Privacy Policy

1. Introduction

1.1 This Privacy Policy (this "Policy") describes how Bitaura Technologies, Surat, Gujarat, India("Voluble", "we", "us" or "our") collects, uses, discloses and otherwise processes Personal Data in connection with the Voluble mobile application, this website, and related features (collectively, the "Services"). Our registered address is set out in Section 17.

1.2 "Personal Data" means any information relating to an identified or identifiable natural person. Capitalised terms used but not defined in this Policy have the meanings given to them in our Terms of Service.

1.3 By accessing or using the Services, you acknowledge that you have read and understood this Policy. Enquiries may be directed to legal@bitauratechnologies.com.

2. Voice Data

2.1 The Services process speech in order to provide their core functionality. This Section 2 applies to every recording you make.

2.2 Audio is recorded on your device while the microphone control is held and is written to a temporary file on that device. The recording is transmitted to our servers and forwarded to OpenRouter, a third-party artificial intelligence provider, for transcription. The temporary file is deleted from your device upon completion of transmission.

2.3 We do not write audio to persistent storage or to our database. Audio is held in server memory solely for the duration of the request.

2.4 OpenRouter routes requests to underlying model providers. The identity of the provider handling any given request, the period for which that provider retains submitted audio, and whether such audio is used to train models, are governed by OpenRouter's terms and our account configuration, and not by this Policy. Accordingly, we do not warrant that submitted audio is discarded upon transcription.

2.5 The resulting transcript is used to continue the conversation and to generate feedback. Retention of transcripts is addressed in Section 7.

3. Personal Data We Collect

3.1 Personal Data you provide. We collect the following categories of Personal Data directly from you:

• Account information, comprising your email address and either a password (stored solely as an irreversible hash) or a third-party sign-in credential, together with a display name where you elect to provide one.
• Onboarding responses, comprising your native language, target language, proficiency level, daily goal and related responses concerning your learning objectives and circumstances, used to personalise the Services.
• User-created practice scenarios, which are transmitted to our artificial intelligence providers for conversion into a practice session.
• Speech and conversation content, as described in Section 2.
• Correspondence submitted to support or as feedback.

3.2 Personal Data generated by the Services. The Services generate the following categories of Personal Data:

• Progress data, comprising streaks, session history, fluency estimates and collected vocabulary.
• Conversation memory, comprising durable facts disclosed during a conversation, including without limitation your name, occupation or circumstances, recorded by an artificial intelligence model following that conversation in order to provide continuity across sessions. Such records are limited in length, stored on a per-scenario basis, constitute Personal Data, and may be deleted by you.
• Usage data, comprising daily session, practice and hint counters, together with your timezone, used to reset free-tier allowances at local midnight.

3.3 Personal Data collected automatically. The Services automatically collect:

• Analytics data, comprising screens opened and features used, collected through Firebase Analytics and associated with an internal account identifier rather than your email address or name.
• Crash diagnostics, collected through Firebase Crashlytics in the event of an application crash.
• A device identifier, used to apply free-tier usage limits and to detect repeated registrations originating from a single device.
• A push notification token, where notifications are enabled.
• Referral data, comprising your invite code, the referring user and your referral count, where you refer another user or register through a referral.

3.4 We do not collect contacts, location data, photographs, or any other information from your device beyond that specified in this Section 3.

4. Use Prior to Registration

4.1 The Services may be used prior to registration of an account. Where they are, a guest account is created on our servers at that time, to which no email address is associated. Onboarding responses, warm-up activity and early progress are stored in our database against that guest account.

4.2 Upon subsequent registration, your identity is associated with the same account record, and no Personal Data is copied or migrated. Guest accounts that remain unregistered and inactive are purged after 14 days.

5. Automated Processing

5.1 The Services operate by automated means, including artificial intelligence models. Speech is transcribed, replies are generated, user-created scenarios are converted into sessions, and scores and feedback are produced, in each case without human review.

5.2 Our personnel do not listen to or read session content in the ordinary course of operating the Services. You acknowledge that automated output may contain errors and is provided for practice purposes only, as further described in our Terms of Service.

6. Lawful Bases for Processing

6.1 Where the UK or EU General Data Protection Regulation, or India's Digital Personal Data Protection Act, 2023, applies to our processing, we rely on the following lawful bases: (a) performance of our contract with you, in respect of operating the Services, transcribing speech and storing progress; (b) our legitimate interests, in respect of maintaining service availability and preventing abuse; and (c) your consent, where obtained.

6.2 Where processing is founded on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

7. Data Retention

7.1 We retain Personal Data for no longer than is reasonably necessary for the purposes for which it was collected, subject to the following:

• Account and progress data is retained for the duration of the account.
• Voice audio is not written to our storage. Retention by our transcription providers is addressed in Section 2.4.
• Free-tier conversations are not stored on our servers and are retained on your device.
• Paid-plan conversations are stored in order to enable resumption. A paused conversation ceases to be resumable after seven (7) days. Conversation content remains in our database until the account is deleted or removal is requested.
• Conversation memory records are retained until deleted by you or until account deletion.
• Unregistered guest accounts are purged after 14 days of inactivity.
• Analytics and crash data is retained in accordance with the retention settings of the relevant provider.

7.2 Following deletion of an account, Personal Data is rendered inaccessible immediately and permanently erased thereafter, as described in Section 13.

8. Disclosure of Personal Data

8.1 We do not sell Personal Data and do not disclose Personal Data for advertising purposes.

8.2 We disclose Personal Data to service providers engaged to operate the Services, in the following categories:

• Artificial intelligence providers, for speech transcription and the generation of replies, feedback and hints.
• Cloud hosting and database providers, for storage of the Personal Data described in this Policy.
• Analytics and crash-reporting providers, for usage analytics, diagnostics and push notifications.
• Authentication providers, where third-party sign-in is used.
• Payment and subscription processors, for payment processing and confirmation of subscription status. Payment card details are not received by us.

8.3 We may further disclose Personal Data where required by applicable law, where necessary to protect the rights and safety of our users, or to a successor entity in connection with a merger, acquisition or sale of assets, in which case notice will be provided.

8.4 A current list of the providers referred to in Section 8.2 is available on request at legal@bitauratechnologies.com.

9. International Transfers

9.1 We are established in India. Our servers and database are hosted in [CONFIRM: hosting region]. The providers referred to in Section 8.2 operate globally, and Personal Data, including without limitation voice recordings, may accordingly be processed in jurisdictions whose data protection laws differ from those of your own, including the United States.

9.2 Where Personal Data is transferred outside India, we implement the safeguards required by applicable law.

10. Advertising

10.1 The Services do not currently display advertising. No advertising identifier is collected and no advertising network receives Personal Data.

10.2 We may introduce advertising in the free tier. In that event, advertising partners may collect device identifiers and usage information in order to serve and measure advertisements, this Policy will be updated, notice will be provided in advance, and consent will be obtained where required by applicable law. Advertising will not be displayed to paid subscribers.

11. The Website

11.1 This website sets no cookies, operates no analytics, and carries no third-party trackers.

11.2 Where you submit an email address to the waitlist form, that address is stored in order to notify you of availability, and your IP address is transmitted to our server for the purpose of rate-limiting submissions and preventing abuse of that form. Removal may be requested at legal@bitauratechnologies.com; deletion of your account also effects removal.

12. Your Rights

12.1 Subject to your jurisdiction, and including without limitation under India's Digital Personal Data Protection Act, 2023, you may request access to a copy of your Personal Data; its correction or completion; its erasure; restriction of, or objection to, its processing; and withdrawal of consent previously given.

12.2 You may nominate a person to exercise the rights set out in Section 12.1 on your behalf in the event of death or incapacity, and you may lodge a complaint with your supervisory authority.

12.3 To exercise these rights, contact legal@bitauratechnologies.com. We will respond within thirty (30) days. Certain of this Personal Data may also be managed or deleted directly within the application under Settings.

13. Account Deletion

13.1 You may delete your account at any time, with immediate effect, using Settings → Delete account within the application, or at voluble.io/delete-account, which does not require installation of the application.

13.2 Upon confirmation, the account ceases to function: you are signed out on all devices, sign-in is refused, notifications cease, and any waitlist entry is removed.

13.3 Your learning profile, progress, vocabulary, session history, stored conversations and the messages contained in them, and the conversation memory records described in Section 3.2, are thereafter retained in an inaccessible state for 30 days and permanently erased at the expiry of that period. Restoration may be requested by email within that period and is not possible thereafter.

13.4 Where third-party sign-in is used, no password is available for the web form. Please use the in-application control, or contact legal@bitauratechnologies.com from your account address.

13.5 Notwithstanding the foregoing, records may persist briefly in encrypted backups, and we retain the minimum necessary to comply with legal obligations, including without limitation purchase records. Anonymised analytics that can no longer be associated with you are not deleted.

14. Children's Privacy

14.1 The Services are intended for persons aged 13 years or older. We do not request date of birth and do not knowingly collect Personal Data from children under 13. If you believe that a child has provided us with Personal Data, please contact us and it will be deleted.

14.2 Users between 13 and 18 years of age must use the Services with the involvement of a parent or guardian, and only where permitted by the law of their country.

15. Security

15.1 Passwords are hashed and are not stored in readable form. Traffic between the application and our servers is encrypted in transit. Access to production data is restricted.

15.2 No system of storage or transmission can be guaranteed to be entirely secure. In the event of an incident affecting you, we will provide notice promptly and as required by applicable law.

16. Changes to This Policy

16.1 We may amend this Policy from time to time. Where an amendment is material, including without limitation any change to the handling of voice data, the date set out above will be updated and notice will be provided in the application or by email before the amendment takes effect. Continued use of the Services thereafter constitutes acceptance of the amended Policy.

17. Contact and Grievances

Questions, requests and complaints regarding privacy may be addressed to our grievance point of contact:

Bitaura Technologies — Grievance Officer
1005, White Orchid, Subhash Chandra Bose Marg, Guru Ram Pavan Bhumi, Adajan Gam, Adajan, Surat, Gujarat 395009, India
legal@bitauratechnologies.com

We will acknowledge and respond within the timelines prescribed by applicable law.