Privacy Policy

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Kalemny ("we," "our," or "us") operates the Kalemny mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

Please read this Privacy Policy carefully. By using the App, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

1.1 Personal Information

When you register for an account, we collect:

• Username (display name)
• Email address
• Password (stored securely using encryption)
• Date of birth (for age verification and COPPA compliance)
• Profile photo (optional)

1.2 Usage Information

We automatically collect information about how you use the App:

• Lessons completed and progress
• Practice sessions and scores
• Learning statistics and streaks
• Feature usage patterns
• Time spent in the App

1.3 Device Information

We may collect information about your device:

• Device type and model
• Operating system version
• App version
• Unique device identifiers
• Language preferences

1.4 Audio Data (Voice Recordings)

For pronunciation practice and conversation features, we collect and store voice recordings:

What We Collect:

• Voice recordings when you use pronunciation practice features
• Voice recordings during speaking conversation exercises
• Audio metadata (duration, timestamp, associated text)

How Voice Data is Stored:

• Voice recordings ARE stored on our servers (Tencent Cloud COS) for playback functionality
• Recordings are associated with your account for your learning history
• Recordings are encrypted during transmission and storage

Why We Store Voice Recordings:

• To enable playback of your pronunciation attempts
• To track your pronunciation progress over time
• To allow you to review and compare your recordings
• To provide conversation history with audio playback

1.5 AI Chatbot Conversation Data

When you use our AI chatbot features for language practice, we collect and store:

What We Collect:

• Message content you send to the AI assistant
• AI responses generated during conversations
• Voice recordings during speaking conversations (if enabled)
• Conversation metadata (timestamps, topic, level, session identifiers)

How Conversation Data is Stored:

• All conversation messages ARE stored on our servers for your conversation history
• Voice messages within conversations ARE stored for playback functionality
• Conversations are associated with your account and accessible in your history
• Data is encrypted during transmission and storage

1.6 User-Generated Content

If you use community features:

• Posts you create
• Comments you make
• Likes and interactions

2. How We Use Your Information

We use the collected information to:

• Provide and maintain the App
• Create and manage your account
• Personalize your learning experience
• Track and display your learning progress
• Provide pronunciation feedback
• Process AI chatbot conversations for language practice
• Generate AI responses to support your learning
• Send notifications about your learning
• Respond to support requests
• Improve our services
• Enforce our Terms of Service
• Comply with legal obligations

2.1 AI-Specific Data Use

Your AI conversation data is used to:

• Generate relevant language learning responses
• Maintain conversation context within a session
• Track your learning progress and conversation history
• Improve AI response quality (in anonymized form)

We do NOT use AI conversation data to:

• Build individual profiles for advertising purposes
• Share identifiable conversation content with third parties (except AI providers necessary for functionality)
• Train AI models on your personal conversations without consent

3. Children's Privacy (COPPA Compliance)

We are committed to protecting children's privacy and complying with the Children's Online Privacy Protection Act (COPPA).

3.1 Age Verification

• We collect date of birth during registration to verify age
• Users under 13 years old are identified as minors

3.2 Parental Consent for Minors

For users under 13 years old:

• We require a parent or guardian's email address
• A verification email is sent to the parent/guardian
• Parental consent must be verified before the child's account is fully activated
• Parents can review their child's information at any time
• Parents can request deletion of their child's data

3.3 Data Collection from Children

For users under 13, we:

• Collect only information necessary to provide the service
• Do NOT use children's personal information for targeted advertising
• Do NOT sell children's personal information
• Do NOT share children's information with third parties (except as required to provide the service)

3.4 Parental Rights

Parents of children under 13 have the right to:

• Review the personal information we have collected about their child
• Request deletion of their child's personal information
• Refuse further collection of their child's information
• Request that we stop using their child's information

4. Information Sharing and Disclosure

4.1 We Do NOT Sell Your Personal Information

We never sell, rent, or trade your personal information to third parties for marketing purposes.

4.2 Service Providers

We may share information with third-party service providers who assist us in:

• Hosting and maintaining the App
• Analyzing usage patterns
• Processing payments (for premium features)
• Sending notifications

These service providers are contractually obligated to protect your information.

4.3 Third-Party Services We Use

We use the following third-party services to provide app functionality:

Service	Purpose	Data Shared
MiniMax	Text-to-Speech (Arabic audio)	Text content
Alibaba DashScope/Qwen	Speech Recognition	Voice recordings
DeepSeek	AI Chat Assistant	Chat messages
Google/Apple Speech	Device speech recognition	Voice (on-device)

5. Data Security

We implement appropriate security measures to protect your information:

• All data transmitted to our servers is encrypted using TLS
• Passwords are hashed using industry-standard algorithms
• Access to personal data is restricted to authorized personnel
• Regular security audits and updates
• Secure data centers with physical and electronic safeguards

However, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

6. Data Retention

We retain your information for as long as:

• Your account is active
• Necessary to provide you with services
• Required by law

Data Type	Retention Period
Account information	Until account deletion
Learning progress	Until account deletion
Voice recordings (pronunciation)	Until account deletion or upon request
Voice recordings (conversations)	Until account deletion or upon request
AI conversation history (text)	Until account deletion or upon request
AI messages at provider	Per provider's policy
Usage analytics	2 years
Support requests	3 years

7. Your Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your personal information
• Portability: Request a copy of your data in a portable format
• Opt-Out: Opt out of marketing communications at any time
• Withdraw Consent: Withdraw consent for data processing where applicable

7.1 Voice Recording Rights

You have specific rights regarding your voice recordings:

• Access: Request a copy of all voice recordings associated with your account
• Deletion: Delete individual recordings through the App or request bulk deletion
• Disable Storage: Disable voice storage in settings (this will disable playback features)
• Export: Request export of your voice recordings in standard audio format

8. Biometric Data Notice

8.1 Voice Data as Biometric Information

Voice recordings may be classified as biometric data under certain privacy laws, including:

• Illinois Biometric Information Privacy Act (BIPA)
• California Consumer Privacy Act (CCPA)
• General Data Protection Regulation (GDPR)
• Texas Capture or Use of Biometric Identifier Act (CUBI)
• Other state biometric privacy laws

8.2 Our Biometric Data Practices

We collect voice recordings for the following purposes:

• Pronunciation practice and feedback
• Conversation history playback
• Learning progress tracking

We do NOT:

• Create unique voiceprints or voice templates for identification purposes
• Use voice recordings for authentication or identity verification
• Sell or share voice recordings with third parties for their independent use
• Use voice data for purposes other than the educational features described

8.3 Consent for Voice Data Collection

By using voice recording features in the App, you provide your informed consent to:

• The collection and storage of your voice recordings
• The processing of recordings for pronunciation analysis
• The storage of recordings on our servers (Tencent Cloud COS) for playback
• The transmission of recordings to speech recognition services for transcription

8.4 Retention and Destruction

• Voice recordings are retained until you delete them or delete your account
• Upon deletion request, recordings are permanently destroyed within 30 days
• Backup copies are destroyed within 90 days
• We maintain written policies governing the retention and destruction of biometric data

9. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request information about data we collect, including voice recordings
• Right to Delete: Request deletion of your data, including all voice recordings
• Right to Opt-Out: Opt out of sale of personal information (we do not sell data, including voice data)
• Right to Non-Discrimination: Exercise your rights without discrimination

Biometric Data Notice for California Residents: Voice recordings are classified as biometric information under CCPA. You have the right to know what biometric data we collect, request its deletion, and opt out of its collection.

10. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR):

• Lawful Basis: We process voice data based on your explicit consent
• Data Protection Officer: Contact privacy@kalemny.app for GDPR-related inquiries
• Supervisory Authority: You have the right to lodge a complaint with your local data protection authority
• Right to Erasure: You may request deletion of all voice recordings and conversation data

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted within the App and the "Last Updated" date will be revised.

Material changes will be communicated via in-app notification or email notification (if you have provided an email).

Continued use of the App after changes constitutes acceptance of the updated policy.

12. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

By using Kalemny, you acknowledge that you have read and understood this Privacy Policy.