Privacy Policy

# Langlio — Privacy Policy

Effective Date: 2026-06-01
Last Updated: 2026-06-12

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## 1. Introduction

Welcome to Langlio, a mobile language-learning application that helps people learn languages through AI-powered conversation, diary writing, saved phrase libraries, and personalized practice. This Privacy Policy explains what information we collect when you use Langlio, how we use it, who we share it with, and the choices and rights you have over your personal data.

This Policy applies to the Langlio mobile application, our supporting websites, and any related services we make available (together, the "Services"). It is published by Langlio Ltd ("Langlio," "we," "us," "our"), the operator of the Services.

We take privacy seriously. We try to collect only what we need to make Langlio work well, keep it safe, and improve it over time. Where the law requires it, including under the EU and UK General Data Protection Regulation ("GDPR" and "UK GDPR") and the California Consumer Privacy Act, as amended by the CPRA ("CCPA"), this Policy explains the legal basis for processing and the rights you have. Please read it together with our Terms of Service.

If you do not agree with this Policy, please do not use the Services.

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## 2. Information We Collect

We collect personal information in three ways: you give it to us, we collect it automatically when you use the Services, and we receive it from third parties, for example, an authentication provider you choose to sign in with.

### 2.1 Account & Profile Information

- Email address.
- Sign-in provider identifiers when you use third-party sign-in, such as Sign in with Google, Sign in with Apple, or email/password.
- Display name, avatar if you provide one, and any optional profile details you enter.
- Language preferences, including native language, target language, and level.
- Account settings and notification preferences.

Profile photos and avatars: You may choose an in-app avatar or select a profile image from your device. Based on the current app behavior, selected profile images are used to display your profile in the app and are not uploaded to Langlio servers. When you select a profile image, Langlio may store a local image reference in your account/profile settings so the app can display it, but the image file itself is not uploaded to Langlio servers based on the current app behavior. If this changes in a future feature, Langlio will update this Policy and the relevant app disclosures.

### 2.2 Learning Content You Create

- Learning progress, lesson history, achievements, and streaks.
- Conversation history with AI tutors and scenario partners inside the Services.
- Diary or journal entries you write inside Langlio.
- Saved phrases, vocabulary, flashcards, and other items you choose to save to your library.
- Voice or text input you submit to language exercises, when applicable.

### 2.3 Subscription & Payment Information

Where Langlio offers paid plans and you purchase one, we may receive:

- Subscription status, plan, renewal date, and entitlements.
- Receipts and transaction identifiers from the App Store or Google Play.
- We do not receive or store full payment card details. Payment is handled by the platform store and/or our payment processor.

### 2.4 Device & Usage Information

- Device type, operating system, OS version, app version, language, region, and time zone.
- Approximate location derived from IP address. We do not collect precise GPS location unless you grant a specific permission for a feature that requires it.
- App events such as screens viewed, features used, taps, session length, and similar interaction signals.
- Crash logs, performance metrics, and diagnostic information, where such tools are enabled.
- Anonymous or pseudonymous identifiers used for diagnostics and abuse prevention, where such tools are enabled. Langlio does not currently use advertising identifiers or serve third-party advertising.

### 2.5 Communications

- Messages you send to support and any information included in them.
- Feedback, survey responses, and bug reports you submit to us.

### 2.6 Notifications

- Langlio currently uses local device notifications (such as daily reminders and streak nudges) that are scheduled on your device after you grant notification permission. We do not currently collect or store a push-notification token on our servers. If we introduce server-sent ("remote") push notifications in future, a push token issued by your operating system would be used, and we will update this Policy and our Google Play Data Safety disclosure before doing so.

### 2.7 Voice Recordings

- Voice recordings: If you choose to use voice practice, Langlio may access your device microphone to record your speech for language-learning features such as pronunciation or conversation practice. Voice recording is optional and only starts when you use a voice feature and grant microphone permission.
- Voice recordings are processed on your device and are not uploaded to Langlio servers unless a future feature clearly tells you otherwise.

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## 3. AI & Conversation Data

A core part of Langlio is AI-generated practice. Langlio processes chat messages, scenario replies, Conversation Room messages, diary entries, saved phrases, and other learning content so the app can generate AI-powered responses, corrections, translations, practice suggestions, flashcards, and progress features. This includes alternate-script and non-Latin learning support, such as the Conversation Builder, script-aware practice, and transliteration/translation help for languages where puzzle formats like crossword or wordsearch are not appropriate.

When you interact with AI chat, scenarios, Conversation Room, diary helpers, grammar audits, or any other AI-powered feature:

- Your text input is sent to one or more third-party AI providers we work with so that a response, correction, translation, or practice item can be generated. Voice recordings made for pronunciation practice are processed on your device and are not sent to AI providers.
- AI providers may process your input transiently to produce a reply, apply safety filters, and return results to the app.
- Some AI providers may temporarily retain inputs and outputs in line with their own policies for safety, abuse prevention, and service reliability. We choose providers that contractually limit how that content can be used.
- We may also store conversation history in your account so that you can revisit your learning, and to power features like progress tracking and personalization.

AI responses are generated automatically and are intended for language learning and practice only. They are not professional advice, including medical, legal, financial, mental-health, or other professional advice, and may contain mistakes, including inaccurate or out-of-date information. You should not rely on them for any decision that requires expert judgment.

Please do not share highly sensitive personal information, for example government identifiers, payment card data, health diagnoses, sensitive financial details, or information about others who have not consented, in chat, diary, or any AI-facing feature.

Where lawful and appropriate, Langlio may use aggregated, anonymized, or de-identified usage insights, safety signals, and product analytics to improve the Services, educational systems, and AI-powered features.

We do not use private diary entries or personally identifiable conversation content for advertising purposes.

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## 4. How We Use Your Information

We use personal information to:

- Provide the Services — create and authenticate your account, deliver lessons, conversations, diary features, saved phrases, and AI-generated content.
- Personalize your learning — tailor recommendations, daily goals, scenario suggestions, vocabulary, and difficulty based on your activity.
- Operate features — sync data across devices, deliver notifications you have enabled, and remember your preferences.
- Process subscriptions — manage your plan, entitlements, renewals, refunds, and receipts via the relevant app store or payment provider.
- Communicate with you — respond to support requests, send service-related messages, and, with your consent or as otherwise permitted, send product updates.
- Improve the Services — analyze usage, debug crashes, measure performance, run experiments, and develop new features and educational content.
- Train and refine learning systems — where lawful, we may use de-identified or aggregated data to improve our recommendation models, content libraries, and the quality of AI-driven educational features. We will respect any applicable consent or opt-out you have given.
- Keep Langlio safe — detect, investigate, and prevent abuse, fraud, harmful content, and violations of our Terms of Service, and protect the rights, property, and safety of users and Langlio.
- Comply with law — meet our legal, regulatory, accounting, and reporting obligations.

We do not sell your personal information for money, and we do not use the content of your diary, conversations, or saved phrases to serve third-party advertising.

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## 5. Legal Bases for Processing (GDPR / UK GDPR)

If you are in the European Economic Area, the United Kingdom, or another jurisdiction that requires a legal basis for processing, we rely on the following bases:

- Performance of a contract — to deliver Langlio to you under our Terms of Service, such as creating your account, syncing your learning data, and processing subscriptions.
- Legitimate interests — to operate, secure, analyze, and improve the Services, to prevent fraud and abuse, to keep AI features safe, and to communicate with you about your account, where these interests are not overridden by your rights and freedoms.
- Consent — for marketing communications you have opted into, optional analytics or personalization where required by law, push notifications, and certain device permissions, such as microphone. You can withdraw consent at any time, without affecting prior lawful processing.
- Legal obligation — to comply with applicable laws, court orders, and regulatory requirements.

If you would like more detail about the legal basis for a specific processing activity, please contact us using the details in Section 17.

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## 6. Cookies, Analytics & Mobile Identifiers

Langlio is primarily a mobile application and generally does not rely on browser cookies inside the app. We use mobile analytics and diagnostic tools to understand how the app is used and to keep it stable. These tools may collect:

- App events and screen views.
- Crash and performance data.
- Device, OS, and app version information.
- Pseudonymous identifiers, such as installation IDs or, where permitted, advertising identifiers.

Where we enable analytics or crash-diagnostics tools, they may collect app events, crash and performance data, and device, OS, and app version information. We keep our Google Play Data Safety disclosure consistent with the tools actually in use, and the exact set of providers may change as we evolve the Services.

Langlio does not currently use advertising identifiers or serve third-party advertising. On iOS, if we ever introduce tracking that requires it, we will request your permission via Apple's App Tracking Transparency framework. You can opt out of non-essential analytics in your account or device settings where available.

Any websites we operate may use a small number of strictly necessary and analytics cookies, which will be described in a separate cookie notice where required.

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## 7. Third-Party Services

We work with carefully chosen third-party service providers ("Processors") to run Langlio. Categories include:

- AI providers — third-party AI and language-model providers that process your text inputs to generate language-learning content, translations, grammar feedback, and conversational responses.
- Authentication providers — Google sign-in and email/password authentication, and Sign in with Apple where offered, used to sign you in securely.
- Cloud hosting & storage — to host the Services, store your account and learning data, and run backups.
- Payment & subscription platforms — where paid plans are offered, the Apple App Store, Google Play, and/or a payment processor handle purchases, renewals, and receipts. Langlio does not receive or store full payment card details.
- Notification delivery — notifications are currently scheduled locally on your device by your operating system. If we add remote push notifications in future, a push-delivery provider may be used.
- Analytics and crash-diagnostics providers, where such tools are enabled, to measure usage and diagnose issues.
- Customer support tools, such as our support email, to respond to messages you send us.

These providers may process limited personal information on our behalf, under contracts that require them to protect your data and use it only for the purposes we direct. Some providers may act as independent controllers for their own portion of the processing, for example the App Store handling a payment, in which case their own privacy policies will also apply.

We do not sell your personal information to third parties for their own marketing purposes.

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## 8. Subscriptions & Payments

If you subscribe to a paid Langlio plan:

- Payment is processed by the Apple App Store, Google Play, or, where applicable, by our third-party payment processor.
- Langlio receives transaction status, plan, expiration, and similar entitlement information so we can activate and manage your subscription.
- Langlio does not directly store or have access to your full payment card number, CVC, or bank credentials. Those are handled and stored by the platform store or payment processor under their own terms and privacy policies.
- Refunds are handled according to applicable law and the policies of the platform through which the subscription was purchased.

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## 9. Data Storage & Retention

We store your personal information on cloud infrastructure operated by reputable providers, and we keep it only for as long as we need it.

- Account and learning data is retained while your account is active and for a reasonable period afterwards so you can reactivate or recover it.
- Conversation, diary, and saved-phrase content is retained while your account is active or until you delete it, whichever comes first.
- Subscription and billing records may be retained for as long as required by tax, accounting, audit, or consumer-protection laws.
- Crash logs, security logs, and abuse-prevention data are retained for the period needed to keep the Services secure and to comply with our legal obligations.
- Backups may persist for a limited additional period after deletion before being overwritten in the ordinary course of operations.

You can request deletion of your account at any time. Once deletion is initiated, we remove your active production data within 30 days. Encrypted backups may retain residual copies for up to 90 days before being overwritten in the ordinary course of operations. Records we are legally required to keep (for example, tax, accounting, or audit records) may persist longer, but they will not be used for any active processing.

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## 10. Age Restrictions

Langlio is intended only for users who are at least 18 years old.

We do not knowingly permit children or minors to create accounts or use the Services. If we become aware that a person under 18 has used Langlio or provided personal information to us, we may suspend or terminate the account and delete associated information where appropriate.

By using Langlio, you confirm that you are at least 18 years old and legally capable of entering into these Terms.

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## 11. Your Rights and Choices

Depending on where you live, you may have some or all of the following rights:

- Access — request a copy of the personal information we hold about you.
- Correction — ask us to fix information that is inaccurate or incomplete.
- Deletion / Erasure — ask us to delete your personal information, subject to legal limits.
- Portability — request a copy of certain information in a portable, machine-readable format.
- Restriction or Objection — ask us to limit or stop certain processing, including processing based on legitimate interests.
- Withdraw consent — where we rely on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.
- Opt out of "sale" or "sharing" (CCPA/CPRA) — although we do not sell personal information for money, you may have specific rights under California law, including the right to opt out of "sharing" for cross-context behavioral advertising. We do not engage in such sharing for the Services.
- Non-discrimination — we will not deny, charge a different price for, or provide a different quality of the Services because you exercised a privacy right.
- Lodge a complaint — if you are in the EEA, UK, or another jurisdiction with a supervisory authority, you have the right to complain to your local data protection authority, for example the UK Information Commissioner's Office or your national supervisory authority in the EU.

You can exercise many of these rights directly inside the app, for example editing your profile, deleting saved items, or requesting account deletion. For everything else, contact us at hello@langlio.co.uk. We may need to verify your identity before responding.

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## 12. International Data Transfers

Langlio is offered globally. Personal information we collect may be transferred to, processed in, and stored in countries other than the one in which you live, including countries that may have different data protection laws.

Where we transfer personal information out of the EEA, the UK, Switzerland, or other regions with similar restrictions, we use appropriate safeguards, such as Standard Contractual Clauses, UK International Data Transfer Agreement / Addendum, or another valid transfer mechanism, and rely on cloud and AI providers that offer similar protections.

By using Langlio, you understand that your information may be processed in jurisdictions outside your home country.

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## 13. Security

We take reasonable technical and organizational measures designed to protect personal information from loss, misuse, and unauthorized access, including:

- Encryption of data in transit using industry-standard protocols.
- Restricted access to production data and audit logging for sensitive operations.
- Use of reputable cloud, hosting, and authentication providers.
- Regular review of dependencies and processors.

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a security incident that affects your personal information, we will notify you and the relevant authorities where required by law.

You also play a role in keeping your account safe: use a strong, unique password, keep your sign-in method secure, and log out from shared devices.

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## 14. AI & Educational Content Disclaimers

Langlio's lessons, scenarios, audits, diary helpers, and chat responses are AI-assisted educational tools. They are intended to help you practice and learn, not to replace qualified instructors, certified translators, or professional advisors.

AI output may sometimes be inaccurate, incomplete, biased, or culturally inappropriate. We work to reduce these issues but cannot guarantee error-free output.

Translations, grammar feedback, idioms, and example sentences are best-effort suggestions and may not reflect every regional variation, dialect, or context.

You are responsible for what you submit to AI features. Please follow our Terms of Service, do not submit unlawful content, and do not share information about others without permission.

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## 15. Push Notifications & Marketing

If you enable push notifications, we use them to support learning, such as reminders, streak nudges, daily prompts, or important account messages. You can turn off notifications at any time in your device or app settings.

If you opt in to receive marketing communications, you can unsubscribe at any time using the link in those messages or by updating your settings. We will continue to send essential service-related communications, for example security alerts and billing notices, even if you opt out of marketing.

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## 16. Changes to This Policy

We may update this Privacy Policy from time to time, for example to reflect changes in our Services, technology, applicable laws, or business practices. When we update the Policy, we will revise the "Last Updated" date at the top and, where the changes are material, we will provide a more prominent notice, such as an in-app message or email, before the changes take effect.

Your continued use of the Services after an update means you accept the updated Policy, unless a more specific consent is required by law.

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## 17. Contact Us

If you have any questions, requests, or concerns about this Privacy Policy or how we handle your personal information, please contact us:

Langlio Ltd

Company Number: 17229776

Registered Office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

Email: hello@langlio.co.uk

If you are in the EEA or UK and you believe we have not addressed your concern adequately, you also have the right to contact your local data protection supervisory authority.

This Privacy Policy is provided to help users understand how Langlio handles personal information. It is not legal advice. Langlio Ltd may consult qualified legal counsel to confirm that this Policy reflects current laws and the specific way it operates the Services in each jurisdiction.