Privacy Policy

1. Introduction

Welcome to Floo ("we," "our," or "us"). We are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our English practice mobile application (the "App").

By using Floo, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our App.

2. Information We Collect

2.1 Personal Information

When you create an account, we collect:

• Email address: Used for account authentication and communication
• Name: To personalize your experience
• Profile avatar/photo: Optional, for profile display
• Language proficiency level: To match you with appropriate conversation partners

2.2 Voice Recording Data

When you participate in conversation rooms, we collect voice recordings for analysis purposes:

• Voice recordings: Audio recordings of your conversations (typically 20-30 minutes)
• Recording notification: You will be clearly notified through the app interface when recording is active
• User control: You can pause, skip, or stop voice recording at any time
• Deletion rights: You have full control to delete or export your recordings anytime
• AI analysis: Voice recordings are processed to generate performance reports and feedback

2.3 Usage and Performance Data

• Conversation session duration and frequency
• AI-generated performance reports and analytics
• Progress tracking and skill assessment data
• Room participation history
• Practice session timestamps

2.4 Technical Information

• Device information (model, operating system version)
• IP address and general location (country/region level)
• App usage statistics and crash reports
• Network connection type

2.5 Advertising & Device Identifier Data

To support our advertising and marketing efforts, we collect the following through the Meta (Facebook) Ads SDK:

• Advertising ID / IDFA:Your device's Identifier for Advertisers (IDFA on iOS, GAID on Android), collected for ad attribution and campaign optimization
• Ad interaction data: Information about ads you have seen or interacted with, used to measure the effectiveness of our advertising campaigns
• Purpose: Used for third-party advertising (Meta) and our own advertising and marketing purposes
• Not linked to identity: This data is not linked to your name, email address, or other personal account information
• Shared with: Meta Platforms, Inc. (Facebook) as a third-party advertising partner
• Tracking:This constitutes "tracking" as defined by Apple's App Tracking Transparency (ATT) framework. On iOS, you will be prompted via an ATT dialog before any tracking data is collected. You may opt out at any time in your device settings.

We also use Google Analytics for Firebase to collect anonymized usage statistics that help us understand how users interact with the app and improve our services.

2.6 AI Conversation Data

When you use the AI Conversationfeature, you engage in a live voice conversation with an AI model powered by Google's Gemini Live API. During these sessions:

• Real-time audio streaming:Your voice is streamed in real-time to Google's Gemini Live API to generate AI responses
• No server-side storage by us:AI conversation audio is not stored on our servers — it is processed directly by Google's API in real time
• Google's data handling:Audio and conversation data sent to Gemini Live API is subject to Google's Privacy Policy and data handling practices
• Microphone permission: This feature requires microphone access, which you can revoke at any time through your device settings
• Session metadata: General session data (duration, frequency) may be recorded for progress tracking purposes

3. How We Use Your Information

We use the collected information for the following purposes:

• Service delivery: To provide and maintain our English practice platform
• AI feedback generation: To analyze your speaking patterns and generate personalized improvement reports
• Account management: To manage your account and provide customer support
• Matching: To connect you with appropriate conversation partners
• Progress tracking: To monitor and display your learning progress
• App improvement: To analyze usage patterns and improve our services
• Communication: To send you important updates, notifications, and support messages
• Security: To detect, prevent, and address technical issues and fraudulent activity
• Advertising & marketing: To measure the performance of our ad campaigns, attribute app installs and events to ad interactions (via Meta Ads SDK), and improve the targeting and efficiency of our promotional efforts

4. Data Storage and Security

4.1 Database Provider

We use Supabase, a secure and reliable cloud database service, to store your personal information and app data. Supabase maintains industry-standard security measures to protect your data.

4.2 Security Measures

• Data encryption in transit (TLS/SSL)
• Data encryption at rest
• Secure authentication protocols
• Regular security audits and updates
• Access controls and monitoring
• Secure API endpoints

4.3 Data Retention

• Voice recordings: Stored until you choose to delete them or delete your account
• Account data: Retained for as long as your account is active
• Performance reports: Retained for your learning history unless you delete them
• Deleted data: Permanently removed from our systems within 30 days of deletion request

5. Your Rights and Controls

You have full control over your personal data:

5.1 Access and Management

• Access: View all your personal data stored in the app
• Edit: Update your profile information, name, email, and avatar
• Export: Download your voice recordings and performance reports
• Delete: Remove individual recordings or your entire account

5.2 Recording Controls

• Pause or stop voice recording at any time during a session
• Skip recording entirely for any conversation
• Delete recordings immediately after creation
• Choose which recordings to keep or remove

5.3 Additional Rights

Depending on your location, you may have additional rights including:

• Right to data portability
• Right to object to data processing
• Right to restrict processing
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

6. Data Sharing and Disclosure

6.1 We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

6.2 Service Providers

We may share your information with trusted service providers who assist us in:

• Supabase: Cloud hosting and database management
• AI processing and analysis services
• Google Gemini Live API: AI Conversation — real-time voice processing
• Meta Platforms, Inc. (Facebook):Advertising attribution and campaign optimization via the Meta Ads SDK. Device advertising IDs may be shared with Meta for these purposes. Meta's use of this data is governed by the Meta Privacy Policy.
• Google Analytics for Firebase: Anonymized app usage analytics and performance monitoring
• Customer support and communication
• Payment processing (if applicable)

These service providers are contractually obligated to protect your data and use it only for the purposes we specify.

6.3 Public Room Participants

When you join public conversation rooms, other participants can see:

• Your name and avatar
• Your presence in the room
• Your voice during live conversations

Note: Your voice recordings and AI reports are private and not shared with other users.

6.4 Legal Requirements

We may disclose your information if required to:

• Comply with legal obligations or court orders
• Protect our rights, privacy, safety, or property
• Protect the safety of our users or the public
• Prevent fraud or illegal activities

7. Children's Privacy

Our App is intended for users aged 13 and above. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will delete such information from our systems.

For users between 13 and 18, we recommend parental guidance when using the App.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. We ensure appropriate safeguards are in place to protect your personal information in accordance with this Privacy Policy.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate and improve the app:

• Essential cookies: Required for app functionality and authentication
• Analytics (Google Analytics for Firebase): Help us understand how users interact with the app using anonymized and aggregated data
• Advertising (Meta Ads SDK):Collects your device's advertising identifier (IDFA/GAID) to measure ad campaign performance and attribute app installs. On iOS, this is subject to your App Tracking Transparency consent. On Android, you can opt out via Settings > Privacy > Ads.
• Preference storage: Remember your settings and preferences locally on your device

You can manage tracking permissions through your device settings. On iOS, go to Settings > Privacy & Security > Tracking to control tracking consent. Disabling certain functionality may limit app features.

10. Third-Party Links and Services

Our App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new Privacy Policy in the App
• Sending you an email notification
• Displaying an in-app notification

Your continued use of the App after changes are posted constitutes your acceptance of the updated Privacy Policy.

12. Data Breach Notification

In the unlikely event of a data breach that affects your personal information, we will notify you within 72 hours via email and in-app notification. We will also inform relevant authorities as required by law.

13. Your California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information
• Right to delete personal information
• Right to non-discrimination for exercising your rights

14. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR):

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Rights related to automated decision-making

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

16. Consent

By using Floo, you consent to our Privacy Policy and agree to its terms. You acknowledge that you have read and understood how we collect, use, and protect your personal information.