Privacy Policy — Octolingo

Last updated: October 4, 2026

This Privacy Policy explains how Octolingo ("we", "us", "the App") collects, uses, and protects your information when you use our mobile application. Octolingo is operated by TIE d.o.o., Rudarska cesta 6, 3320 Velenje, Slovenia, European Union, company registration number 3713091000 ("we", "Data Controller").

If you have questions about this policy, contact us at support@octolingoapp.com.

1. Information We Collect

1.1 Information you provide

1.2 Information collected automatically

1.2b Cloud backup (signed-in users only)

If you are signed in, your learning progress (cards, review history, streak, achievements) is backed up to our server at specific moments — when you sign out, and when you switch to a different account, so it is not lost if you change devices or reinstall the App. This backup is accessible only through your authenticated account. If you are not signed in, no backup occurs — your device is the only place your progress is stored.

Usage events are recorded against a pseudonymous device identifier — a random value generated on your device. It does not contain your name or email, but it does allow activity from the same device to be linked together over time, so it remains personal data. When you are signed in, these events are linked to your account instead to help us understand usage and improve the App.

1.3 Guest use

You can use the App without creating an account. If you choose not to sign in, we do not collect any of the account information described in Section 1.1, and your learning progress remains only on your device. We do not access your contacts, photos, or other apps on your device.

2. How We Use Your Information

We use the information collected to:

We do not sell your personal information to third parties.

2.1 Legal bases for processing (GDPR Article 6)

Under the GDPR we must tell you not only what we do with your data, but on what legal basis. Each purpose below has one:

PurposeDataLegal basis
Creating and running your accountEmail, username, name, hashed password, Google identifierPerformance of a contract (Art. 6(1)(b)) — we cannot give you an account without it
Cloud backup of your learning progressCards, review history, streak, statisticsPerformance of a contract (Art. 6(1)(b)) — this is a feature of the signed-in service
Spaced-repetition scheduling and personalisationYour review results and progressPerformance of a contract (Art. 6(1)(b)) — it is the core of what the App does
AI speaking practiceYour voice; the episode title, transcript and your level sent as session contextPerformance of a contract (Art. 6(1)(b)) — you start this feature yourself and it cannot work without processing what you say. You are free never to use it
Feedback on sentences you say, and word explanationsThe sentence or word, as textPerformance of a contract (Art. 6(1)(b))
Translating words and text you look upThe text you tap or pastePerformance of a contract (Art. 6(1)(b))
Searching the podcast catalogueYour search termPerformance of a contract (Art. 6(1)(b))
Understanding how the App is used, so we can improve itUsage events tied to a pseudonymous device identifier (Section 1.2)Legitimate interests (Art. 6(1)(f)) — our interest in knowing which features work. We use this only for our own product decisions, never for advertising, profiling or sale, and you can object at any time (Section 6)
Keeping the service secure and fixing errorsDiagnostic and error dataLegitimate interests (Art. 6(1)(f))
Processing subscription paymentsPurchase data (handled by Google Play)Performance of a contract (Art. 6(1)(b)) — not yet active in the App

We do not rely on consent for any of the above. Where a feature requires processing in order to exist at all, consent would be misleading: refusing it would simply mean the feature cannot run. You remain free not to use any individual feature, and you can delete your account at any time (Section 6).

Transcription of podcast episodes does not appear above because no personal data is involved — only the published audio of the episode itself (Section 3).

3. Third-Party Services

To provide certain features, we share limited data with the following third-party service providers. Each operates under its own privacy policy:

ServicePurposeData shared
OpenAI — speaking practice (gpt-realtime)Live AI conversation practiceYour voice, streamed from your device directly to OpenAI (it does not pass through our server), together with context we send to start the session: the title and transcript of the episode you listened to today, your approximate known-word count and the verb tenses you are confident with
OpenAI — transcription (whisper-1)Producing word-by-word transcripts of podcast episodesNo personal data. Only the published podcast audio, downloaded by our server from the podcast’s own feed. Your voice is never sent here
Anthropic (Claude API)Word and grammar explanations; feedback on sentences you say in speaking practiceText only — never audio. The word or sentence concerned. For feedback on speaking practice, the chain is: your voice goes to OpenAI, OpenAI returns a text transcript, and only that text is then sent to Anthropic. No account identifiers are sent
Google Cloud TranslationTranslating words and text you look upThe word or text you tap or paste. No account identifiers are sent
TaddyPodcast catalogue and episode listsYour search term, when you search for a podcast. No account or device identifiers are sent; the request is made by our server, not by your device
Hetzner Online GmbH (Germany, EU)Hosting our server and databaseProvides the servers on which everything we store (Sections 1.1, 1.2, 1.2b) resides. Hetzner provides infrastructure only and does not use your data for its own purposes; processing takes place in the EU
Google PlayApp distribution and, in future, payment processingPurchase data and device identifiers, handled by Google. Subscriptions are not yet active in the App

Some of these providers are located outside the European Economic Area (EEA), including in the United States. Where this is the case, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, or the provider's participation in an equivalent legal data transfer framework, to ensure your data remains protected.

3b. AI-Generated Content

Some audio content in the App — our own educational podcast episodes — was narrated using AI voice synthesis. All of these episodes have already been produced and we no longer generate new ones, so no data is sent to a voice-synthesis provider when you use the App. Our AI conversation practice feature involves direct interaction with an AI system, not a human. Where required by applicable law (including the EU AI Act), we clearly indicate in the App when you are interacting with an AI system or engaging with AI-generated content.

4. Data Retention

We keep data only as long as it serves the purpose it was collected for:

DataHow long we keep it
Account (email, username, hashed password)Until you delete your account. If you do not sign in for 24 months, we delete the account and its cloud backup
Cloud backup of learning progressUntil you delete your account, or 24 months of inactivity. Each new backup replaces the previous one — we do not keep a history of backups
Usage events (analytics)14 months from the event, then deleted. Events are anonymised immediately if you delete your account
Your voiceNever stored by us — see below
Learning progress on your deviceUntil you delete your account or uninstall the App

You may request deletion at any time (Section 6).

Voice recordings never reach our server. During speaking practice, audio is streamed from your device directly to OpenAI, which processes it to generate a spoken reply. We do not receive, store or have access to that audio. Retention of the audio is governed by OpenAI’s own policies, not ours. What we do receive and store is the text of the sentences you said, as part of your learning progress, and the usage statistics described in Section 1.2.

5. Data Security

We take reasonable technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Your Rights

6.1 If you are in the European Economic Area (GDPR)

You have the right to:

If you have an account, you can delete your account and all associated server-side data at any time directly in the App (Settings → Delete Account). This is immediate and does not require contacting us. Deleting your account also erases the learning progress stored on the device you are using — your cards, streak and statistics — and this cannot be undone.

To exercise these rights, contact us at support@octolingoapp.com.

6.2 If you are a California resident (CCPA/CPRA)

You have the right to:

To exercise these rights, contact us at support@octolingoapp.com.

7. Children's Privacy

Octolingo is intended for users aged 16 and over. We do not knowingly collect personal data from anyone under 16. We set the limit at 16 rather than 13 deliberately: the speaking practice feature sends your voice to an external AI provider (Section 3), and we would rather not process children’s voices at all than build a parental-consent process we could not meaningfully verify.

If you believe someone under 16 has provided us with personal data, contact us at support@octolingoapp.com and we will delete it.

8. International Users

Octolingo is operated from Slovenia, European Union. If you use the App from outside the EU, your information may be transferred to and processed in Slovenia and in the countries where our third-party providers (Section 3) operate, including the United States.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Continued use of the App after changes constitutes acceptance of the updated policy.

10. Contact Us

If you have questions or requests regarding this Privacy Policy or your personal data, contact:

TIE d.o.o.
Company registration number: 3713091000
Rudarska cesta 6, 3320 Velenje, Slovenija
Email: support@octolingoapp.com