1. What Speakly is

• Speakly is a language-learning service. It includes self-study tools, vocabulary training, listening, reading, speaking and writing exercises, AI-assisted features, paid subscriptions and optional Community features.
• Speakly Community is designed only for language practice, cultural exchange and study-partner discovery. It is not a dating app, marketplace, recruitment service, advertising platform or general social network.

2. Who may use Speakly

• The core Speakly learning service is not intended for children under 13.
• Users aged 13–17 may use the core self-study learning features only where permitted by law and, where required, with consent or involvement from a parent or legal guardian.
• Speakly Community is strictly for users aged 18 or older. Users under 18 may not access Community features. If we learn or reasonably suspect that a Community user is under 18, we may restrict, suspend or permanently remove Community access and take other safety measures.

3. Personal data we collect

The data we collect depends on how you use Speakly. We may collect the following categories of personal data:

Account, Guest Mode and learning data:

• Name or display name, email address, password hash, Apple, Google, Facebook or other login identifier, account creation date, user ID, account status, subscription status, language preferences, country or region, vocabulary progress, lesson progress, exercise results, mistakes, corrections, streaks, XP, points, level, study history, learning statistics, feature usage, preferences, feedback and support requests.
• You may use some learning features without creating a registered account. In Guest Mode, we may assign a pseudonymous local, device-based or server-side identifier to track learning progress and operate the service. Guest progress may be lost if you clear app data, change devices, reset identifiers, uninstall the app or do not register an account. If you later create an account, we may link your Guest progress to your registered account where technically possible. Guest Mode does not give access to Community features.
• If you sign in using Apple, Google, Facebook or another third-party login provider, we receive the account information that the provider makes available to us. We do not receive your third-party account password. If you use Apple private relay or another email relay service, some account recovery, security, verification or Community communications may depend on your ability to receive messages through the relay email address connected to your account.

Community profile and visibility data:

• First name or display name, profile photos, languages you speak, languages you are learning, interests, age or age range where used, gender where used, online or recently online status, country, region or approximate location where used, league, XP, points, streaks or activity indicators, study-partner preferences, invite and match status, profile completeness and account or Community status indicators.
• Some Community profile information is visible to other Community users. Do not add information to your Community profile that you do not want other Community users to see. Your phone number, date of birth, verification details, report history, moderation notes, internal risk signals and payment details are not shown to other Community users.

Community communications, photos, audio and media:

• Text messages, voice messages, message timestamps, delivery, read, edited or deleted-message events, corrections, translations, conversation starters, invites, match activity, blocked or deleted study partners, reports, report context, moderation history, conversation metadata, profile photos and other uploaded media.
• Messages, voice messages, corrections, translations, invites, media and similar communications are shared with the users you send them to. They may also be reviewed by Speakly where necessary for safety, support, moderation, enforcement, legal compliance or abuse prevention.
• Human moderators do not review every private communication in real time. Automated safety systems may analyze Community messages, voice messages, profile photos and uploaded media to detect possible safety risks, abuse or violations of our Terms of Use or Community Guidelines. Speakly cannot guarantee that all violations will be detected.
• Reported, flagged, frozen, appealed or safety-related content and related context may be reviewed by authorized Speakly personnel, contractors or moderation partners under confidentiality and access-control obligations.

Phone number, verification and age data:

• Phone number, country code, verification method, one-time-code delivery logs, verification attempt timestamps, verification result, anti-fraud signals related to verification, hashed or otherwise protected identifiers used to prevent repeat abuse or ban evasion, date of birth, age confirmation, profile-photo safety signals, suspected underage-access signals and related moderation information.
• Your phone number is not publicly displayed and is not shared with other Community users.
• For Community access, we collect your date of birth or age confirmation to confirm that you are 18 or older. If your date of birth or age confirmation shows that you are under 18, we will block Community access.
• We may also use phone or WhatsApp verification, automated systems, AI-assisted profile-photo review, safety signals, user reports, moderation history and other abuse-prevention checks to help detect suspected underage access, fake profiles, unsafe conduct or violations of our Community Guidelines.
• Where a profile, photo, report or safety signal suggests that a user may be under 18 or otherwise ineligible for Community, authorized moderators may review available account, profile, photo, report and safety information. This review is a safety and eligibility assessment, not formal identity-document verification.
• Unless Speakly expressly requests and processes identity documents in a specific case, Speakly does not verify users’ legal identity or official age through government ID checks.
• If we cannot reasonably determine that a user is eligible for Community, or if we reasonably suspect that a user is under 18, we may restrict, suspend or permanently remove Community access.

Payment and purchase data:

• Purchase confirmation, billing information, App Store or Google Play receipts, subscription status and related technical information needed to activate access, keep accounting records, handle support, prevent fraud and comply with law. We do not store full card numbers.

Device, log, cookies and technical data:

• IP address, device type, operating system, browser type, app version, language settings, time zone, crash logs, session data, device identifiers, diagnostic information, security logs, approximate location derived from IP address, fraud signals, abuse signals and integrity signals.
• We use cookies, SDKs, pixels, local storage and similar technologies for login, session management, security, remembering preferences, analytics, performance, fraud prevention, attribution, advertising measurement and marketing where permitted and with required consent.
• Where available, you can manage cookie, analytics, advertising, tracking or similar preferences through our cookie banner, consent settings, app privacy settings, device settings or browser settings. Essential cookies and similar technologies that are necessary to provide the service may remain active.

Support, reports and moderation data:

• Support messages, attachments, support history, reporter and reported-user IDs, reported content and related context, timestamps, screenshots, profile information, profile photos, moderation notes, enforcement decisions, appeal information, suspected underage-access signals, safety signals, fraud indicators, AI or automated moderation signals, account history relevant to a report, and hashed or protected identifiers used to prevent repeat abuse or ban evasion.
• Reporter identity is not disclosed to the reported user unless required by law or necessary in exceptional circumstances to protect rights, safety or legal interests.

4. How we use personal data

• We use personal data to provide, operate and secure Speakly;
• Create and manage accounts; save learning progress;
• Personalize learning content;
• Process subscriptions and purchases;
• Provide customer support;
• Enable Community features;
• Display Community profiles;
• Recommend, rank or prioritize study partners;
• Send and receive messages, voice messages, translations, corrections and conversation starters;
• Verify age and contact details;
• Keep Community access limited to adults;
• Detect spam, fraud, scams, harassment, grooming, sexual content and abuse;
• Moderate content, profiles, photos and communications; enforce our Terms of Use and Community Guidelines;
• Process reports and appeals;
• Provide notices and explanations of enforcement decisions where required;
• Prevent banned users from returning; send service notifications;
• Send direct marketing communications where legally permitted;
• Improve, test and develop the service; comply with legal obligations; and protect users, Speakly and the public.

5. AI, automated processing and matching

• Speakly may use automated systems, including AI, to support language-learning exercises, corrections, translations, explanations, recommendations, study-partner matching, profile ranking, conversation starters, spam, scam and fraud detection, profile review, safety moderation, content flagging, abuse prevention, support workflows and product improvement. Automated safety systems may analyze Community messages, voice messages, profile photos and uploaded media at intervals or when safety signals are detected to help identify possible Community Guidelines violations, abuse, fraud or safety risks.
• Automated systems may make mistakes.
• Where automated systems detect severe safety, illegal, or explicit content with high confidence, Speakly may apply a temporary protective restriction, content quarantine, or Community freeze before human review where necessary to protect users or the service. Temporary protective restrictions, content quarantine or Community freezes may also be triggered by repeated reports, patterns of reports from multiple users, safety signals or abuse-prevention indicators pending human review.
• Where required by law, or where a decision significantly affects your access to the service, we provide human review or an appeal process.
• Speakly does not guarantee that AI-generated translations, corrections, explanations, recommendations, safety classifications or learning content will always be accurate, complete, safe, appropriate or error-free.
• Speakly does not use private Community messages, voice messages, profile photos, reports or support communications to train third-party foundation models. Where we use AI providers to process content for features such as corrections, translations, safety moderation, abuse prevention or support, we do so to provide and protect the service and, where possible, under settings or agreements that restrict provider use of that content for their own model training.
• If Speakly uses aggregated, anonymized or de-identified data to improve our own services, we take steps designed to prevent the data from identifying individual users.
• If you use Community features, we may recommend profiles or prioritize visibility using information such as languages spoken, languages being learned, shared interests, location or region, activity level, online status, profile completeness, prior interactions, invites, matches, blocks, reports, safety signals, learning progress, XP, streaks, league activity and subscription status where relevant to feature availability.
• These recommendations support language learning, Community quality and user safety. They do not mean that Speakly verifies a user’s identity, background, intentions, language ability, suitability or safety.

6. Legal bases for processing

For users in the EU, EEA, UK and other regions with similar privacy laws, we process personal data under the following legal bases:

Contract:

• To provide the service you request, including account creation, learning progress, subscriptions, Community features, messages, corrections, translations, recommendations and customer support.

Legal obligation:

• To comply with tax, accounting, consumer protection, platform-safety, law-enforcement, regulatory and other legal obligations.

Legitimate interests:

• For service security, fraud prevention, spam prevention, abuse prevention, moderation, enforcing our Terms of Use, improving the service, preventing banned users from returning, protecting users and Speakly, protecting Community integrity, handling legal claims, analytics that do not require consent, and sending direct marketing communications to existing users about Speakly’s own similar language-learning products and services where permitted by applicable law.
• Where we rely on legitimate interests, we consider and balance our interests against your rights, freedoms and expectations.

Consent:

• For optional processing such as non-essential cookies, some analytics or marketing technologies, marketing emails where consent is required, optional profile fields where applicable, certain device permissions, advertising or tracking where required by law or platform rules, and other processing where consent is required by law.
• You may withdraw consent at any time. Withdrawal does not affect processing already carried out lawfully before withdrawal.

7. Marketing communications

• We may send you emails about Speakly’s own language-learning products, study plans, Premium or Lifetime offers, learning tips, feature updates and similar Speakly services where legally permitted.
• We do not use this basis to send third-party marketing.
• You can opt out of promotional emails at any time by using the unsubscribe link included in those emails or by contacting hello@speakly.me.
• We may still send essential service messages, such as security alerts, verification codes, payment confirmations, subscription notices, policy updates, moderation notices and important account notices.

8. When we share personal data

• We do not sell, trade or rent your personal data.
• We may share personal data with service providers for hosting, storage, analytics, email delivery, push notifications, customer support, payments, fraud prevention, crash reporting, AI services, age or identity checks, verification messages, moderation tools, security and infrastructure; AI and moderation providers where needed for language-learning, safety, moderation, fraud-detection or support functions; payment providers, Apple and Google for purchases and subscriptions; other Community users where you choose to make information visible or send them messages, voice messages, corrections, translations, invites or media; authorities, courts, regulators or legal recipients where required by law or necessary to protect users, prevent fraud, investigate abuse, report serious safety risks, enforce rights or respond to legal claims; and parties involved in a merger, acquisition, financing, restructuring, sale of assets or similar transaction, subject to appropriate safeguards.
• Service providers may process data only as instructed by Speakly and under appropriate contractual, security and confidentiality safeguards.
• Current or past categories of authorized providers may include Amazon Web Services, Firebase or other Google services, Sentry, Elastic, HelpCrunch, DeployGate, payment providers, email or direct marketing service providers, analytics providers, moderation providers and similar infrastructure or support providers.
• Where possible, we minimize data shared with AI and moderation providers, pseudonymize identifiers, use business or enterprise-grade services and apply appropriate data-processing terms.

9. International transfers

• Personal data is primarily stored and processed in the EU/EEA where possible. Some providers may process personal data outside Estonia, the EU, EEA or UK.
• Where personal data is transferred internationally, we use appropriate safeguards, such as adequacy decisions, EU Standard Contractual Clauses, UK transfer mechanisms where applicable, data processing agreements, transfer impact assessments where appropriate, technical and organizational safeguards, encryption, pseudonymization and access controls where appropriate.

10. Security

• We use technical and organizational measures designed to protect personal data, including access controls, encryption where appropriate, secure infrastructure, monitoring, logging and internal policies.
• Access to Community messages is restricted to authorized personnel and approved service providers who need access for moderation, safety, support, abuse prevention, technical troubleshooting, legal compliance or enforcement of our Terms of Use and Community Guidelines. Ordinary staff and developers do not access Community message content for general browsing purposes. Where message content is reviewed, access may be logged and limited to the relevant case or operational need.
• No online service is completely secure. You are responsible for keeping your password confidential and protecting access to your device and account.

11. Retention and deletion

We keep personal data only as long as necessary for the purposes described in this Policy.

Typical retention periods or retention criteria include:

• Account data and learning progress: while your account exists or until deleted or anonymized;
• Guest progress: until inactive, reset, deleted or linked to an account;
• Billing and accounting records: generally up to 7 years or longer if legally required;
• Support communications: as long as needed for support, legal, compliance or dispute-resolution purposes;
• Community profile data: while your Community profile exists or until deleted, restricted, anonymized or retained for safety or legal reasons;
• Community messages and voice messages: while needed to provide the service, maintain conversation history, support user safety, handle reports, enforce rules, comply with law or resolve disputes;
• Reports and moderation records: as long as needed to enforce rules, prevent abuse, handle appeals, comply with law, protect users or defend legal claims;
• Banned-account identifiers, safety records, hashed phone numbers, account IDs, device or security signals and ban flags: as long as reasonably necessary to enforce Community bans, prevent abuse, prevent ban evasion, protect users, handle legal claims or address safety risks;
• Cookie data: according to cookie settings and provider retention periods;
• Backup data: retained for limited periods according to backup cycles.

12. Your rights

• Depending on your location, you may have the right to access your personal data, correct inaccurate data, delete your data, restrict processing, object to processing, object to direct marketing, withdraw consent, receive a portable copy of your data, object to certain automated processing, request human review where required by law and complain to a data protection authority.
• To exercise your rights, contact hello@speakly.me
• You may also contact the Estonian Data Protection Inspectorate or your local supervisory authority.
• We may need to verify your identity before responding to a request. Some rights may be limited where we must retain data for legal, safety, fraud-prevention, accounting, enforcement or dispute-resolution reasons.

13. Children’s privacy

• Speakly does not knowingly collect personal data from children under 13.
• Community features are not available to users under 18.
• If you believe a child under 13 has used Speakly or a person under 18 has accessed Community, contact hello@speakly.me

14. External links

15. Changes to this Privacy Policy

16. Contact

For privacy questions or requests: Speakly OÜ Roseni tn 7, 10111 Tallinn, Estonia Registry code: 14437781 Email: hello@speakly.me Phone: +372 5120938