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Privacy Policy

FluentNow.ai

Effective Date: 2026-02-01

Last Updated: 2026-02-01

This Privacy Policy explains how Crystalab LLP ("FluentNow," "we," "us," or "our") collects, uses, stores, and protects your personal data when you use FluentNow.ai ("Service"). Crystalab LLP is a limited liability partnership registered in England and Wales.

We are committed to protecting your privacy and processing your data in accordance with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and other applicable data protection laws.

By using the Service, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

The data controller responsible for your personal data is:

Crystalab LLP

71-75 Shelton Street

London

WC2H 9JQ

United Kingdom

For all privacy inquiries and data requests, contact us at privacy@fluentnow.ai.

2. Data We Collect

2.1 Account Data

When you create an account, we collect your name, email address, and date of birth. Date of birth is collected to verify that you meet our minimum age requirement of 16 years.

2.2 Voice and Conversation Data

When you use the Service, we collect audio recordings of your conversations with our AI assistant, transcripts generated from those conversations, and AI-generated assessment results including CEFR level estimates, feedback, and improvement suggestions.

2.3 Payment Data

When you subscribe, payment is processed by Stripe, Inc. We do not store your full credit card number or payment credentials on our servers. Stripe may collect and process payment information in accordance with its own privacy policy. We receive and store limited transaction data such as subscription status, billing dates, and transaction identifiers.

2.4 Usage Data

We collect data about how you interact with the Service, including session duration, features used, frequency of usage, and conversation history. This data is collected through PostHog, our analytics provider.

2.5 Technical Data

When you visit or use the Service, we automatically collect certain technical data, including IP address, browser type and version, device type and operating system, referring URL, and approximate geographic location derived from IP address.

2.6 Cookies and Similar Technologies

We use cookies and similar technologies to operate the Service and to collect analytics data. We use strictly necessary cookies required for the Service to function, which do not require your consent, and analytics cookies used by PostHog to understand how the Service is used, which require your consent.

When you first visit the Service, you will be presented with a cookie consent banner. Analytics cookies are only placed after you provide your consent. You may withdraw your consent at any time through the cookie settings accessible on the Service.

3. How We Use Your Data

We process your personal data for the following purposes and on the following legal bases:

Performance of Contract (Article 6(1)(b) GDPR). We process your account data, voice recordings, transcripts, and assessment results to provide the Service to you, including conducting conversations, generating assessments, tracking your progress, and managing your subscription.

Legitimate Interest (Article 6(1)(f) GDPR). We process usage data and technical data to maintain and improve the Service, ensure security and prevent abuse, enforce fair use limits, and understand how the Service is used so we can improve it.

Consent (Article 6(1)(a) GDPR). We process analytics cookies only with your prior consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Legal Obligation (Article 6(1)(c) GDPR). We may process data as necessary to comply with applicable laws, including responding to lawful requests from public authorities.

We do not use your voice recordings, transcripts, or any personal data to train AI models.

4. Third-Party Processors

We share your data with the following third-party service providers, who process data on our behalf under data processing agreements:

  • ElevenLabs, Inc. — Voice audio, conversation context, user first name, language metrics. Purpose: Real-time voice conversation and AI processing. Location: United States.
  • Deepgram, Inc. — Voice audio recordings. Purpose: Post-call transcription. Location: United States.
  • Google (Gemini) — Voice audio recordings, transcripts. Purpose: Post-call pronunciation and grammar assessment. Location: United States / EU.
  • Convex, Inc. — Account data, transcripts, assessment results, usage data. Purpose: Database and backend infrastructure. Location: Ireland (EU).
  • Google Cloud Platform — Voice audio recordings. Purpose: Long-term audio storage. Location: Belgium (EU).
  • Vercel, Inc. — Technical data (IP, user agent). Purpose: Website hosting and delivery. Location: United States / Global CDN.
  • Stripe, Inc. — Payment and transaction data. Purpose: Payment processing. Location: United States.
  • PostHog, Inc. — Usage data, technical data. Purpose: Product analytics. Location: EU.

We require all processors to implement appropriate technical and organisational security measures and to process your data only in accordance with our instructions.

5. International Data Transfers

Your data is primarily stored within the European Union (Ireland and Belgium). However, some of our processors are located in the United States, including ElevenLabs, Deepgram, Stripe, and Vercel.

Where personal data is transferred outside the EU/UK to countries that do not benefit from an adequacy decision, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, together with supplementary measures where appropriate, to ensure an adequate level of data protection.

ElevenLabs retains voice data on its servers for up to 30 days for service delivery purposes, after which it is automatically deleted. We retrieve audio recordings from ElevenLabs after each conversation and store them on Google Cloud Platform in Belgium for long-term retention.

6. Data Retention

We retain your data for the following periods:

Account data is retained for as long as your account is active and for up to 30 days after account deletion to allow for account recovery.

Voice recordings are retained on ElevenLabs servers for up to 30 days (per ElevenLabs' retention policy) and on Google Cloud Platform in Belgium for up to 12 months from the date of recording.

Transcripts and assessment results are retained on Convex for as long as your account is active.

Payment data is retained for as long as required to manage your subscription and as required by applicable tax and accounting laws.

Usage and technical data is retained for up to 24 months.

Anonymised and aggregated data, from which you cannot be identified, may be retained indefinitely.

7. Account Deletion

You may request deletion of your account at any time by emailing privacy@fluentnow.ai or through your account settings.

Upon account deletion, we will delete or anonymise your personal data, including your account details, voice recordings stored on GCP, transcripts, and assessment results stored on Convex. Deletion will be completed within 30 days of your request.

Data that has already been anonymised or aggregated in a form that cannot be linked back to you may be retained indefinitely.

We will also instruct our third-party processors to delete your data in accordance with their respective retention policies and our data processing agreements.

Please note that certain data may be retained beyond the 30-day period where required by law (for example, transaction records for tax purposes).

8. Your Rights

Under applicable data protection law, you have the following rights:

Right of Access. You have the right to request a copy of the personal data we hold about you.

Right to Rectification. You have the right to request correction of inaccurate or incomplete personal data.

Right to Erasure. You have the right to request deletion of your personal data, subject to certain legal exceptions.

Right to Data Portability. You have the right to receive your personal data in a structured, commonly used, and machine-readable format (such as JSON or CSV) and to transmit it to another controller.

Right to Restriction of Processing. You have the right to request that we restrict the processing of your personal data in certain circumstances.

Right to Object. You have the right to object to processing based on legitimate interest. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.

Right to Withdraw Consent. Where processing is based on your consent (such as analytics cookies), you have the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, contact us at privacy@fluentnow.ai. We will respond to your request within 30 days. If your request is complex or we receive a high volume of requests, we may extend this period by an additional 60 days, in which case we will notify you.

If you are unsatisfied with our response, you have the right to lodge a complaint with a supervisory authority. For UK residents, this is the Information Commissioner's Office (ICO) at ico.org.uk. For EU residents, you may contact the supervisory authority in your country of residence.

9. Children's Privacy

The Service is not intended for children under 16 years of age. We do not knowingly collect personal data from anyone under 16. If we become aware that we have collected data from a user under 16, we will take steps to delete the account and all associated data promptly.

If you believe a child under 16 has used the Service, please contact us at privacy@fluentnow.ai.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS/SSL), access controls and authentication requirements, regular review of data processing practices, and contractual obligations on all third-party processors.

While we take reasonable steps to protect your data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. For material changes, we will provide at least 30 days' notice via the email address associated with your account. For minor or clarifying changes, we will post the updated policy on the Service with a revised "Last Updated" date.

Your continued use of the Service after the notice period constitutes acceptance of the updated Privacy Policy.

12. Contact

For all privacy inquiries, data requests, or complaints:

Email: privacy@fluentnow.ai

Crystalab LLP

71-75 Shelton Street

London

WC2H 9JQ

United Kingdom