Learn English, Spanish: Learna

"We may ask for your permission to access your device's photo file or gallery app, camera and audio recording tools, to provide certain services, when you are using the Application, such as to generate Output for photos you share or to transcribe your audio recording. We may collect data about the device you use to interact with our Services, including the device name, device ID, its model, its manufacturer, region information, device's operating system, device identifiers, hardware model."

The app requests access to camera, microphone, photo gallery, and collects extensive device identifiers and hardware information. While some access supports core features, the breadth of device data collected (device ID, hardware model, manufacturer, OS) goes beyond what a language learning app strictly requires.

"Please note that we may be able to determine the general area of your device's location when it interacts with our Services, based on the information associated with your IP address and the region information of the device."

The app derives your geographic location from your IP address and device region information, used for service personalization like language display. While described as 'general area,' this is passive location tracking without explicit opt-in.

"The Company may also transfer your Marketing Data to service providers (incl. Google, Apple, Facebook SDK, Adjust and Firebase Analytics, which are embedded into our service) for the purpose of conducting marketing analysis studies and execution of advertising (including personalised advertising)/campaign/promotion processes. Please note that we engage with third-party AI service providers ("Third-Party AI Service Providers"), which are essential for the duly operation of the Application by means of processing and creating AI-generated Output."

Multiple third-party SDKs (Google, Apple, Facebook, Adjust, Firebase) are embedded in the app and collect marketing data including advertising identifiers. User content is also shared with AI providers (OpenAI, Google, ElevenLabs, Soniox) including voice recordings and user messages.

"When you give us permission, we may collect your Usage Data; and an identifier for advertisers designated in your mobile device used in accessing our services (the Identifier for Advertisers-IDFA), an identifier for vendors/developers designated to your mobile device (the Identifier for Vendors-IDFV), Google advertising ID (GAID); identifier for Firebase analytics."

The app collects multiple advertising and device identifiers (IDFA, IDFV, GAID, Firebase ID) which are commonly used to track users across apps and services for advertising purposes.

"Your data will be stored for the duration specified in the applicable legislation or until the purpose of processing ceases to exist. The Company may continue to store your personal data, even after the expiry of the purpose of its use provided that it is required by other laws or separately a consent is granted by you in this regard. Additionally, your data may be further stored even after the fulfilment of the purpose of processing on the legal basis of the necessity of the establishment, execution and protection of our legal rights until the end of legal limitation periods."

No specific deletion timelines are provided. Data can be retained indefinitely after its original purpose expires, justified by vague references to legal requirements, user consent, or potential legal claims.

"We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Your continued use of the Services after the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated terms, unless applicable law requires a different form of acceptance (such as explicit consent for certain types of changes."

The company can change the privacy policy at any time, and continued use of the service is treated as acceptance of the new terms. While they promise notice for material changes, no opt-out mechanism beyond stopping use is provided.

"Carrying out the auto-renewable subscriptions for giving users access to content, services, or premium features in our Service. We may collect order information directly from you, our marketing vendors or our payment processors. This information includes order date, payment date, subscription type, billing period, billing document, payment amount, due amount, payment status and any associated transaction identifiers."

The policy mentions auto-renewable subscriptions but provides no details about cancellation procedures, renewal notice, or how to stop recurring charges, leaving users without clear guidance on managing their subscriptions.