Privacy Policy

Data Controller: Vocal Education Services, Inc.

This Privacy Policy explains how the Vocaelis platform collects, uses, and protects personal data. For more detailed information you may also review our disclosure notices.

The following data is collected on our platform:

• Identity information: name, school, class.
• Account information: username, password (encrypted).
• Audio data: voice recordings from AI conversations.
• Conversation data: transcripts, feedback, progress data.
• Technical data: device information, IP address, application logs.

We use your data for the following purposes:

• Providing the AI-powered conversation practice service.
• Personalized feedback and progress tracking.
• Pedagogical supervision by teachers.
• Fulfilling legal obligations.

Legal bases:

• Explicit consent: for audio data and optional features.
• Performance of a contract: for processing required to deliver the service.
• Legal obligation: for statutory retention requirements.
• Legitimate interest: for platform security (not used for audio data).

Your data may be shared with the following parties:

• Teachers and school administration: for pedagogical supervision and management.
• Technology providers: AI service providers and notification-infrastructure providers (named below).
• Legal requirements: competent authorities where required by law.

Specifically, we share data with the following third-party service providers:

• Google (Gemini API / Gemini Live): audio and conversation content is sent to Google for real-time AI processing that powers the conversation practice. Data encrypted in transit.
• Sentry: diagnostics and crash data, used to detect and fix errors. This data is not linked to your identity.

Your data is never sold or rented to third parties for commercial purposes.

Cross-border transfer: As part of the AI and cloud-infrastructure services, your data may be transferred abroad. Such transfers are carried out on the basis of your explicit consent or adequate protection safeguards (KVKK art. 9).

To protect your data we apply:

• Encryption (in transit and at rest).
• Access control and authorization.
• Regular security testing.
• Employee confidentiality undertakings.

• Account data: for as long as the account is active + the statutory retention period.
• Audio recordings: for as long as the account is active (deleted on account closure).
• Technical logs: 1 year.

Data is deleted or anonymized once the processing purpose ends or the account is closed.

Under applicable data protection law (KVKK) you have the right to:

• Learn whether your data is being processed.
• Request access to and correction of your data.
• Request deletion of your data.
• Object to the processing of your data.

To exercise your rights, contact us at privacy@vocaelis.com

Processing the personal data of users who are not of legal age is subject to the explicit consent of a parent or guardian. The parent or guardian may withdraw this consent at any time.

This policy may be updated. Significant changes will be communicated via in-app notification or email.

For any questions, including data deletion requests, contact us at privacy@vocaelis.com