Privacy Policy

1. Introduction

Irums Consulting (“we,” “us,” “our,” or “Company”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the “App”).

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our App.

2. Information We Collect

A. Information you provide:

• Authentication data: email address, name, profile picture (via Google or Apple sign-in)
• Account preferences: language choice, daily practice goal, learning level
• Payment information: processed by Apple App Store and Google Play Store (we do not directly handle payment data)

B. Information generated during use:

• Speech recordings: temporary audio files while you speak (processed in real time, not permanently stored)
• Transcriptions: text of your speech (generated by our speech-to-text service, stored only as summaries, not full transcripts)
• Dialog summaries: notes about errors and areas for improvement (stored in our database)
• Progress data: dialogs completed, streak count, scenarios practised
• Usage analytics: app opens, features used, session duration (anonymized)

C. Device information:

• Device type, operating system, and version
• IP address and general location (country/region level)
• Device identifiers (for crash reporting and analytics)

D. Third-party data: When you sign in with Google or Apple, we receive the information you authorize them to share (name, email, profile picture).

3. How We Use Your Information

We use your information to:

• Provide, maintain, and improve the App and our services
• Process your account registration and manage your subscription
• Deliver personalized language learning experiences
• Generate feedback on your pronunciation and grammar
• Analyse usage patterns to improve the App (anonymized data only)
• Comply with legal obligations
• Communicate with you about updates, support, or promotional content (with your consent)
• Detect and prevent fraud or misuse

We do not use your information to:

• Sell or share personal data with third parties for marketing
• Build commercial databases or profiles
• Train other machine-learning models on your speech (except to improve Jolome)

4. Legal Basis for Processing (GDPR)

If you are in the EU or UK, we process your data based on:

• Your consent (e.g. for marketing emails)
• Performance of our service contract with you
• Our legitimate interests (e.g. preventing fraud, improving the App)
• Compliance with legal obligations

5. Third-Party Service Providers

We share your information with the following service providers to deliver Jolome:

A. Cloud infrastructure:

• Supabase (PostgreSQL database): stores account data, progress, dialog summaries
• Google Cloud: hosts some backend services

B. Speech processing:

• Microsoft Azure Speech Services: processes your speech-to-text requests; converts your speech to text in real time and does not permanently retain audio

C. Language processing: Third-party LLM providers (Claude, OpenAI, or similar) process text for AI responses; they do not store your complete dialogs and process only what is necessary for your current conversation.

D. Analytics: Google Analytics (anonymized usage patterns), Sentry (crash reports, anonymized).

E. Payment processing: Apple App Store and Google Play Store handle subscriptions (we never see payment details).

These third parties are contractually obligated to protect your data and use it only to provide services to us.

6. Data Retention

We retain your data as follows:

• Account information: while your account is active; deleted upon account deletion
• Dialog summaries and progress: while your account is active; deleted 30 days after account deletion
• Speech recordings: temporary only (real-time processing); not permanently stored
• Full transcripts: not stored; only summaries are retained
• Crash logs and analytics: 90 days maximum
• Backup copies: retained up to 30 days after deletion for disaster recovery

Upon account deletion, all personally identifiable information is removed. Anonymized usage data may be retained indefinitely for analytics.

7. Your Rights

Depending on your location, you may have the right to:

• Access your personal data
• Correct inaccurate data
• Delete your data (right to be forgotten)
• Restrict processing of your data
• Export your data in a portable format
• Withdraw consent at any time
• Object to certain types of processing

To exercise these rights, contact us at privacy@jolome.co. We respond within 30 days.

8. Data Security

We implement industry-standard security measures to protect your data: encryption in transit (TLS/SSL), encryption at rest, regular security audits and penetration testing, restricted access on the least-privilege principle, and secure authentication (OAuth 2.0). No method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

9. International Data Transfers

Your data may be processed and stored in different countries, including the United States and the European Union. By using Jolome, you consent to the transfer of your information to countries outside your country of residence, which may have different data-protection laws. If you are in the EU, we rely on Standard Contractual Clauses and other lawful mechanisms to transfer data internationally.

10. Children’s Privacy

Jolome is not directed to individuals under 13 years old. We do not knowingly collect personal data from children under 13. If we become aware that a child under 13 has provided us with personal data, we will delete such information promptly. For users aged 13–18, we provide additional privacy protections and restrict targeted advertising.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to remember your login status, track usage patterns for analytics, and improve your experience. You can disable cookies in your device settings, though this may limit App functionality.

12. Your Communication Preferences

You can manage your communication preferences in your account settings: opt out of marketing emails, control push notifications, and adjust data-sharing settings. To opt out of all non-essential communications, email privacy@jolome.co.

13. Third-Party Links

Jolome may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy policies independently.

14. California Privacy Rights (CCPA)

If you are a California resident, you have the right to know what personal data we collect, how we use it, and with whom we share it. You also have the right to delete your data and opt out of data sales (though we do not sell personal data for marketing). To exercise these rights, email privacy@jolome.co.

15. GDPR — EU Data Subject Rights

If you are in the EU or UK, you have specific rights under GDPR, including the right of access, right to rectification, right to erasure (right to be forgotten), right to restrict processing, right to data portability, right to object, and rights related to automated decision-making. You also have the right to lodge a complaint with your local data-protection authority if you believe we have violated your rights.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes via email or by prominently posting the updated policy in the App. Your continued use of Jolome after changes constitutes acceptance of the updated Privacy Policy.

17. Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us at:

• Email: privacy@jolome.co
• Address: Eemstraat 16, Heerlen, 6413WG, Netherlands
• Data Protection Officer (EU residents): dpo@jolome.co