Privacy Policy

This Policy applies to GermanTutor.ai and related GermanTutor.ai services that link to it, including AI language learning, conversation practice, pronunciation practice, vocabulary and grammar learning, role-play scenarios, progress tracking, AI Language Certificate features, customer support, and subscription services.

Different or additional privacy terms may apply when GermanTutor.ai is provided through a school, university, business, organization, or other institutional customer. In those situations, the institution may control certain information and GermanTutor.ai may process information on its behalf under a separate agreement.

Third-party websites, applications, and services linked from GermanTutor.ai are governed by their own privacy notices.

The information we collect depends on how you interact with GermanTutor.ai and which features you use.

Account and contact information

• Name or display name, email address, account identifiers, login and authentication information.
• Language preferences, country or region, and settings associated with your account.
• Communications, customer-support requests, screenshots, files, or other information you choose to provide.

Learning and conversation information

• Text, prompts, conversation messages, role-play responses, exercises, and other learning content you submit.
• AI-generated responses, corrections, translations, pronunciation feedback, grammar feedback, and learning suggestions.
• Vocabulary, grammar, phrase, speaking, assessment, CEFR-related level, progress, completion, and learning-history information.
• Learning preferences and information used to personalize your experience.

Voice, audio, and speech information

• Voice recordings or audio snippets submitted through speaking and microphone features.
• Speech-to-text transcripts, pronunciation samples, speech timing, and language-learning feedback derived from speech.
• Technical information needed to transmit, process, troubleshoot, and deliver audio functionality.

Learning progress and certificate information

If you use progress tracking or an AI Language Certificate feature, we may process your account information, language studied, learning level, activities, assessment or progress results, certificate eligibility, certificate details, and information needed to display or verify a certificate.

Subscription and transaction information

• Plan, transaction amount and currency, payment status, order or transaction identifier, billing country or region.
• Renewal, cancellation, refund, tax, fraud-prevention, and payment-dispute information.
• Limited payment-method information supplied by a payment processor, such as card type or the last digits of a card.

When card details are entered directly into a payment provider’s checkout environment, GermanTutor.ai does not need to receive the complete card number or card security code.

Information collected automatically

Information from other sources

We may receive information from supported sign-in providers, payment providers, educational or business customers, service providers, and other sources when permitted by law and relevant to providing the Services.

We may use personal information to:

• Create, authenticate, maintain, and secure accounts.
• Provide AI tutoring, voice and text conversations, speech recognition, pronunciation feedback, exercises, and personalized learning.
• Maintain learning history, progress, assessments, and certificate-related functionality.
• Process subscriptions, payments, renewals, cancellations, refunds, taxes, and transaction records.
• Respond to support requests and communicate account, transaction, security, or service information.
• Detect fraud, abuse, unauthorized activity, and security threats.
• Troubleshoot problems, maintain reliability, conduct analytics, and improve our Services.
• Send marketing communications where permitted and subject to your choices.
• Comply with legal, tax, accounting, regulatory, and contractual obligations.
• Establish, exercise, or defend legal claims and protect users, Windvale LLC, and others.

We may create aggregated or de-identified information that is not reasonably capable of being linked to an identifiable person and use it for analytics, research, service improvement, or business planning where permitted by law.

GermanTutor.ai uses artificial intelligence and speech technologies to provide its Services. When you submit text, voice, audio, or other learning content, relevant information may be processed by GermanTutor.ai systems and by service providers supplying technologies such as artificial intelligence, speech recognition, text-to-speech, cloud computing, content safety, or infrastructure.

These systems may analyze your input to generate replies, corrections, pronunciation feedback, translations, exercises, transcripts, or other learning results.

AI-generated feedback is intended to support language learning. GermanTutor.ai does not use ordinary language-learning feedback to make decisions about you that produce legal or similarly significant effects.

Authorized personnel may access limited user information when reasonably necessary for customer support, security, abuse prevention, troubleshooting, legal compliance, or maintaining and improving the Services, subject to appropriate access controls.

Where applicable law requires a legal basis, we rely on one or more of the following:

Performance of a contract

We process information when necessary to provide services you request, including accounts, AI tutoring, conversations, learning tools, subscriptions, certificates, and support.

Legitimate interests

We may process information for legitimate interests such as securing the Services, preventing fraud and abuse, troubleshooting, maintaining reliability, understanding product usage, improving our Services, protecting legal rights, and operating our business. We consider the nature of the information and the impact on users before relying on this basis.

Consent

We rely on consent where required, including for certain non-essential cookies, marketing communications, optional features, sensitive processing, or other activities for which applicable law requires consent. You may withdraw consent at any time, subject to applicable law.

Legal obligations

We may process information to comply with legal, regulatory, tax, accounting, court, law-enforcement, or other binding obligations.

GermanTutor.ai may use cookies, local storage, pixels, SDKs, and similar technologies.

Strictly necessary technologies

Used for security, authentication, session management, fraud prevention, network operation, and features required to provide the Services.

Preference technologies

Used to remember language, interface, and other settings.

Analytics and performance technologies

Used, where enabled, to understand how users interact with GermanTutor.ai and to improve performance and functionality.

Advertising and measurement technologies

Where used, these technologies may help measure advertising effectiveness, attribute registrations or subscriptions, or provide advertising functionality.

Where applicable law requires consent before non-essential technologies are used, we will seek that consent and provide available privacy or cookie controls. You may also control certain cookies through your browser, although disabling them may affect functionality.

Where required by applicable U.S. privacy laws, we will process recognized opt-out preference signals, such as Global Privacy Control, as required in the circumstances.

We may disclose personal information in the following circumstances:

Service providers

We may use providers of cloud hosting, artificial intelligence, speech recognition, text-to-speech, authentication, databases, storage, security, fraud prevention, analytics, customer support, communications, payment processing, and technical monitoring. They receive information as reasonably necessary to perform their functions and are subject to applicable contractual and legal obligations.

Payment providers and financial partners

Information necessary to process purchases, subscriptions, refunds, taxes, fraud prevention, and payment disputes may be exchanged with payment providers, financial institutions, and related service providers.

Educational or business customers

If your account is provided or administered by a school, employer, university, or organization, certain account or learning information may be available to that organization according to the applicable agreement, account configuration, and law.

Legal and safety reasons

We may disclose information when reasonably necessary to comply with law or legal process, respond to valid authority requests, enforce agreements, investigate fraud or security incidents, protect rights or safety, or establish, exercise, or defend legal claims.

Corporate transactions

Information may be transferred as part of a merger, financing, acquisition, restructuring, bankruptcy, sale of assets, or similar transaction, subject to applicable law and appropriate safeguards.

At your direction or with your consent

We may disclose information when you request, direct, or consent to the disclosure.

Windvale LLC does not operate GermanTutor.ai as a data broker, and we do not sell personal information simply in exchange for money.

Some privacy laws define “sale,” “sharing,” or “targeted advertising” broadly and may treat certain advertising or measurement technologies as covered activities even when no money is exchanged for personal information.

If GermanTutor.ai engages in an activity considered a sale, sharing, or targeted advertising under applicable law, eligible users will be provided with legally required methods to opt out. Where required, we will also recognize applicable browser-based opt-out preference signals.

We do not knowingly sell or share personal information of children or teenagers in violation of applicable law.

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.

The applicable period may depend on the type of information, the feature used, whether the account remains active, whether information forms part of learning history or a certificate, security and fraud-prevention needs, support and dispute requirements, contractual requirements, tax and accounting obligations, and applicable legal limitation periods.

Voice or audio information may be processed temporarily or retained when necessary to provide a requested learning feature, maintain learning history, troubleshoot a problem, prevent abuse, or otherwise operate the Services.

Transcripts, conversations, progress information, and learning records may be retained while an account is active or until they are deleted under available features, a valid deletion request, or our retention practices.

Payment, tax, refund, fraud, and dispute information may be retained for longer when necessary to satisfy financial, legal, accounting, or payment-provider requirements.

When information is no longer required, we take reasonable steps to delete, anonymize, or securely dispose of it. Information removed from active systems may remain temporarily in protected backups until those backups are overwritten or expire through normal cycles. Aggregated or de-identified information may be retained for longer when it no longer reasonably identifies a person.

Windvale LLC is located in the United States, and GermanTutor.ai may use service providers located in the United States and other countries. Personal information may therefore be processed outside the country in which you live, where privacy laws may differ.

Where required by law, we use recognized mechanisms or safeguards for international transfers. Depending on the circumstances, these may include adequacy decisions, Standard Contractual Clauses, applicable UK international data-transfer mechanisms, contractual and technical safeguards, an applicable certified transfer framework, or another permitted mechanism.

You may contact [email protected] for additional information about applicable transfer safeguards where required by law.

Depending on where you live, you may have the right to:

• Request access to personal information and information about how it is collected, used, or disclosed.
• Request correction of inaccurate information.
• Request deletion of personal information.
• Receive a portable copy of certain information.
• Restrict or object to certain processing.
• Withdraw consent where processing relies on consent.
• Opt out of certain targeted advertising, sale, sharing, or profiling where applicable.
• Limit certain uses of sensitive personal information where applicable.
• Appeal certain privacy-request decisions where applicable.
• Receive equal treatment without unlawful discrimination for exercising privacy rights.

These rights are subject to applicable limitations and exceptions. We may request information reasonably necessary to verify your identity and protect your account before completing certain requests. An authorized agent may submit a request where permitted by law, subject to proof of authority and verification requirements.

If applicable European, UK, or Swiss data-protection law applies to our processing, you may have rights including access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and the right to lodge a complaint with the competent supervisory authority.

The availability of a particular right may depend on the legal basis and circumstances of processing.

Where GermanTutor.ai is legally required to appoint a representative in the EEA, United Kingdom, or another jurisdiction, the applicable representative information will be made available through this Policy or an applicable regional privacy notice.

Residents of California and certain other U.S. states may have additional rights under applicable state privacy laws. Depending on the law and whether it applies to Windvale LLC, these rights may include:

• Knowing or accessing categories and specific pieces of personal information collected.
• Learning the sources, purposes, and categories of recipients associated with personal information.
• Deletion, correction, and portability.
• Opting out of sale, sharing for cross-context behavioral advertising, or targeted advertising.
• Limiting certain uses of sensitive personal information.
• Opting out of certain profiling or automated decision-making activities where legally applicable.
• Appealing a privacy-request decision and receiving freedom from unlawful discrimination.

Where required, we provide applicable privacy choices and honor legally recognized opt-out preference signals.

GermanTutor.ai provides language-learning services that may be useful to teenagers and may include age-appropriate protection features such as Teen Protection Mode. However, the ordinary direct-to-consumer Services are not directed to children under 13 years of age.

A child under 13 should not independently create an account or submit personal information, voice recordings, or conversation content unless use occurs through a specifically supported parent-, guardian-, or institution-authorized arrangement that satisfies applicable legal requirements.

If the law in a user’s country requires parental or guardian consent at a higher age, the user should use the Services only with the authorization required by that law.

If we learn that personal information has been collected from a child in violation of applicable law, we will take appropriate steps to delete or otherwise lawfully handle it. A parent or guardian may contact [email protected].

We use reasonable technical, organizational, and administrative measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

Measures may include access controls, authentication, encryption in transit, infrastructure security, monitoring, restricted personnel access, backup protections, and security and fraud-prevention procedures, as appropriate.

No website, Internet transmission, or storage system can be guaranteed to be completely secure. Protect your credentials and notify us promptly if you suspect unauthorized account activity.

If a personal-data breach occurs, we will take appropriate response measures and provide notifications to affected individuals or authorities where required by law.

If you choose to receive marketing or promotional communications, we may use your contact information to send them where permitted by law.

You may unsubscribe using an available unsubscribe mechanism or by contacting us. Even after opting out of promotional communications, we may continue sending non-marketing messages necessary for your account, subscriptions, transactions, security, support requests, or important service changes.

GermanTutor.ai may contain links to websites, social-media services, payment providers, or other third-party services. We do not control the privacy practices of independent third parties.

Information you provide directly to those third parties is governed by their privacy notices and terms. We encourage you to review them before providing personal information.

GermanTutor.ai may provide services to schools, universities, businesses, or other organizations. When an organization provides or manages your access, it may determine certain purposes for which personal information is processed.

Depending on the relationship and applicable law, Windvale LLC may act as a data controller, processor, service provider, contractor, or equivalent regulated role.

Where an institutional agreement conflicts with this general Policy regarding information processed on behalf of that institution, the institutional agreement and applicable law may govern that processing. Students, employees, or other institutional users may also contact their organization regarding information controlled by that organization.

We may update this Policy as our Services, technology, legal obligations, or privacy practices change. When we do, we will update the “Last updated” date at the top of this page.

If changes are material, we may provide additional notice through the website, account interface, email, or another appropriate method where required by law. We encourage you to review this Policy periodically.

For privacy questions, requests, concerns, or complaints, contact:

Please include enough information for us to understand and respond to your request, but do not send passwords or complete payment-card information by email.

If applicable data-protection law gives you the right to complain to a supervisory or regulatory authority, you may also contact the authority responsible for data protection in your country or region.