Privacy Policy

Draft revision: October 30, 2026 — not yet published. Effective date to be assigned on publication.

This Privacy Policy explains how LOKEAI s.r.o., operating Leap to Fluent, collects, uses, stores, shares, and protects personal data when you visit leaptofluent.com, create or use an account, participate in language-practice calls, communicate with us, or otherwise use the Service.

Leap to Fluent provides scheduled AI telephone conversations for language-speaking practice, including a free trial and optional paid memberships. This Policy describes the personal data used to provide the service, personalized learning feedback, and subscriptions.

1. Who Is Responsible for Your Personal Data?

The data controller is:

LOKEAI s.r.o.
IČO: 06699391
Registered office: Pýchavková 282/7, 104 00 Praha – Pitkovice, Czech Republic
Registered in the Commercial Register maintained by the Municipal Court in Prague, file no. C 287363
Email: contact@leaptofluent.com
Website: leaptofluent.com

In this Policy, “Leap to Fluent,” “we,” “us,” and “our” mean LOKEAI s.r.o.

2. Personal Data We Collect

2.1 Account and Registration Data

When you register, create an account, start the free trial, or purchase a membership, we may collect:

• first name;
• email address;
• phone number;
• country;
• native language;
• language you want to practice;
• current language level;
• main language-learning goal;
• timezone;
• preferred call time;
• preferred practice frequency;
• learning-email and marketing-email preferences and the time those preferences were made or changed;
• confirmation that you are at least 18 years old; and
• the date and time of your Terms/Privacy acceptance.

Your WordPress account stores the authentication layer, including your first name, email address, an automatically generated internal username, and a password hash. We do not store your password in plaintext.

The broader profile, scheduling, preference, call, and learning data is stored in our application database.

2.2 Practice-Call and Call-Metadata Data

When you use an AI language-practice call, we may process:

• your voice/audio while the call is taking place;
• a transcription of the conversation;
• call date and time, duration, and call status, for example completed, missed, unanswered, or declined;
• telephone and conversation identifiers used to route and associate the call with the correct account; and
• technical information needed to deliver and troubleshoot the call.

Leap to Fluent does not store complete call transcripts in its main application database as permanent learning history. Complete transcripts are processed to generate learning feedback and may be temporarily retained by the voice provider and in backend workflow/debugging systems as described in Section 9.

We do not retain raw call audio as part of the user’s permanent learning record. Our current voice-provider configuration is set not to store call audio as a permanent recording.

2.3 Learning Memory, Feedback, and Derived Data

We use the conversation to generate and retain structured learning information, which may include:

• conversation summaries and main topics;
• grammar, vocabulary, naturalness, and pronunciation feedback;
• selected excerpts of what you said together with suggested corrections;
• new vocabulary and recurring mistakes;
• estimated language level, strengths, tips, and recommendations;
• speaking metrics and learning progress;
• learning goals and suggested future topics or exercises;
• context for the next practice call; and
• limited learning-memory context, such as broad interests relevant to practice, learning goals, language preferences, recurring mistakes, recent vocabulary, and short prior lesson summaries.

The learning-memory layer is designed to retain learning-relevant context rather than an unrestricted biography. It is configured to exclude unnecessary sensitive categories and detailed personal-profile information. If you mention such information during a call, it may still appear temporarily in the call transcript while the conversation is processed.

Please avoid unnecessary sensitive information. The Service is designed for language learning, not for collecting health, political, religious, financial, or other highly sensitive information. Please avoid sharing such information unless it is genuinely necessary for the language exercise.

2.4 Contact and Support Data

If you use our contact form or contact us by email, we may process your name, email address, optional phone number, enquiry topic, message, and any other information you choose to provide. Contact-form submissions are delivered to our business email system and are not intentionally stored as separate contact-form records in WordPress.

2.5 Technical, Security, and Website Data

When you use our website or Service, we and our service providers may process technical data such as IP address, browser and device information, operating system, date and time of access, requested pages or features, error data, server or workflow logs, and security-related information. We use this information for service operation, security, fraud and abuse prevention, troubleshooting, and maintenance.

We do not currently use automated IP geolocation to determine your precise location. We use PostHog for product analytics, session replay, and error tracking. Depending on the interaction, PostHog may process page or feature interactions, usage events, browser/device and technical information, error information, and session-replay data.

2.6 Data We Do Not Currently Collect

We use Stripe to process membership purchases and renewals. We may process your Stripe customer and subscription identifiers, plan and price identifiers, billing status, payment-related events, paid-through dates, and limited billing information needed for customer support, accounting and compliance. Payment card details are entered and processed through Stripe; we do not intentionally store full payment card numbers or card security codes in the Leap to Fluent application database. Availability of file uploads may change as the service develops.

3. How and Why We Use Personal Data

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before the withdrawal.

4. AI and Voice Processing

Leap to Fluent uses artificial intelligence as a core part of the language-learning Service. The voice tutor is an AI system and is identified as such during the call experience.

During a practice call, voice and transcript data may be processed by voice, transcription, telephony, and AI providers so that the Service can understand your speech, respond during the conversation, and generate structured learning feedback afterward.

Only limited learning-memory context may be provided to the AI voice system so that future practice can reflect your language level, goals, previous mistakes, vocabulary, preferences, and recent lesson context. We do not intentionally maintain or send an unrestricted biographical profile for this purpose.

We do not currently use solely automated processing to make decisions about you that produce legal effects or similarly significant effects. Language-level estimates, corrections, scores, and recommendations are educational features only and are not official certifications.

5. Calls, Scheduling, and Communications

5.1 Practice Calls

When you choose your available calling days, time windows and timezone, we use those settings to schedule AI language-practice calls to your registered phone number, subject to your current trial or paid membership allowance. You can change your schedule in My Account. A change to call scheduling is not, by itself, a change to billing or renewal.

5.2 Essential Account Emails

We may send essential emails needed to operate the Service, such as account-activation emails, password-reset messages, security notices, and necessary service communications. These messages are not marketing communications.

5.3 Optional Learning Emails

Depending on your settings and the service features you use, we may send personalized post-call feedback and weekly progress messages containing selected speech excerpts, corrections, vocabulary, summaries and recommendations. Certain learning communications may be part of delivering the service; separate optional educational or marketing emails are handled according to the applicable preferences and legal requirements. Review before publication: confirm how the live learning-email preference controls function.

5.4 Marketing Communications

Marketing emails are optional. If you opt in, we may send product news, launch information, offers, or other promotional communications. You can change your marketing preference in My Account or use another withdrawal mechanism we provide. We may retain a limited record of your preference so that we can respect it.

6. Cookies, Google Analytics, and PostHog

We use necessary cookies and similar technologies needed for website operation, security, and account functionality. We use Google Analytics on the public website to understand website usage and performance. We also use PostHog for product analytics, session replay, and error tracking in the website/application.

Non-essential analytics and session-replay technologies are subject to consent where required by applicable law. You can reopen the cookie settings and change or withdraw your choice. More information is available in our Cookie Policy.

7. Service Providers and Recipients

We use service providers to operate Leap to Fluent. They process personal data only for the purposes required to provide their services to us, subject to applicable contractual and legal requirements. Current key providers include:

We may change or replace service providers as the Service develops. If a change materially affects how we process personal data, we will update this Policy as appropriate. We do not sell personal data to advertisers.

8. International Transfers

Our primary application database, backend/workflow infrastructure, and PostHog project are hosted in the European Economic Area. Some service providers are international companies and may process or access personal data from countries outside the EEA.

Where personal data is transferred outside the EEA and additional safeguards are required, we use an appropriate lawful transfer mechanism, such as an adequacy decision, Standard Contractual Clauses approved by the European Commission, or another mechanism permitted by applicable law.

9. How Long We Keep Personal Data

We keep personal data only for as long as needed for the purposes described in this Policy, subject to legal, security, dispute, and technical requirements. Our current retention approach is:

• Account/profile, scheduling, call metadata, and derived learning data: generally for as long as your Leap to Fluent account remains open. When you delete your account, this data is removed from our active application systems, subject to the exceptions below.
• Complete call transcripts: not stored as permanent learning history in our main application database. ElevenLabs is currently configured to retain conversation data for up to 30 days. Transcript or processing payload data may also appear temporarily in backend workflow/debugging systems and encrypted backup or disaster-recovery copies. Residual backup copies may remain until the applicable backup expires, for up to 91 days.
• Raw call audio: not retained by Leap to Fluent as part of the permanent user learning record. Our current voice-provider configuration is set not to store call audio as a permanent recording.
• Contact and support correspondence: retained while reasonably needed to handle the matter, manage the relationship, maintain appropriate business records, comply with law, or establish, exercise, or defend legal claims.
• Technical and security logs: retained according to the relevant system/provider settings and for as long as reasonably necessary for security, troubleshooting, fraud/abuse prevention, and service operation.
• Consent, preference, and acceptance records: retained for as long as reasonably necessary to administer your preferences and demonstrate compliance.
• Analytics and session-replay data: retained according to the configured analytics/project retention settings and for as long as reasonably needed for product analytics, troubleshooting, error diagnosis, and product improvement.
• Backups and disaster recovery: we maintain encrypted, access-restricted backup and disaster-recovery copies of certain systems. Application archives are generally subject to lifecycle deletion after about 40 days, while certain disaster-recovery copies may be retained for up to 91 days. These copies are maintained for recovery, security, and business-continuity purposes rather than ordinary business use.
• Subscription, transaction and accounting records: retained for the periods required by applicable tax and accounting law, and where needed for disputes, refunds or legal claims. These records may remain after account deletion; only records necessary for the applicable purpose are retained. Review before publication: verify precise record categories, systems and statutory retention schedules.

We may retain specific information longer where required by law, necessary for legal claims, or reasonably necessary to investigate security incidents, fraud, or abuse. We may delete or anonymize information earlier when it is no longer needed.

10. Account Deletion and Correction

You may request self-service account deletion through My Account once any paid membership has ended. Canceling renewal does not necessarily end an existing paid access period immediately. You should first cancel your subscription in billing settings and wait until its paid period ends. This restriction relates to self-service deletion; you may contact us at any time to exercise your GDPR rights, including making an erasure request. We assess such requests under applicable law and may need to retain certain billing or legal records.

Following an accepted account-deletion request, we remove the associated WordPress account and applicable active learning/profile data in Supabase, cancel future scheduled calls and stop account-linked learning and marketing messages. Certain transaction, tax, security and legal records may need to be retained separately in accordance with Section 9.

Deletion from active systems does not necessarily remove every copy immediately. ElevenLabs conversation data may remain for up to 30 days under the current provider-retention setting. Residual personal data may also remain temporarily in encrypted backup and disaster-recovery systems until the relevant backup expires, which may take up to 91 days, and technical/security/workflow logs may remain until their normal retention period expires. We may also retain limited information where required by law or necessary for legal claims, security, fraud prevention, or to respect an unsubscribe preference.

You can update certain profile and communication-preference fields in My Account. To change other information, including your email address or phone number, contact us at contact@leaptofluent.com.

11. Data Security

We use reasonable technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access. Measures include multi-factor authentication for administrative accounts across our core systems, authenticated and restricted administrative access, encrypted communications where supported, password hashing for WordPress accounts, encrypted and access-restricted backup and disaster-recovery storage, security monitoring, and limiting human access to persons who need it to operate, support, secure, or maintain the Service.

No internet-based, cloud, AI, or electronic system can be guaranteed to be completely secure.

12. Your Data-Protection Rights

Depending on applicable law and the circumstances, you may have the right to:

• request access to personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request deletion of personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain personal data in a portable format;
• withdraw consent at any time where processing is based on consent;
• object to direct marketing at any time; and
• lodge a complaint with a competent data-protection authority.

You can exercise some controls directly in My Account, including updating certain profile fields, communication preferences, and deleting your account. For access/export requests or other rights, contact contact@leaptofluent.com. We may need to verify your identity before acting on a request.

13. Supervisory Authority

If you believe your personal data has been processed unlawfully, you may lodge a complaint with a competent supervisory authority. In the Czech Republic, the supervisory authority is:

Úřad pro ochranu osobních údajů
Office for Personal Data Protection
Pplk. Sochora 27
170 00 Praha 7
Czech Republic
Email: posta@uoou.gov.cz
Website: uoou.gov.cz

You may also have the right to contact the supervisory authority in the EU/EEA country in which you live, work, or where the alleged infringement occurred.

14. Children

We do not knowingly provide the service to children. If you believe a person under 18 has supplied personal data contrary to this restriction, contact us at contact@leaptofluent.com.

15. Paid Memberships and New Features

Memberships are purchased separately after the free trial. The trial does not automatically create a paid subscription without a purchase. Paid membership renewals and cancellations are managed through Stripe and the available billing interface. We may update this Policy when additional features materially change the processing of personal data.

16. Changes to This Policy

We may update this Privacy Policy to reflect changes in the Service, technology providers, data flows, business model, legal requirements, or privacy and security practices. When we update it, we will change the effective date at the top. Where required by law, we will provide additional notice of material changes.

17. Contact Us

Leap to Fluent
Operated by LOKEAI s.r.o.
IČO: 06699391
Pýchavková 282/7
104 00 Praha – Pitkovice
Czech Republic

Email: contact@leaptofluent.com
Website: leaptofluent.com