Privacy Policy

Last updated: 13 July 2026

1. Who we are

Avlalo ("we", "us", "our") operates the platform available at https://avlalo.com ("the Platform"). Contact us at info@avlalo.com.

2. Personal data we collect

We only collect the information required to operate the Platform and deliver our language-learning services:

• Name
• Email address
• Optional trainer preferences you choose to personalise your AI conversation partner (e.g. name, gender, age, and a photo)
• Conversation transcriptions for course lessons, used to generate your feedback (see Section 3)

We do not collect or store your full payment card details. Your payment is entered directly into a secure checkout page hosted by our payment provider, Stripe, and is never transmitted to or stored on our own servers. We do receive limited billing-related information from Stripe, such as your subscription status, renewal date, and payment history.

We do not sell personal data.

We do not share data with third parties for their own purposes.

3. Conversation transcriptions & AI processing

When you complete a course lesson, your conversation is processed to evaluate your performance and generate feedback. This is a core part of how course lessons work and is not an optional setting you can disable.

Standalone practice scenarios outside of a structured course are not analysed or scored in this way.

Your conversations are processed using the following third-party providers:

• Deepgram — speech-to-text transcription
• Google Gemini — language model processing
• OpenAI — language model processing

Processing is used exclusively to:

• evaluate lesson performance,
• analyse language use and progress,
• extract learning insights,
• provide feedback,
• support progress tracking over time.

Transcriptions are linked to your account solely for educational and performance-evaluation purposes. To protect your privacy, we never send these providers your real email address. Instead, we generate a unique identifier for your account that cannot be traced back to your personal information. We do not allow these providers to use transcriptions to train their models unless permitted by applicable agreements.

We do not use transcriptions for advertising.

We do not share transcriptions externally beyond the providers listed above.

User-Provided Sensitive Information

During lessons or interactions with the Platform, you may voluntarily provide personal or sensitive information. We do not request such information, nor do we classify or process it as special-category data. Any sensitive information you choose to share is provided entirely at your discretion, and Avlalo is not responsible for any consequences arising from your voluntary disclosure of such information.

4. Legal basis for processing

We process personal data under:

• Contractual necessity — to deliver the Platform's core features, including processing your subscription payment
• Legitimate interest — to analyse lesson performance and provide service improvements
• Legitimate interest — to prevent abuse of our refund policy, using a limited reference linked to your payment method that does not itself identify you
• Consent — for storing and analysing conversation transcriptions as part of course lessons

5. How we use your data

We use your information to:

• Manage your account
• Authenticate access
• Process your subscription and billing
• Deliver teaching and coaching services
• Provide AI-driven learning evaluation
• Track progress
• Send necessary service-related communications
• Provide user support

We do not use your data for marketing.

6. Data sharing

We only share your data with:

• Essential service providers (e.g., hosting infrastructure, the AI processing services listed in Section 3, and Stripe for payment processing)
• Authorities, when legally required

Service providers act strictly under our instructions and cannot use the data for their own purposes.

7. Data retention

• Account data is retained while your account remains active.
• Course lesson transcriptions are retained while your account remains active.
• Billing records are retained as required by applicable law.
• You may request deletion at any time.

If you request deletion, we retain a limited reference linked to your payment method (a one-way cryptographic reference generated by our payment provider, not your card number) for fraud and abuse prevention purposes, specifically to administer the one-time refund entitlement described in our Terms. This reference does not include your name, email, or other information that would allow us to directly identify you from it, and is not restored or linked back to any other personal data following deletion.

8. Security

We apply technical and organisational measures to protect personal data, such as encrypted connections and restricted access controls. Although no system can guarantee absolute security, we continuously update and improve our protections.

9. Your rights

You may request:

• access to your data,
• correction,
• deletion,
• restriction of processing,
• data portability,
• withdrawal of consent.

To exercise your rights, contact info@avlalo.com.

10. Changes

We may update this Privacy Policy. A new "Last updated" date will be published when changes occur.

11. Contact

For questions about this policy, contact info@avlalo.com.