1. General

At ProStack, we value your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, and share your personal data regarding the Fluenti’s language learning platform.

This Privacy Policy (“Privacy Policy”) outlines the personal data that ProStack (“we”, “us”, “our”) collects about you, how we process it, and your rights and obligations regarding your personal data. ProStack's address is #301-ho, 16-14 Baekjegobun-ro 19-gil, Songpa-gu, Seoul. As the data controller, we comply with the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).

By accessing Fluenti, you accept the terms of this Privacy Policy. If you are unfamiliar with any of the terms or conditions, please review Fluenti's terms of use at https://bit.ly/3odxrEf. We may update this Privacy Policy as our information practices evolve, and if we make material changes, we will notify you of the changes at least 3 days before they take effect. The date when these terms were last revised is indicated at the bottom of this Privacy Policy.

If you are a ProStack employee, worker, or contractor, please refer to our internal knowledge base for information on how we handle your personal data. We are committed to working with European data protection authorities (DPAs) and adhering to their advice concerning human resources data transferred from Europe in the context of the employment relationship.

2. Information We Gather

This Privacy Policy explains how we collect, use, and share your personal data when you use Fluenti.

Information you provide When you register for Fluenti, you will provide your name, email address, and age or date of birth. If you choose to pay for Fluenti services, you will also provide payment transaction information.

Activity Data As you use Fluenti, you will submit information to your profile, and we will generate data about your use of the app, including engagement in educational activities. We collect technical data about how you interact with Fluenti, including usage patterns, taps, swipes, scrolling, typing, browser, device type, operating system, viewfinder size, script errors, IP address, navigation, pages visited, referrers, URL parameters, session duration, and learning activity data such as session progress and answers. We may use a third-party service to log your activity and provide a session replay of your activity.

Interacting with Practice You may interact with a feature called Practice, which lets you practice speaking and writing in a conversation format with an AI. Any data shared in this experience will be stored by Fluenti and our AI vendor, who may keep a copy or audio responses to help us improve the product. Please do not enter any of your personal data.

Speech Recognition Some lessons involve you speaking into the app. To recognize speech, your audio may be sent to a third-party provider. We may ask you to allow Fluenti to collect and analyze your speech data to help us understand the effectiveness of our lessons and improve the product. Any audio you agree to send to Fluenti is anonymized when it reaches our servers to ensure that no trace of your personal data remains attached to the audio.

Third-Party Data We may collect information about you from third parties. For more information, see Information obtained by Third Parties.

Product Research and Development We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio, and text transcriptions of this feedback together with any additional contact information you provide and will retain this data for two years.

Please contact us at [email protected] to: