Privacy Policy

1. Overview

This Privacy Policy explains how Lughara ("Lughara," "we," "us," or "our") collects, uses, shares, and protects information when you use our website, learning dashboard, speaking-practice tools, tutoring features, classroom features, AI-powered feedback, and related services collectively referred to as the "Services."

2. Information We Collect

We may collect the following information:

• Account information, such as your name, email address, login identifiers, profile settings, role, and workspace membership.
• Learning information, such as assigned lessons, practice attempts, answers, completion status, lesson progress, scores, weak words, vocabulary sets, and progress summaries.
• Audio and speech information, such as microphone input, audio uploads, pronunciation attempts, transcripts, speech-to-text outputs, AI feedback, prompts, responses, and related metadata.
• Tutoring and classroom information, such as session bookings, teacher selections, class participation, assignments, attendance, teacher notes, support requests, and signup forms.
• Technical and usage information, such as device information, browser type, pages visited, feature interactions, log data, error data, IP-based network information, and security signals.
• Analytics and marketing information, such as website visits, referral sources, campaign identifiers, conversion events, and interactions with ads or marketing pages.

If we later offer paid Services, we may also collect payment-related information, such as subscription plan, billing status, transaction identifiers, invoices, refunds, and limited payment method details. Payment card details are generally processed by third-party payment processors and are not stored directly by us.

3. How We Collect Information

We collect information directly from you, automatically when you use the Services, from teachers or administrators connected to your program, and from service providers that help us operate the Services.

4. How We Use Information

We use information to:

• provide, maintain, and improve the Services;
• create and manage accounts;
• deliver lessons, speaking practice, pronunciation feedback, AI feedback, tutoring, and classroom features;
• personalize lessons, progress views, review loops, and recommendations;
• communicate with you about your account, lessons, bookings, support requests, updates, and security;
• measure product usage, landing page performance, and marketing campaigns;
• prevent fraud, abuse, unauthorized access, and security issues;
• troubleshoot errors and improve reliability;
• comply with legal obligations and enforce our Terms.

If we later offer paid Services, we may also use information for billing, subscriptions, invoices, refunds, and payment support.

5. Audio, Transcripts, and AI Processing

Some features require microphone access, voice input, or audio uploads so we can provide speaking practice, pronunciation checks, transcription, text-to-speech, conversational practice, and AI-generated feedback.

Audio and related text may be processed by Lughara and third-party providers, including providers for AI, speech processing, transcription, hosting, and infrastructure. These may include Google Gemini, OpenAI, and similar providers we use from time to time.

We do not currently design the Services to keep raw learner microphone recordings as a permanent library of account content. However, audio may be processed temporarily, and transcripts, evaluations, prompts, responses, metadata, error logs, and operational logs may be generated or retained as needed to provide features, maintain security, troubleshoot issues, monitor reliability, improve the Services, and support learning progress features.

Third-party providers may process or temporarily retain data according to their own terms and policies.

6. Teacher, Tutor, and Classroom Visibility

If you use Lughara through a classroom, school, language center, employer, teacher, tutor, or instructor-led program, relevant instructors or administrators may receive limited learning progress information.

This may include your name, email address, enrollment status, assigned lessons, completed modules, practice status, completion history, scores, weak words, progress summaries, assignment results, attendance, teacher notes, and related learning activity.

Instructor visibility is limited to information reasonably needed to support learning, manage access, assign lessons, prepare for sessions, and provide feedback.

7. How We Share Information

We may share information with:

• Service providers that help us operate the Services, including authentication, AI processing, speech processing, hosting, storage, analytics, email delivery, scheduling, customer support, and security providers.
• Teachers, tutors, instructors, schools, language centers, classroom administrators, or organization administrators when you use Lughara through a managed learning program. The information shared is limited to learning progress and program-management information.
• Analytics and advertising partners to measure website usage, campaign performance, conversions, and marketing effectiveness, where permitted by law.
• Professional advisors, such as lawyers, accountants, auditors, insurers, and security consultants.
• Authorities or other parties when required by law, necessary to protect rights or safety, or needed to enforce our Terms.
• Successors or potential successors in connection with a merger, acquisition, financing, reorganization, sale of assets, or transfer of all or part of our business.

If we later offer paid Services, we may share information with payment processors to process purchases, subscriptions, invoices, refunds, failed payments, taxes, and billing support.

We do not sell personal information in the ordinary sense of exchanging it for money.

8. Cookies, Local Storage, and Analytics

We and our providers may use cookies, session tokens, pixels, SDKs, local storage, and similar technologies to keep you signed in, protect accounts, remember preferences, operate product features, analyze usage, measure marketing performance, and detect fraud or abuse.

We may use browser local storage for settings such as theme preference, selected workspace, lesson drafts, sound settings, onboarding state, and preferred microphone device.

If we use analytics or advertising tools such as Meta Pixel, Google Analytics, PostHog, or similar tools, those providers may collect information about your browser, device, pages visited, referral source, and interactions with our website or Services.

9. Marketing Communications

We may send emails about product updates, lessons, bookings, account activity, offers, beta programs, or other Lughara-related information.

You can unsubscribe from promotional emails where available. We may still send transactional or service-related messages, such as account, security, booking, or support communications.

10. Data Retention

We keep information for as long as reasonably necessary to operate the Services and for legal, accounting, security, product, and support purposes.

Retention periods vary by data type. Account details, learning progress, classroom records, booking records, and signup submissions may remain while your account or program relationship is active and for a reasonable period afterward.

Transcripts, pronunciation evaluations, AI feedback, prompts, responses, and learning analytics may be retained as needed for progress tracking, learning features, reliability monitoring, and product improvement.

Temporary logs, audio-processing artifacts, security logs, and AI-processing artifacts may persist for shorter periods, including in backups or provider systems.

11. Security

We use reasonable technical and organizational safeguards designed to protect information. No system is completely secure, and we cannot guarantee absolute security.

You are responsible for keeping your login credentials secure and telling us if you believe your account has been compromised.

12. Your Rights and Choices

Depending on where you live, you may have rights to access, correct, delete, restrict, or object to certain processing of your personal information. You may also have rights to request data portability, withdraw consent, opt out of marketing emails, or opt out of certain analytics or advertising activities.

To make a privacy request, contact us at:

lughara1@gmail.com

We may need to verify your identity before completing certain requests. Some information may be retained where permitted or required by law.

13. Children's Privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13.

If you believe a child under 13 has provided personal information to us, contact us at lughara1@gmail.com and we will take appropriate steps.

If we later offer Services intended for schools, children, or users under 13, we may provide additional notices, consent flows, agreements, or child-specific privacy terms.

14. International Processing

Your information may be processed in countries other than your own, including the United States.

15. Changes

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date. If we make material changes, we may provide additional notice where appropriate.

16. Contact

If you have privacy questions or requests, contact us at:

lughara1@gmail.com