Privacy Policy

This Privacy Policy along with our Terms of Service applies to the website supafluent.com and all its subdomains (the "Site"), together with the Supafluent language learning platform and services (the "Services"), owned and operated by superfluid digital UG (haftungsbeschränkt) (Limited liability Business, collectively, "supafluent", "superfluid", "superfluid digital", "we", "us", or "our"). This Privacy Policy describes how we collect, use, share, and secure the personal information you provide to us. It also describes your choices regarding use, access, correction, and deletion of your personal information.

1. Definitions

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

The marketing site refers to all public-facing informational pages on our website. This includes content such as the homepage, about us, contact information, product descriptions, and support resources. Essentially, it's any part of the site accessed from the main supafluent.com domain that provides information about our company, products and services but does not require user login.

The web application consists of all functional pages that require user authentication and are part of the Supafluent service delivery. This includes, but is not limited to, user dashboards, learning interfaces, conversation sessions, progress tracking, personal profile settings, and subscription management. These pages provide the interactive components of Supafluent where users can manage their accounts and access the platform's features.

2. What Data We Collect

We collect both information you knowingly and actively provide us when using or participating in any of our services and promotions, and any information automatically sent by your devices in the course of accessing our products and services.

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

Third-party Services and Sub-processors

We share certain information with companies that may be considered our "sub-processors" under GDPR. The following services are required for the operation of the supafluent.com website and corresponding services:

Important: By using Supafluent, you agree to the terms of service and privacy policies of our AI providers (Google Gemini and Groq). Your conversation data is processed by these services in accordance with their respective policies.

3. How We Collect Information

Information That You Provide to Us About Yourself

When you sign up for the Services, we request information such as:

• Contact Information: such as name and email address
• Learning Data: Language preferences, learning progress, conversation history, and session data
• Voice Data: Audio recordings during conversation sessions (processed in real-time and not permanently stored)

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with the purpose of providing you with our Service's core features.

Please be aware that we may combine information we collect about you with general information or research data we receive from other trusted sources.

Information Collected Automatically

When you visit our website, our servers automatically log standard data provided by your web browser. This may include your device's Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error occurred, and other technical information related to the problem. You may or may not receive notice of such errors, even in the moment they occur, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Information Collected After Opt-In Permission

We use essential cookies for website functionality and authentication. We do not use tracking or advertising cookies. We will update this data policy if that changes.

4. How We Use Information

• Provide, maintain, and improve the Service
• Process and complete transactions
• Deliver language learning sessions and AI-powered coaching
• Track learning progress and provide personalized recommendations
• Send you technical notices, updates, security alerts, and support messages
• Respond to your comments, questions, and requests
• Personalize your experience on the Service
• Monitor and analyze trends, usage, and activities in connection with the Service
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Comply with legal obligations

5. Sharing of Information

We may share your information in the following circumstances:

• With your consent or at your direction
• With service providers who perform services on our behalf (as listed in Section 2)
• To comply with legal obligations
• In connection with a merger, sale, or acquisition of all or a portion of our company

Important: Your voice data during conversation sessions is processed in real-time by our AI providers (Google AI or Groq) but is not permanently stored on our servers. Transcripts may be temporarily stored for session continuity.

6. Security

The security of your personal information is important to us. We implement adequate measures to protect the personal information submitted to us, both during transmission and once it is received. We take steps to ensure that all data remains private and confidential.

We restrict access to personal information to our employees, contractors, and agents who need to know that information in order to operate, develop, or improve our service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

If you have any questions about the security of your personal information, you can contact us using the contact information below.

7. Rights with Respect to Your Information

You always retain the right to withhold personal information from us, with the understanding that your experience of our website may be affected. We will not discriminate against you for exercising any of your rights over your personal information.

Your Rights

• Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.
• Object to processing of your Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent.
• Access your Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. You have the right to verify the accuracy of your Data and ask for it to be updated or corrected.
• Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your Data.
• Have your Personal Data deleted or otherwise removed. You have the right to obtain the erasure of your Data from us.
• Receive your Data and have it transferred to another controller. You have the right to receive your Data in a structured, commonly used, and machine-readable format.
• Lodge a complaint. You have the right to bring a claim before your competent data protection authority.

How to Exercise These Rights

To exercise your rights, such as requesting or deleting your data, please contact us through the contact details provided below. Requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.

8. Data Retention

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.

• Account data: Retained for the duration of your account and up to 2 years after deletion for administrative purposes
• Learning progress data: Retained while your account is active
• Voice data: Processed in real-time and not permanently stored
• Payment data: Retained for the period required by German tax law (typically 10 years)
• Support communications: Retained for quality assurance and record-keeping purposes

Even if you delete your account, keep in mind that deletion by our third-party providers may not be immediate, and the deleted information may persist in backup copies for a reasonable period of time.

9. Policy Regarding Children

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13. If you are under 13, please do not use our Service or provide any information to us.

10. Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

11. Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we may contact you and all our registered users with the new details and links to the updated or changed policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.