Privacy Policy

How Simply Fluent collects, uses, and protects your personal data while using our platform.

Last updated: April 9, 2025

Privacy Policy

Last updated: April 9, 2025

Introduction

Simply Fluent is owned and operated by Simply Fluent OÜ.

We value your privacy and the protection of your personal data. This privacy policy explains what information we collect from you, how we collect it, how we use it, how we obtain your consent, how long we retain it, and if necessary, with whom we share it.

By using our platform, you are accepting the practices described in this Privacy Policy. Your use of the platform is also subject to our Terms and Conditions.

This Privacy Policy may change from time to time. Your continued use of the platform after we make changes is deemed acceptance of those changes, so please check the policy periodically for updates. This Privacy Policy has been prepared and is maintained in accordance with all applicable national and international laws and regulations, particularly with the California Online Privacy Protection Act (“CalOPPA” – U.S regulation) and the General Data Protection Regulation (“GDPR” - European regulation).

1. General Information

The personal data of users collected and processed through the platform:

Will be under responsibility and in charge of:

  • Simply Fluent - Simply Fluent OÃœ
  • legal AT simplyfluent.com

(Hereinafter referred to as “Simply Fluent”).

2. Types of Information We Collect

The information we collect from our users and customers helps us to deliver our products effectively and to personalize and continually improve the user experience on the platform. Here’s what we collect:

Information You Provide to Us

You provide information when you search, read and view content through the platform, register as a user, use the functionalities within the platform, and/or communicate with us. This information may include:

  • First and last name
  • Email address
  • Social network account information (Google, Apple)
  • Any additional information relating to you that you provide to us directly or indirectly through our platform

Simply Fluent will not collect any personally identifiable information about you unless you provide it.

Information Collected Automatically

By accessing and using the platform, you automatically provide us with:

  • The device and usage information you use to access the platform
  • Your IP address
  • Browser and device characteristics
  • Operating system
  • Referring URLs
  • Your location
  • Which parts of the platform you use and how often

If you access the platform through a mobile device, we will collect:

  • Mobile device ID
  • Model and manufacturer
  • Operating system
  • Version information
  • IP address

Payment Information

Subscription payments are made through in-app payments. Your credit/debit card details or payment information will be processed by Google Play and App Store through RevenueCat, which will process and store your details securely and solely for processing subscription purchases. Simply Fluent reserves the right to engage any payment platform available on the market, which will process your data solely for processing subscription purchases.

Social Media Information

On our platform, you’ll find links and functions connected to different social media platforms where you can share information.

We recommend you consult the privacy policy and data protection terms of each social media platform used on our platform.

Google

Apple

3. How Long We Keep Your Data

We follow the data minimization principle: we only store and process personal data that is essential for providing you with the best service possible. We do not store or process personal data we don’t use.

We retain your personal data as follows:

  • Personal data in our accounting records for tax authorities are stored for at least 10 years after your last transaction on our Platform
  • Personal data we process to prevent fraud is stored for at least 5 years after your last login
  • All other personal data used within your account is stored for 5 years after your last login

If your account is inactive, we will send you reminders after 3 years, 4 years, and 5 years of inactivity. After 5 years of inactivity, we will remove your account and personal data. We will also remove your personal data immediately after you delete your account.

4. How We Use Your Information

We use the information we collect primarily to provide, maintain, protect, and improve our platform and services. Specifically, we use your personal data to:

  • Identify you as a user in our system
  • Provide the platform (available on Google Play and App store)
  • Enable registration and login via social network accounts (Google, Apple)
  • Send registration and login links to your email address
  • Enable user registration (via email)
  • Provide subscriptions and platform functionalities
  • Improve our platform and business operations
  • Understand and enhance your experience using our platform
  • Respond to your comments or questions through our support team
  • Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and administrative messages
  • Communicate with you about upcoming events, offers, and news about services offered by Simply Fluent and our selected partners
  • Support our marketing efforts
  • Link or combine your information with other data to help understand your needs and provide better service
  • Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity

By registering as a user, using the platform’s functionalities, communicating with us through contact forms or our contact information, and providing us with personal information, you consent to our collection, storage, and use of your information as described in this privacy policy.

You may withdraw your consent by contacting us via the information provided at the end of this policy.

6. How We Share Information

Your personal information is fundamental to our business. Under no circumstances will we sell or share information with third parties that has not been previously authorized by you or the owner of the personal data. We share user information solely as described below.

Third-Party Service Providers

We use third-party services to perform certain functions on our behalf. Examples include:

  • Firebase Authentication: Allows users to create accounts, log in, and securely access our platform. When users register or log in using Google or Apple accounts, Firebase processes user data to verify identities, manage authentication sessions, and enhance account security. This may include basic profile information like your name and email address. Firebase Privacy Policy

  • SendGrid and MailChimp: Used for processing and sending emails, including account notifications and newsletters you’ve opted into. These services process email data in accordance with their respective privacy policies.

  • Gleap: Used for customer support and collecting feedback, helping us improve our platform based on your input.

  • CloudConvert: Used to convert PDF files uploaded by users to formats better suited for our platform. When you upload a PDF file, it may be processed by CloudConvert, temporarily storing your file on their servers for conversion. CloudConvert Privacy Policy

  • Sentry: Used for crash and error reporting to improve our platform’s stability and performance. These tools help us diagnose issues by collecting crash reports and error data, which may include user identity information to provide more effective debugging and support.

  • RevenueCat: Processes subscription payments through in-app payments. RevenueCat will have access to your user ID, name, and email address to process and manage your subscriptions securely.

  • Wasabi: Used for cloud storage of user-uploaded books and documents to enable synchronization across devices.

These third-party services may have access to personal information needed to perform their functions but may not use that information for other purposes. Information shared with these services is processed in accordance with their respective privacy policies and our privacy policy.

External Controllers and Marketing Partners

We may also share your personal data with external controllers in the following cases:

Payments: Your payment will be processed via a third-party payment service provider. We currently use RevenueCat for providing this service. Any personal data you provide to this payment provider will be processed by the payment provider (as separate Controller) in accordance with their own privacy policies.

Tax authorities: We are legally obliged to include certain personal data in our financial administration, which may have to be shared with various national tax authorities. The tax authorities will process these personal data as separate Controller in accordance with their own privacy policies.

Marketing Partners: We may share certain contact information (such as email addresses) with trusted external marketing professionals who assist us with our marketing efforts, including sending newsletters and promotional communications. These professionals have access only to the information necessary to perform their marketing functions and are contractually obligated to process this data in accordance with GDPR and other applicable data protection regulations. They may not use your information for any purpose other than providing marketing services to Simply Fluent. The legal basis for this sharing is our legitimate interest in promoting our services, or your consent where required by applicable law.

Apart from the above, we may share your personal data with third parties if we are legally obliged to do so. Simply Fluent does not sell, trade, or rent personal data to third parties. We may share generic aggregated data with our business partners and trusted affiliates. In such cases, the data will be fully anonymized.

7. International Data Transfers

We may transfer personal data to parties outside the European Economic Area (EEA) if one of our service providers is established outside the EEA. We ensure that any transmission of personal data outside the EEA complies with the Privacy Legislation (chapter 5 of the GDPR), meaning personal data will only be transferred to a company or country that provides an adequate level of protection.

8. Protecting Your Information

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you provide or share through the platform. For transactions processed on the platform, transaction information is transmitted in encrypted form using industry-standard SSL connections.

We restrict authorized access to your personal information to those persons who have a legitimate need to know such information to provide certain functions and to those persons you have authorized to have access.

Simply Fluent follows generally accepted industry standards for data security to protect your personal information, both during transmission and once we receive it. No method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

9. Your Rights

As a user providing information through our platform, you have specific rights over your data. While some of these rights apply generally, others apply only in certain limited circumstances:

  • Access and Portability: You can request access to know what information is stored in our servers, and you can request a copy of your data in a structured, commonly used format.

  • Rectify, Restrict, Limit and/or Delete: You can request correction of inaccurate personal data, restriction of processing in certain circumstances, or deletion of your data where there is no compelling reason for us to continue processing it.

  • Right to be Informed: Upon request, we’ll inform you about what data we collect, how it’s used, how long it’s retained, and whether it’s shared with third parties.

  • Object: When we process your information based on our legitimate interests or in the public interest, you may object to this processing in certain circumstances. In such cases, we will stop processing your information unless we have compelling legitimate reasons to continue or where processing is necessary for legal reasons.

  • Revoke Consent: Where you’ve previously given consent, such as for processing and storing your personal information, you have the right to withdraw that consent at any time. For example, you may withdraw consent by contacting us at legal AT simplyfluent.com. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal was limited to certain processing activities.

  • Complaint: If you wish to file a complaint about our use of your information, you have the right to do so with your local supervisory authority.

  • Rights Related to Automated Decision-making: You may request information about any automated processing activities we conduct if you believe data is being unlawfully processed.

You can exercise all these rights by contacting us through the information at the end of this policy.

10. Children’s Online Privacy Protection

We comply with all applicable national and international laws and regulations regarding the protection of children’s personal data, including the Children’s Online Privacy Protection Act (COPPA) in the US and the General Data Protection Regulation (GDPR) in the EU.

For users in the European Union: We do not knowingly collect information from children under the age of 16 without parental or legal guardian permission.

For users outside the European Union: We do not knowingly collect information from children under the age of 13 without parental or legal guardian permission.

If you become aware that a child under the applicable age limit has provided us with personal information without appropriate permission, please contact us. If we discover that a minor has provided us with personal information without parental or legal guardian permission, we will take steps to delete that information, terminate that person’s account, and restrict access.

11. Editing and Deleting Information

If you believe any information we hold about you is incorrect or incomplete, please contact us as soon as possible. We will promptly correct any information found to be incorrect.

You can change, modify, correct, and delete your information at any time by contacting us using the information at the end of this policy. To stop receiving emails from Simply Fluent, please follow the unsubscribe instructions included in our emails. Your request should be processed within 48 hours.

12. Third Parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information Simply Fluent collects from you. If you disclose your information to others, whether other Simply Fluent users or vendors, different rules may apply to their use or disclosure of the information you disclose to them.

Simply Fluent does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. Simply Fluent is not responsible for the privacy or security practices of other platforms, including those linked from Simply Fluent.

13. Beta Testing Program

As part of our commitment to developing high-quality products, Simply Fluent offers a beta testing program that allows users to experience pre-release versions of our platform. When you sign up for our beta program, we collect additional information necessary to facilitate the testing process and provide you with access to beta features.

Beta Program Sign-up Information

When you apply to join our beta testing program, we collect specific information. This information may include:

  • Your name (optional)
  • Email address (associated with your Apple ID or Google Play account)
  • Country of residence
  • Device information (which devices you own: iPhone, iPad, Android phone, Android tablet)
  • Languages you are interested in learning
  • Information about your current language learning methods
  • Any additional feedback or information you provide in your application

How We Use Beta Testing Information

The information collected during the beta program is used for:

  • Evaluating your eligibility for the beta program
  • Providing you with access to pre-release versions of our platform
  • Sending you instructions, updates, and communications about the beta program
  • Collecting feedback on features, usability, and performance
  • Analyzing usage patterns to improve our platform
  • Troubleshooting issues specific to the beta version
  • Determining regional preferences and requirements

Data Retention for Beta Testing

Information collected for the beta program will be retained for the duration of the beta testing period plus an additional period of up to 12 months to allow for analysis and implementation of feedback. After this period, your beta application information will be deleted or anonymized, unless you have opted to become a regular user of our platform, in which case your information will be handled according to our standard retention policies outlined in Section 3.

Withdrawing from the Beta Program

You may withdraw from the beta program at any time by contacting us at beta AT simplyfluent.com. Upon withdrawal, you will no longer receive beta-related communications, though we may retain your feedback and usage data from the beta period for the purposes described above.

Beta testers have the same rights over their personal information as described in Section 9 of this Privacy Policy, including the right to access, rectify, restrict, and delete their information.

14. Contact Us

If you have questions or concerns about this privacy policy and the processing and security of your data, please contact us:

Simply Fluent OÜ

legal AT simplyfluent.com