps on your device.

2. How We Use Your Information

We use the information collected to:

• Provide and personalize the learning experience (spaced repetition scheduling, content recommendations)
• Track your progress, streaks, and daily goals
• Process voice input for AI conversation practice and generate feedback
• Provide grammar explanations via AI-generated content
• Process subscription payments
• Improve app performance and fix errors
• Communicate with you about your account or the service, if you have provided contact information

We do not sell your personal information to third parties.

3. Third-Party Services

To provide certain features, we share limited data with the following third-party service providers. Each operates under its own privacy policy:

Some of these providers are located outside the European Economic Area (EEA), including in the United States. Where this is the case, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, or the provider's participation in an equivalent legal data transfer framework, to ensure your data remains protected.

3b. AI-Generated Content

Some audio content in the App (educational podcast episodes) is generated using AI voice synthesis (ElevenLabs — see Section 3). Our AI conversation practice feature involves direct interaction with an AI system, not a human. Where required by applicable law (including the EU AI Act), we clearly indicate in the App when you are interacting with an AI system or engaging with AI-generated content.

4. Data Retention

We retain your data for as long as your account is active or as needed to provide the service. Learning progress and statistics are retained to allow spaced-repetition scheduling to function correctly. You may request deletion of your data at any time (see Section 6). If you have an account, your account data and cloud backup are retained until you delete your account (see Section 6) or request deletion by contacting us.

Voice recordings used for AI conversation practice are processed to generate a response and are not retained longer than necessary for this purpose, unless you have opted into a feature that explicitly stores them (this will be clearly indicated in-app).

5. Data Security

We take reasonable technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Your Rights

6.1 If you are in the European Economic Area (GDPR)

You have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data ("right to be forgotten")
• Request a copy of your data in a portable format
• Object to or restrict certain processing
• Withdraw consent at any time, where processing is based on consent
• Lodge a complaint with your local Data Protection Authority (in Slovenia: Informacijski pooblaščenec, www.ip-rs.si)

If you have an account, you can delete your account and all associated server-side data at any time directly in the App (Settings → Delete Account). This is immediate and does not require contacting us. Your local learning progress on your device is not affected by this action unless you separately choose to clear it.

To exercise these rights, contact us at octolingoapp@gmail.com.

6.2 If you are a California resident (CCPA/CPRA)

You have the right to:

• Know what personal information we collect and how it is used
• Request deletion of your personal information
• Opt out of the "sale" or "sharing" of personal information (note: we do not sell your data)
• Non-discrimination for exercising these rights

To exercise these rights, contact us at octolingoapp@gmail.com.

7. Children's Privacy

Octolingo is not directed at children under the age of 13 (or the relevant minimum age in your jurisdiction, e.g. 16 in some EU member states without parental consent). We do not knowingly collect personal information from children below this age. If you believe a child has provided us with personal information, please contact us at octolingoapp@gmail.com and we will take steps to delete it.

8. International Users

Octolingo is operated from Slovenia, European Union. If you use the App from outside the EU, your information may be transferred to and processed in Slovenia and in the countries where our third-party providers (Section 3) operate, including the United States.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Continued use of the App after changes constitutes acceptance of the updated policy.

10. Contact Us

If you have questions or requests regarding this Privacy Policy or your personal data, contact:

TIE d.o.o.
Rudarska cesta 6, 3320 Velenje, Slovenija
Email: octolingoapp@gmail.com