🔒 Privacy Policy

Kelmet is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you use our mobile application.

1. Information We Collect

1.1 Account Information

When you create an account, we collect:

• Email address (required for all registration methods)
• Username (required for email sign-up only)
• Password (encrypted - only for email sign-up)
• Profile information (optional)
• Learning preferences and progress (automatically tracked)

Registration Methods

You can create an account using:

1. Google Sign-In - We receive: email, name, profile picture (with your permission)
2. Apple Sign-In - We receive: email (or private relay), name (optional)
3. Email + Password - You provide: email, username, password

Email Verification

• Email verification is NOT required to use the app or your 20 free IA Credits
• Email verification IS required to make purchases (subscriptions, credit packs) - only for email sign-up
• Google/Apple Sign-In users have pre-verified emails (can purchase immediately)

1.2 Usage Data

We automatically collect:

• Lesson completion and progress
• Exercise results and scores
• Learning statistics and milestones
• App usage patterns
• Device information (type, OS version)
• IP address (for security purposes)

1.3 Audio Recordings

1.4 Purchase Information

Through Apple's In-App Purchase system:

• Subscription status
• Purchase history
• IA Credits balance (including free credits and purchased credits)
• Note: Payment details are handled exclusively by Apple and never shared with us

2. How We Use Your Information

2.1 Core App Functionality

• Manage your account (required for app access)
• Provide personalized language learning experience
• Track your progress and adapt content to your level
• Save your exercise results and learning statistics
• Manage your subscription (if applicable)
• Process IA Credit purchases and usage
• Distribute 20 free IA Credits to new users
• Sync your learning data across devices

2.2 AI-Powered Features

• Pronunciation analysis: Audio → Azure Speech-to-Text → Gemini AI feedback
• Image description analysis: Your text → Gemini AI evaluation
• Open question responses: Your text → Gemini AI correction
• Role-play conversations: Your responses → Gemini AI dialogue management
• All AI processing is done without permanently storing your audio recordings

2.3 Communication

• Send lesson reminders and learning tips
• Account verification emails (for email sign-up)
• Important updates about the service
• Customer support responses

3. Third-Party Services

3.1 Microsoft Azure Speech-to-Text

• Purpose: Convert audio recordings to text for pronunciation analysis
• Data shared: Temporary audio files (deleted after processing)
• Privacy Policy: Microsoft Azure Privacy

3.2 Google Gemini AI

• Purpose: Analyze language learning exercises and provide personalized feedback
• Data shared: Text transcriptions, user responses, exercise context
• Privacy Policy: Google Gemini Privacy

3.3 Google Cloud Platform (GCP)

• Purpose: Backend infrastructure, database, file storage
• Compliance: GDPR-compliant infrastructure

3.4 Apple In-App Purchases

• Purpose: Process subscriptions and IA Credit purchases
• Data handling: All payment processing is handled by Apple

4. Data Retention

4.1 Active Accounts

• We retain your data as long as your account is active
• Learning progress and history are preserved for educational continuity

4.2 Audio Recordings

• Audio recordings are deleted immediately after processing
• Only text transcriptions are retained for exercise history

4.3 Account Deletion

• You can request account deletion at any time via: info@kelmet.app
• All personal data will be permanently deleted within 30 days
• This includes your IA Credit balance

5. Data Security

• Encryption in transit: All data transmitted via HTTPS/TLS
• Encryption at rest: Database encryption on Google Cloud Platform
• Password protection: Passwords are hashed and salted (bcrypt)
• Access controls: Role-based access to backend systems

6. Your Rights (GDPR)

Under the General Data Protection Regulation (GDPR), you have the right to:

• Access: Request a copy of all personal data we hold about you
• Rectification: Correct inaccurate or incomplete personal data
• Erasure: Request deletion of your personal data ("right to be forgotten")
• Portability: Receive your data in a structured format

To exercise your rights, contact us at: info@kelmet.app

7. Children's Privacy

• Kelmet is intended for users aged 13 and above
• We do not knowingly collect data from children under 13

8. International Data Transfers

• Your data may be processed in servers located outside your country
• We use Google Cloud Platform (European data centers when possible)
• All transfers comply with GDPR requirements

9. Changes to This Policy

• We may update this Privacy Policy from time to time
• We will notify you of significant changes via email or in-app notification

10. Legal Basis for Processing (GDPR)

• Contract Performance: Account creation is necessary to provide the learning service
• Legitimate Interest: Improving our service and ensuring security
• Consent: Using optional features like pronunciation exercises

11. Contact Us

For any questions about this Privacy Policy or your data: