Privacy Policy

Effective Date: September 25, 2026

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 is currently a beta language-learning service. This Policy is
intended to provide clear information about the data flows used in the current
version of the Service.

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, or apply for beta access, 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

The current beta does not provide user file uploads and does not currently
process payment-card, billing, or subscription-payment data. If paid
subscriptions are introduced, this Policy will be updated before those data
flows become part of the Service.

3. How and Why We Use Personal Data

Purpose Examples of data used GDPR legal basis where applicable
Create and administer your account; provide the beta Service; schedule and deliver practice calls; generate learning feedback and personalize practice. Account/profile data, phone number, schedule, call and learning data. Performance of a contract or steps requested before providing the Service (Art. 6(1)(b) GDPR).
Send optional learning emails and optional marketing communications. Email address, communication preference, personalized learning content. Consent (Art. 6(1)(a) GDPR).
Provide essential account and service communications, including activation, password reset, security, and necessary service notices. Email address and account/service information. Performance of a contract and, where relevant, legitimate interests.
Secure, troubleshoot, maintain, and prevent misuse of the Service. IP addresses, security logs, call/workflow metadata, error information. Legitimate interests in operating and protecting the Service (Art. 6(1)(f) GDPR).
Respond to enquiries and support requests. Contact and correspondence data. Legitimate interests and/or steps taken at your request.
Understand beta demand and improve the Service, including demand by country and aggregate usage patterns. Country, service usage, aggregate statistics, feedback. Legitimate interests, subject to your rights and reasonable expectations.
Use Google Analytics and PostHog to understand website/application usage, diagnose errors, and improve the user experience. Cookie/device data, product-usage events, page/feature interactions, error information, and session-replay data. Consent where required for non-essential analytics/session replay; legitimate interests may apply to limited technical error diagnostics where permitted by law.
Comply with legal obligations and protect legal rights. Relevant account, correspondence, or security records where applicable. Legal obligation (Art. 6(1)(c)) and/or legitimate interests in legal claims.

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

If you are given beta calling access and choose a preferred calling window,
frequency, and timezone, we use those settings to schedule automated AI
language-practice calls to the phone number you provided. If you change your
schedule, the current settings replace the previous schedule.

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

If you choose to receive learning emails, they may contain personalized
feedback, corrections, selected speech excerpts, vocabulary, progress
information, metrics, summaries, and recommendations. You can change this
preference in My Account.

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:

Provider / service Role Data that may be processed
ACTIVE24 Website/WordPress hosting and WordPress database hosting. Account/authentication data, website data, technical logs, hosting backups.
Supabase Primary application database, currently hosted in Paris, France. Profile, scheduling, preference/consent, call metadata, and derived learning data.
Amazon Web Services (AWS) EU-hosted backend/workflow infrastructure, including our self-hosted automation environment. Data needed to run workflows, including temporary call/transcript, profile, feedback, and technical execution data.
Twilio Telephony transport and call delivery. Phone number and call-routing/metadata information.
ElevenLabs AI voice agent, speech processing, conversation handling, and transcription. Voice during calls, phone number needed for call delivery, limited learning context, transcript, and conversation metadata.
OpenAI AI language analysis used to generate structured learning feedback. Call transcript, limited learning context, and a non-phone technical identifier used to associate the analysis with the correct account. The phone number is not intentionally included in the OpenAI analysis payload.
Google Workspace / Gmail Business email delivery and correspondence. Email addresses, account/service emails, contact enquiries, support and privacy correspondence.
Google Analytics Consent-based public-website analytics. Cookie/device and website usage data after applicable consent.
PostHog EU-hosted product analytics, session replay, and error tracking. Product-usage events, page/feature interactions, browser/device and technical data, error information, and session-replay data.
Wordfence Website security and firewall protection. IP addresses, request/security data, and security events.

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.

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 can delete your Leap to Fluent account through My Account. The deletion
flow includes a confirmation step designed to reduce accidental deletion.

After confirmed account deletion, we delete the associated WordPress account
and active application data in Supabase, cancel future scheduled practice calls,
and stop future learning/marketing emails tied to the account. You are then
logged out.

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

Leap to Fluent is currently intended only for individuals who are at least
18 years old. During registration, users are required to confirm
that they are at least 18 years old. We do not knowingly intend to provide the beta
Service to children. If you believe a person under 18 has provided personal
data contrary to this eligibility requirement, contact
contact@leaptofluent.com.

15. Future Paid Services and New Features

Leap to Fluent does not currently process paid subscriptions or payment-card
data. If we introduce paid subscriptions, social login, phone-verification
services, new analytics, anti-bot tools, or other features that materially
change personal-data processing, we will update this Policy before or when
those changes become applicable.

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