Privacy Policy

Last updated: 12 July 2026

This Privacy Policy explains what personal data Polyglota collects, why we use it, who we share it with, and the rights you have — in plain language. It applies to our websites, the AI Student Portal, classes, translation services, the level test and the referral program.

1. Who is responsible (controller)

Polyglota (polyglota.app), operating from Portugal, is the controller of the personal data described in this policy. Contact for all privacy matters: info@polyglota.app.

2. Data we collect

Contact and account data: name, email, phone, password (stored hashed), language preferences.

Learning data: course progress, exercise answers, mistakes and corrections, saved vocabulary, notes, study plans, level-test answers and results, class schedules and attendance, homework and feedback.

Voice and speech data: recordings and/or transcripts you create in speaking practice (pronunciation, speaking missions, live practice) and — only with the explicit consent captured in that flow — class-conversation transcripts for learning analysis.

Documents: files you upload for translation quotes and the translated output (these may contain sensitive information — see section 6).

Payment and finance data: lesson balances, payment confirmations, invoices/receipts. We do not store card numbers.

Referral data: your referral code, anonymous visit counts, and — for referred people — the minimum needed to operate the program (see section 8).

Technical data: device/browser information, approximate location, usage analytics, and consent records (what you agreed to, when, from which page).

3. Why we use data (purposes and legal bases)

To provide the Services you request — classes, translations, the portal, the level test (legal basis: performance of a contract, or steps before a contract).

To personalise learning — your mistakes, vocabulary and progress power your personal study recommendations (contract / legitimate interest in providing an effective service).

To process voice recordings for pronunciation and speaking feedback (contract for practice features you actively use; consent for class-replay analysis).

To respond to enquiries and manage leads in our CRM (legitimate interest / pre-contractual steps).

To send marketing ONLY if you opt in (consent — withdraw any time).

To run analytics and advertising measurement (consent/legitimate interest — see the Cookie Policy).

To operate the referral program, including fraud prevention (legitimate interest / contract with the referrer).

To meet legal obligations (accounting, tax, consumer law).

4. AI processing

AI features are powered by Google Gemini. When you use them, the relevant text or audio (for example an exercise answer, a practice recording, or an uploaded writing sample) is sent to Google for processing and the result is returned to the portal. We do not use your content to train our own models, and we configure providers as processors for our service.

AI features never make decisions with legal or similarly significant effects about you. Level estimates, feedback and study plans are informational and reviewed or adjustable by humans (your teacher or our staff).

5. Service providers (processors)

We use trusted providers to run the Services: Lovable Cloud / Supabase (hosting, database, file storage), Google (Gemini AI, Google Analytics 4, Google Calendar for teachers’ scheduling), Meta (Meta Pixel advertising measurement), Microsoft (Clarity usage analytics), Freshworks (Freshsales CRM for leads and contacts), Calendly (trial-class booking), and banks/payment providers for payments. When you choose to contact us via WhatsApp, Telegram or Instagram, those platforms process your messages under their own policies.

6. Translation documents

Documents uploaded for translation may include identity, academic, medical or legal information. They are stored in a private bucket, are never publicly accessible, and are only available to the assigned translator and administrators through time-limited secure links. We use them exclusively to prepare your quote and translation, and we delete or anonymise them on request once legal retention needs (for example invoicing) are met.

7. Voice recordings

Practice recordings are processed to create a transcript and feedback. Class-conversation analysis (replays) happens only with the consent captured in that flow, and extracted learning points are reviewed by your teacher before entering your learning records. You can ask us to delete recordings at any time.

8. Referral program privacy

We designed the program to minimise data: referrers share a link; the referred person always submits their own details. Referrers NEVER see the referred person’s data — only anonymous counts and statuses (for example “Invited person #2 — signed up”). For referred people we store the referral code, at most a first name as an internal label, and progress status; you can ask us to anonymise your referral record at any time without affecting your account.

9. International transfers

Some providers process data outside the EU/EEA (for example in the United States). Where that happens we rely on appropriate safeguards, such as the EU–US Data Privacy Framework or Standard Contractual Clauses, plus technical measures.

10. Retention

We keep personal data only as long as needed: account and learning data while your account is active (and deleted or anonymised after you ask us to close it); consent records as a legal audit trail; payment and invoice data for the periods required by tax law; translation source documents until the job is complete plus a short handover window, unless you ask for earlier deletion; anonymous analytics indefinitely.

11. Your rights

You have the right to access, correct, delete and export your data; to object to or restrict certain processing; to withdraw any consent at any time (without affecting past processing); and not to be subject to automated decisions with legal effect. To exercise any right, email info@polyglota.app — we respond within one month.

You also have the right to complain to a supervisory authority — in Portugal, the CNPD (Comissão Nacional de Proteção de Dados, cnpd.pt), or the authority of your country of residence.

12. Security

We apply technical and organisational measures: encrypted connections, role-based access rules at the database level, private storage buckets with expiring access links, server-side permission checks for every sensitive action, and audit trails for consent and financial records. No system is perfectly secure, but we design for least access. Never share your password — we will never ask for it.

13. Children and minors

The portal is intended for users aged 16 or older; younger learners may use the Services only with the involvement and consent of a parent or guardian, who should create and manage the arrangement with us. We do not knowingly market to children.

14. Cookies and tracking

We use cookies and similar technologies (localStorage) for sign-in, preferences, analytics and advertising measurement. See our Cookie Policy for the full list and your choices.

15. Changes

We may update this policy as the Services evolve; material changes will be announced on the site. The date at the top always reflects the current version.

16. Contact

For any privacy request or question, email info@polyglota.app.