Privacy Policy

Infercia ("we," "our," or "us") is committed to protecting the privacy and security of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered English learning application (the "App") available on iOS and Android platforms, and any related services (collectively, the "Services").

This policy applies to all users of our Services, including students, teachers, parents, and educational institutions. By using our Services, you agree to the collection and use of information in accordance with this policy.

2.1 Information You Provide Directly

Account Information:

• Full name
• Email address
• Username
• Password (encrypted)
• Date of birth (to verify age requirements)
• Country/region
• Preferred language
• User type (student, teacher, parent)

Profile Information:

• Profile picture (optional)
• English proficiency level
• Learning goals and preferences
• Time zone

Educational Data:

• Course enrollment and progress
• Lesson completion status
• Quiz and test results
• Speaking recordings (for pronunciation practice)
• Written assignments and responses
• Learning analytics and performance metrics
• Certificates earned

Payment Information (processed through secure third-party providers):

• Billing name and address
• Payment method details
• Transaction history

2.2 Information Collected Automatically

Device and Usage Information:

• Device type, model, and operating system
• Unique device identifier
• IP address
• Screen resolution
• Language settings
• Time zone

App Usage Data:

• Features accessed and frequency of use
• Session duration and timestamps
• Lesson interaction data
• Error logs and crash reports
• In-app navigation patterns

AI Interaction Data:

• Text inputs to AI tutors
• Voice recordings for speech recognition
• AI-generated responses and corrections
• Learning pattern analysis

2.3 Information from Third Parties

• Authentication data from social login providers (Google, Apple, Facebook)
• Information from educational institutions (for institutional accounts)
• Analytics data from third-party services

3.1 Primary Uses

To Provide and Improve Our Services:

• Create and manage user accounts
• Deliver personalized learning experiences
• Track learning progress and provide performance analytics
• Generate AI-powered lessons and feedback
• Process speech recognition and pronunciation analysis
• Provide customer support
• Send important service updates and notifications

For Educational Purposes:

• Adapt content to user proficiency levels
• Create customized learning paths
• Generate progress reports for users and authorized parties
• Provide certificates of completion
• Facilitate teacher-student interactions (where applicable)

For AI and Machine Learning:

• Improve our AI algorithms and language models
• Enhance speech recognition accuracy
• Develop better educational content
• Conduct educational research (with anonymized data)

3.2 Additional Uses

Business Operations:

• Process payments and prevent fraud
• Comply with legal obligations
• Enforce our Terms of Service
• Protect against security threats
• Conduct internal analytics and research

Communications:

• Send learning reminders and motivational messages
• Provide technical support
• Share product updates and new features
• Send marketing communications (with consent)

We DO NOT sell, rent, or trade personal information to third parties.

4.2 Limited Sharing Circumstances

Service Providers: We share information with carefully selected third-party service providers who assist us in:

• Cloud hosting and data storage (AWS/Google Cloud)
• Payment processing (Stripe, Apple Pay, Google Pay)
• Analytics (Google Analytics, Firebase)
• Email services (SendGrid)
• Customer support tools
• Speech recognition services
• Content delivery networks

All service providers are contractually bound to protect your information and use it only for specified purposes.

Legal Requirements: We may disclose information when required by law, including:

• Court orders or subpoenas
• Government investigations
• Child safety concerns
• Protection of our legal rights

Business Transfers: In the event of a merger, acquisition, or sale of assets, user information may be transferred with appropriate notice and consent options.

We retain personal information for as long as necessary to:

• Provide our Services
• Maintain user accounts
• Comply with legal obligations
• Resolve disputes
• Enforce agreements

Specific Retention Periods:

• Active account data: Duration of account plus 30 days
• Learning progress data: 3 years after last activity
• Voice recordings: 90 days (then automatically deleted)
• Payment records: 7 years (for tax purposes)
• Marketing data: Until consent withdrawn

Users can request data deletion at any time, subject to legal requirements.

6.1 Age Requirements

• Users must be at least 13 years old to create an account
• Users under 18 require parental consent in certain jurisdictions
• We offer special protections for users under 18

6.2 Parental Controls

For users under 18, parents/guardians can:

• Review their child's personal information
• Request corrections or deletions
• Manage privacy settings
• Monitor learning progress
• Control communication preferences

6.3 Special Protections for Minors

• No behavioral advertising targeted at users under 18
• Limited social features for younger users
• Enhanced content moderation
• Restricted data sharing
• No public profiles for users under 16

7.1 Technical Safeguards

• Industry-standard encryption (TLS 1.3 for data in transit, AES-256 for data at rest)
• Secure cloud infrastructure with regular security audits
• Multi-factor authentication options
• Regular security updates and patches
• Intrusion detection and prevention systems

7.2 Organizational Measures

• Limited employee access to personal data
• Confidentiality agreements for all staff
• Regular security training
• Incident response procedures
• Third-party security certifications

7.3 User Responsibilities

• Keep login credentials secure
• Use strong, unique passwords
• Report suspicious activity immediately
• Keep app updated to latest version

7.1 Access and Control

You have the right to:

• Access your personal information
• Correct inaccurate data
• Delete your account and data
• Export your data in a portable format
• Opt-out of marketing communications
• Manage cookie preferences
• Restrict certain processing activities

8.1 Data Controller

8.2 Data Protection Officer

8.3 General Inquiries

11.1 Types of Technologies Used

• Essential Cookies: Required for app functionality
• Analytics Cookies: Help us understand usage patterns
• Preference Cookies: Remember your settings
• Performance Cookies: Monitor app performance

11.2 Managing Preferences

• Adjust cookie settings in app settings menu
• Use device-level controls for mobile advertising IDs
• Opt-out of analytics through app settings

12.1 How We Use AI

• Natural language processing for content generation
• Speech recognition for pronunciation practice
• Personalized learning recommendations
• Automated feedback and corrections
• Adaptive difficulty adjustments

12.2 AI Data Practices

• AI models are trained on aggregated, anonymized data
• Individual voice recordings are not used for model training without consent
• AI-generated content is reviewed for accuracy and appropriateness
• Users can opt-out of certain AI features

12.3 Cultural and Content Considerations

• All AI-generated content complies with UAE content standards
• Content is reviewed for cultural appropriateness
• Religious and cultural sensitivities are respected
• Inappropriate content filtering is applied

As a UAE-based company operating globally, your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place:

Data Transfer Mechanisms

• UAE-approved data transfer agreements
• Standard Contractual Clauses (for EU data)
• Appropriate technical and organizational measures
• Compliance with UAE Federal Law No. 45 of 2021

Data Processing Locations

• Primary servers: UAE and other locations
• Backup facilities: Various locations
• Third-party processors: Various countries

We ensure all data transfers comply with applicable laws and maintain equivalent protection levels.

For UAE Users

We process personal data in accordance with UAE Federal Law No. 45 of 2021 based on:

• Consent: For optional features and marketing
• Contract Performance: To provide our educational services
• Legal Obligations: To comply with UAE laws and regulations
• Legitimate Interests: For security, fraud prevention, and service improvement
• Vital Interests: To protect health and safety

For EU/UK Users (GDPR)

We process personal data based on:

• Contract: To provide our Services
• Consent: For marketing and optional features
• Legitimate Interests: For security, fraud prevention, and service improvement
• Legal Obligations: To comply with applicable laws

Additional Compliance: This policy complies with:

• UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection
• GDPR (for EU/UK users)
• Educational data protection standards
• Regional privacy laws in operating countries