Privacy Policy

Effective Date: October 01, 2024

This Privacy Policy explains how ExploreApps sp. z o.o. ("ExploreApps", "we", "our", and "us") collects, uses, shares, stores, and protects information about you when you use our websites, mobile applications, products, and services (collectively, the "Services"), and the choices you have. It applies to all of our products, including those that offer voice-based, conversational, and other AI-powered features.

By using the Services, you agree to this Privacy Policy. If you do not agree, please do not use the Services.

Overview

This Policy explains:

• what information we collect;
• how we use it;
• how we use cookies and similar technologies;
• how and with whom we share it;
• how we store, secure, and retain it;
• how our voice, conversational, and AI-powered features handle your data;
• your choices and privacy rights;
• payment processing;
• rights of California and other U.S. residents;
• rights of EEA and UK residents, and other jurisdictions;
• international data transfers;
• automated processing and AI;
• children's privacy;
• how to contact us.

Our Services may contain links to third-party websites or services. Information you provide to third parties is governed by their own privacy policies, which we encourage you to review.

What Information We Collect

We collect information when you provide it to us, when you use the Services, and from other sources.

Information You Provide

• Contact information (e.g., first name, email address).
• Account information (e.g., login credentials, subscription tier, transactions).
• Profile and preferences, which we collect through the questions you answer when you first set up the app — your first name, language proficiency level, interests, and learning goals — and through your activity in the app.
• Content you submit, including text and, for voice-enabled features, audio.

Voice and Conversation Data

Some Services let you interact by speaking and holding conversations with AI-powered features. When you use these features, we process:

• Voice recordings and audio captured through your device microphone while a session is active, so your speech can be recognized and responded to;
• Conversation content — what you say (converted to text) and what you type, together with the responses generated for you.

We record audio only while a voice session is active. See "Voice, Conversational, and AI-Powered Features" below for how this data is handled.

Information We Collect Automatically

• Features used, access times, device type, operating system, app version, and similar identifiers.
• IP address, session activity, and analytics data, which may be processed in anonymized or pseudonymized form.
• We use cookies and similar technologies as described below, and we honor "Do Not Track" (DNT) signals where required by law.

Information From Other Sources

• Login partners (e.g., Google), where you choose to sign in through them. .
• Publicly available or commercial sources, and our affiliates, where permitted.

Sensitive Information

We do not intentionally collect special categories of personal data (such as health, biometric, or sensitive demographic information). Please do not submit such information — including during voice conversations — unless it is necessary and you understand the implications. Where you voluntarily provide it, we process it only with your explicit, informed consent and as permitted by law.

How We Use Your Information

We use your information to:

• provide, maintain, and secure the Services;
• recognize your speech and generate spoken and written responses in voice-enabled features;
• personalize and adapt the Services to your level, interests, and progress;
• process transactions and manage subscriptions;
• communicate with you and respond to inquiries;
• send marketing messages where legally permitted, with opt-out options;
• conduct internal research and statistical analysis in anonymized form;
• improve AI-generated outputs in non-identifiable form and test accuracy;
• comply with legal obligations and enforce our Terms of Use.

Voice, Conversational, and AI-Powered Features

Where the Services offer voice and conversational AI features, the following applies in addition to the rest of this Policy:

• Processing to deliver the feature. Your audio and conversation content are transmitted securely and processed to recognize your speech, generate spoken responses, and produce AI replies. We use trusted third-party service providers for speech recognition, speech synthesis, and AI language processing, acting on our behalf under contract. They are named in "Third-Party Processing Providers" below.
• What we send, and to whom. Audio captured by your device microphone during a session is sent to Microsoft to be converted into text, and the text of the tutor’s replies is sent to Microsoft to be spoken aloud. The messages exchanged during the session, together with the profile you provided when setting up the app — your first name, English level, interests, learning goal and the running summary of your progress — are sent to Anthropic so that the tutor’s replies can be generated. Nothing else from your account is sent to either provider.
• Transient processing. This content is processed only to deliver the feature and is not retained by us for longer than needed to provide the response and support the Services, consistent with the "How Long We Retain Your Information" section.
• No biometric identification. We process your voice only to recognize what you say. We do not create a voiceprint and do not use your voice to identify or authenticate you.
• Personalization stored on your device. Where a Service maintains a learning profile or history to personalize your experience, that information is stored locally on your device. You can remove it by clearing the app’s data or uninstalling the app.
• No model training. We do not use your voice recordings or conversation content to train generalized AI models, and neither Microsoft nor Anthropic uses them to train theirs.
• No sale, no advertising. We do not sell this content and do not use it for advertising.

How We Use Cookies and Similar Technologies

We use cookies, pixels, SDKs, and web beacons for authentication and security, preferences and settings, and usage analytics. We obtain your consent for non-essential cookies where required by ePrivacy and GDPR. You can manage cookies through your browser or our cookie settings.

How We Share Your Information

We may share your information:

• with service providers under contract, including the hosting, analytics and support providers and the speech and AI providers named in "Third-Party Processing Providers" below;
• with your consent;
• with affiliates and subsidiaries for internal purposes;
• in connection with a merger, acquisition, or sale of assets;
• when required to comply with law or to protect rights and safety.

We do not sell your personal data, and we do not share your personal information for cross-contextual behavioral advertising without your consent.

Third-Party Processing Providers

Third-party providers that process data on our behalf act as processors (or sub-processors) under Data Processing Agreements (DPAs), with appropriate contractual and technical safeguards, and process your data only for the tasks we instruct. Each of them is contractually required to protect your data to a standard equivalent to the one described in this Policy. The providers that power our voice and AI features are:

• Microsoft Corporation, United States — speech recognition and speech synthesis. Receives the audio captured during a voice session and the text of the tutor’s replies.
• Anthropic PBC, United States — generation of the tutor’s replies. Receives the messages exchanged during the session together with your first name, English level, interests, learning goal and progress summary.
• If we replace or add a provider of this kind, we will update this section and, where the law requires it, notify you.

How We Store and Secure Your Information

We maintain physical, administrative, and technical safeguards, including:

• encryption in transit and at rest using industry standards (e.g., TLS 1.2+, AES-256);
• regular audits, vulnerability scans, and access controls;
• staff training in privacy and data security.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

How Long We Retain Your Information

We retain information as follows:

• Account data (e.g., name, email, login): while the account is active, plus up to 12 months.
• Billing and transaction data: 6 years, or longer where required by law.
• Session logs and usage data: up to 6 months.
• Voice recordings and conversation content: not stored by us once the session ends. Our speech provider processes audio in transit and does not store it. Our AI provider may hold the session content briefly for security and abuse monitoring, and for no other purpose.
• Support communications: up to 2 years.

Learning profiles and history stored on your device are retained until you remove them.

Your Choices

• Marketing: opt out via the unsubscribe link in our emails.
• Microphone: grant or revoke microphone permission in your device settings; voice features require it.
• On-device data: delete your learning profile and history by clearing app data or uninstalling the app.
• Access, correction, deletion: contact support@lanso.app.

Payment Processing

Payments are handled by third-party providers that may collect billing details and transaction records. Your payment data is not stored by ExploreApps and is processed securely via PCI-DSS compliant providers.

Rights of U.S. Residents

If you reside in California, Colorado, or a similar state, you have the right to:

• know and access the personal information we collect, including categories such as identifiers, usage data, audio, and content you provide;
• correct or delete your personal information;
• opt out of the sale or sharing of personal information (note: we do not sell or share for cross-context behavioral advertising);
• limit the use of sensitive personal information;
• not be discriminated against for exercising your rights.

You may designate an authorized agent to submit requests on your behalf, and we will verify your identity before responding. We do not sell the personal information of consumers, including minors under 16. To exercise these rights, contact support@lanso.app.

Rights of EEA and UK Residents

If you are in the European Economic Area or the UK, you have the right to access, rectify, erase ("right to be forgotten"), restrict or object to processing, data portability, and to withdraw consent at any time. You also have the right to lodge a complaint with your local supervisory authority.

Legal Basis for Processing

We process personal data based on one or more of: your consent (e.g., marketing or non-essential cookies); performance of a contract (to deliver Services you request); our legitimate interests (e.g., service improvement and analytics), provided these do not override your rights; and legal obligations. Where we rely on consent, you may withdraw it at any time.

Rights of Other Jurisdictions

You may have rights under other privacy laws (e.g., Brazil LGPD, Canada PIPEDA). We honor these rights in accordance with applicable law.

International Data Transfers

We may transfer your personal information to countries outside your jurisdiction (e.g., the United States). The speech and AI providers named above are located in the United States, and the content described in "Voice, Conversational, and AI-Powered Features" is transferred to them on that basis. Where we transfer data, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, the UK International Data Transfer Agreement (IDTA), adequacy decisions, or your explicit consent, supplemented where appropriate by transfer impact assessments.

Automated Processing and AI

We use AI to power certain features, which may involve automated analysis of the content you provide (for example, recognizing speech and generating responses). We do not use AI to make decisions producing legal or similarly significant effects without human oversight. Where AI-based suggestions are provided, you may request human review, object to the processing, and receive an explanation of how a decision was made.

We do not use your personal data to train generalized AI models unless you have provided separate, informed, and explicit consent. Where training is performed, it is limited to de-identified or synthetic data. We conduct Data Protection Impact Assessments (DPIAs) where required and apply data minimization, transparency measures, and periodic review of AI outputs.

Children's Privacy

The Services are intended for users 13 years or older. Users under 18 must have verifiable consent from a parent or legal guardian, which we may verify, before using the Services. We do not knowingly collect personal information — including voice recordings — from children under 13 (or under 16 where applicable under local law) without verifiable parental consent, in accordance with laws such as COPPA and GDPR. We do not sell the personal information of minors.

If we become aware that we have collected information from a child without the required consent, we will delete it promptly. If you believe we may have done so, contact  support@lanso.app.

Changes to This Policy

We may update this Policy from time to time. If we make material changes, we may notify you by email or through a prominent notice in the Services.

Contact

For questions about this Policy or to exercise your rights, contact support@lanso.app.