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") on iOS devices.

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.

Developer Information: This app is developed by Syed Umair Andrabi, located in Srinagar, India. For any privacy-related questions, please contact umair@ryzeapps.com.

2. Information We Collect

2.1 Personal Information

When you create an account, we collect:

• Email address or Apple ID: Used for account authentication when you sign in with Apple or email
• Name: To personalize your experience and display in the app
• Profile avatar/photo: Optional, for profile display in conversation rooms
• Language proficiency level: To match you with appropriate conversation partners

Sign in with Apple: When you use Sign in with Apple, we receive only the information you choose to share, which may include your name and a verified email address (which may be a private relay email address).

2.2 Voice Recording Data (Optional)

Important: Voice recording is entirely optional. You have full control to enable or disable this feature in your app settings.

When you choose to enable voice recording and participate in conversation rooms or 1-on-1 calls, we collect:

• Voice recordings: Audio recordings of your conversations during practice sessions
• 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 during a session
• Server transmission: When recording is enabled, audio is sent to our server for AI analysis
• Deletion rights: You have full control to delete or export your recordings anytime
• AI analysis: Voice recordings are processed by AI to generate detailed performance reports and feedback on pronunciation, fluency, grammar, and vocabulary
• Disable anytime:If you disable recording, no audio will be sent to our servers, and you won't receive AI feedback reports (other features remain available)

2.3 Usage and Performance Data

• Conversation session duration and frequency
• AI-generated performance reports and analytics (only if recording is enabled)
• Progress tracking and skill assessment data
• Room participation history
• Practice session timestamps
• Learning statistics and improvement metrics

2.4 Technical Information

• Device information (iPhone/iPad model, iOS version, app version)
• IP address and general location (country/region level)
• App usage statistics and crash reports
• Network connection type
• Device identifiers for analytics purposes

2.5 Advertising & Device Identifier Data

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

• IDFA (Identifier for Advertisers):Your device's advertising identifier, collected for ad attribution and campaign optimization after you grant consent via the ATT prompt
• 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, subject to the Meta Privacy Policy

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 Data We Do NOT Collect

• We do not collect face data or biometric identifiers (Face ID/Touch ID data stays on your device)
• We do not track your precise location (only country/region for matching purposes)
• We do not access your contacts or photo library

2.7 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 iOS 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, including real-time conversation rooms and 1-on-1 calls
• AI feedback generation: To analyze your speaking patterns and generate personalized improvement reports (only when recording is enabled)
• Account management: To manage your account, authenticate your identity, and provide customer support
• Matching: To connect you with appropriate conversation partners based on language level and preferences
• Progress tracking: To monitor and display your learning progress, statistics, and achievements
• App improvement: To analyze usage patterns and improve our services, features, and user experience
• Communication: To send you important updates, notifications, and support messages
• Security: To detect, prevent, and address technical issues, fraudulent activity, and policy violations
• Social features: To enable you to make friends and connect with other English learners
• Advertising & marketing: To measure the performance of our ad campaigns and attribute app installs to ad interactions via Meta Ads SDK (only if you grant ATT consent)

4. Data Storage and Security

4.1 Database and Hosting 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 including encryption, access controls, and regular security audits to protect your data.

4.2 Security Measures

• Data encryption in transit: All data transmitted between your device and our servers uses TLS/SSL encryption
• Data encryption at rest: Your data is encrypted when stored on our servers
• Secure authentication: Industry-standard authentication protocols, including Sign in with Apple
• Regular security audits and updates
• Access controls and monitoring to prevent unauthorized access
• Secure API endpoints with authentication tokens

4.3 Data Retention

• Voice recordings: Stored on our servers 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
• Backup data: Removed from backup systems within 90 days

4.4 Data Location

Your data is stored on secure cloud servers. By using our app, you consent to the transfer and storage of your data in accordance with this Privacy Policy.

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 through your profile settings
• Edit: Update your profile information, name, email, and avatar at any time
• Export: Download your voice recordings and performance reports in a standard format
• Delete: Remove individual recordings, your entire learning history, or your complete account

5.2 Recording Controls

• Enable/Disable: Turn voice recording on or off completely in app settings
• 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
• Bulk delete all recordings with one action

5.3 iOS-Specific Privacy Controls

• Microphone access:You can manage microphone permissions in iOS Settings > Floo > Microphone
• Notifications:Manage notification preferences in iOS Settings > Notifications > Floo
• Sign in with Apple:Manage your Sign in with Apple settings in iOS Settings > Apple ID > Password & Security

5.4 Additional Rights

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

• Right to data portability (export your data)
• Right to object to data processing
• Right to restrict processing
• Right to withdraw consent at any time
• 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. This is our firm commitment to you.

6.2 Service Providers

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

• Supabase: Cloud hosting and database management
• AI Processing: Third-party AI services for voice analysis and feedback generation (only when recording is enabled)
• Google Gemini Live API: Real-time voice processing for the AI Conversation feature
• Meta Platforms, Inc. (Facebook):Advertising attribution and campaign optimization via the Meta Ads SDK. Your device's IDFA (if ATT consent is granted) 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 tools
• Apple: Payment processing through In-App Purchases

These service providers are contractually obligated to protect your data and use it only for the purposes we specify. They are not permitted to use your data for their own purposes.

6.3 Public Room Participants

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

• Your name and avatar
• Your presence and status in the room
• Your voice during live conversations
• Your language proficiency level (if you choose to display it)

Privacy Protection: Your voice recordings, AI reports, email address, and detailed statistics are private and not shared with other users.

6.4 Legal Requirements

We may disclose your information if required to:

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

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 years of age.

If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us at umair@ryzeapps.com, and we will promptly delete such information from our systems.

For users between 13 and 18, we recommend parental guidance when using the App, particularly when using voice recording and social features.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including countries that may have different data protection laws than your country.

We ensure appropriate safeguards are in place to protect your personal information in accordance with this Privacy Policy, including encryption, secure data transfer protocols, and contractual obligations with service providers.

9. Apple-Specific Privacy Features

9.1 Sign in with Apple

When you use Sign in with Apple, you benefit from:

• Private email relay: Option to use a private relay email address
• Minimal data sharing: Only name and verified email are shared
• Two-factor authentication:Enhanced security through Apple's authentication

9.2 App Tracking Transparency (ATT)

We comply fully with Apple's App Tracking Transparency framework. Our app uses the Meta (Facebook) Ads SDK for advertising attribution, which may use Apple's IDFA (Identifier for Advertisers) to measure the effectiveness of our ad campaigns.

• ATT prompt:Before any tracking data is collected, you will be shown Apple's ATT authorization dialog asking for your permission
• Consent required: Your IDFA is only accessed and shared with Meta if you grant permission through the ATT prompt. If you deny permission, no advertising tracking data is collected.
• Purpose of tracking: Ad attribution (linking ad interactions to app installs and in-app events) and campaign optimization for our own marketing
• Third party: IDFA data (when consented) is shared with Meta Platforms, Inc. — this constitutes cross-app tracking as defined by Apple
• Opt out anytime: You can change your tracking consent at any time in iOS Settings > Privacy & Security > Tracking > Floo
• We do not share your data with data brokers

9.3 In-App Purchases

All payments are processed through Apple's In-App Purchase system. We do not have access to your payment information (such as credit card details). Apple handles all payment data according to their Privacy Policy.

10. Tracking Technologies

We use the following tracking technologies in the app:

• Essential session tokens: Required for app functionality, authentication, and security
• Google Analytics for Firebase: Collects anonymized and aggregated usage statistics to help us understand how users interact with the app
• Meta Ads SDK (advertising tracking): Collects your IDFA for ad attribution and campaign optimization. This is only active if you have granted consent via the ATT prompt. You can change this at any time in iOS Settings > Privacy & Security > Tracking.
• Preference storage: Remember your settings and preferences locally on your device

To manage tracking permissions, go to iOS Settings > Privacy & Security > Tracking and toggle Floo on or off. Revoking tracking consent will stop IDFA collection but will not affect core app features.

11. Third-Party Links and Services

Our App may contain links to third-party websites or services (such as support documentation or social media). 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 to third-party services.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will notify you of any material changes by:

• Posting the new Privacy Policy in the App with an updated "Last Updated" date
• Sending you an email notification (if you have provided an email address)
• Displaying a prominent in-app notification

Your continued use of the App after changes are posted constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should stop using the App and delete your account.

13. 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
• Inform you about what data was compromised
• Explain what steps we are taking to address the breach
• Provide recommendations on how you can protect yourself
• Inform relevant authorities as required by applicable laws

14. 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, used, disclosed, and sold
• Right to delete: Request deletion of your personal information
• Right to opt-out: We do not sell personal information, so no opt-out is necessary
• Right to non-discrimination: Equal service and pricing regardless of privacy rights exercised

To exercise these rights, contact us at umair@ryzeapps.com. We will respond within 45 days.

15. European Privacy Rights (GDPR)

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

• Right of access: Access your personal data
• Right to rectification: Correct inaccurate data
• Right to erasure:Request deletion ("right to be forgotten")
• Right to restrict processing: Limit how we use your data
• Right to data portability: Receive your data in a portable format
• Right to object: Object to certain types of processing
• Rights related to automated decision-making: Request human review of automated decisions

Legal basis for processing: We process your data based on:

• Consent: For voice recordings, AI analysis, and advertising tracking (ATT consent on iOS)
• Contract: To provide the service you requested
• Legitimate interests: To improve our services, prevent fraud, and measure advertising effectiveness

16. Contact Us

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

17. 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.

For voice recording: Separate consent is obtained when you first enable the recording feature, and you can withdraw this consent at any time by disabling recording in your settings.