Privacy Policy
Last updated: 2026-04-18
Yingwu Labs ("we", "us") operates the Speakly language-learning product (the "Service"), available at https://learna.yingwu.lol and on iOS/Android. This policy explains what personal data we collect, how we use it, and the rights you have under GDPR, UK GDPR, CCPA, and similar laws.
1. Data we collect
Account data: email address, authentication identifier, language/level preferences, and survey answers you submit. Usage data: lesson progress, scenario/role-play sessions, saved sentences, cards, streak counts, and aggregate learning metrics. Voice data: audio you record during conversation practice. Audio is transmitted to our speech-to-text and large-language-model providers for real-time tutoring. Raw audio is not retained after the session unless you explicitly save a recording. Device & technical data: IP address, device/OS, app version, crash logs, and anonymized analytics events. Billing data: when you subscribe via the web, Paddle.com Market Ltd. processes the transaction as Merchant of Record. We receive order/subscription status and the last four digits of your card — never full card numbers. Mobile purchases are handled by Apple App Store or Google Play under their own terms.
2. How we use your data
• To deliver the Service — personalize lessons, track progress, play back saved content. • To operate voice conversations — temporary transmission to speech and language-model providers listed in §4. • To process payments and manage subscriptions via Paddle.com Market Ltd.. • To provide support and respond to your requests. • To comply with legal obligations (tax, fraud prevention, abuse). • With your consent, to send product announcements — you can opt out at any time in the app or via the unsubscribe link in email.
3. Legal bases (GDPR/UK GDPR)
Performance of a contract: account creation, lesson delivery, billing. Legitimate interest: service improvement, fraud prevention, aggregate analytics. Consent: optional marketing emails, optional analytics cookies. You may withdraw consent at any time. Legal obligation: tax records, regulatory requests.
4. Third-party processors
We share the minimum data needed with: • Supabase (database, authentication) — EU region. • Cloudflare (CDN, edge workers) — global. • OpenAI / Anthropic / similar LLM providers — transient audio and text for generating tutor responses. No training on your inputs. • Speech-to-text and text-to-speech providers — transient audio processing. • Paddle.com Market Ltd. — payment processing, invoicing, tax remittance. • Crash/analytics provider — anonymized metrics only. All processors are bound by data-processing agreements and EU-approved Standard Contractual Clauses where applicable.
5. International transfers
Some processors may be located outside your country (including the US). We rely on Standard Contractual Clauses and, where available, adequacy decisions to safeguard these transfers.
6. Retention
Account and learning data: kept while your account is active, and up to 30 days after deletion for backup rotation. Voice recordings: not retained unless you save them; STT/LLM providers delete transient audio per their retention policies (typically 0–30 days). Billing records: kept for 7 years to comply with tax law. Support emails: 3 years.
7. Your rights
You have the right to: access your data, correct it, delete it, export it in a portable format, restrict or object to processing, and withdraw consent. California residents additionally have rights under the CCPA including the right to opt out of "sale" of personal information — we do not sell personal information. To exercise any right, email privacy@yingwu.lol or use the in-app Account → Delete account flow. We respond within 30 days.
8. Children
The Service is not directed to children under 13 (or 16 in the EU/UK without parental consent). We do not knowingly collect personal data from such users. If you believe a child has provided data, contact privacy@yingwu.lol and we will delete it.
9. Security
Data in transit is encrypted with TLS 1.2+. Data at rest is encrypted by our infrastructure providers. Access is limited to the minimum staff necessary and is logged.
10. Changes to this policy
We will post any material change on this page and update the "Last updated" date above. If the change is significant we will notify you in-app or by email before it takes effect.
11. Contact & Data Protection Officer
General privacy questions: privacy@yingwu.lol Data Protection Officer: dpo@yingwu.lol Postal: Address available on request via support email.
support@yingwu.lol · https://learna.yingwu.lol