This Privacy Policy explains how LingoCall AI — an AI-powered language-learning app — collects, uses, shares, and protects your information when you use the app and related services.

LingoCall AI is provided by STOCKIMG AI YAZILIM TEKNOLOJİLERİ A.Ş. (“STOCKIMG AI”, “we”, “us”), a company registered in Türkiye. For any privacy question or request, contact support@stockimg.ai.

1. Information we collect

We collect only what we need to run the Service. We do not sell your personal data and do not use it for third-party advertising.

• Onboarding & profile — the language you are learning, your native language, your self-selected level (CEFR A1–C2), your goal or motivation, an optional display name, and your daily practice goal.
• Conversation inputs — the topics you choose, any custom topic text you type, and the text and speech you contribute during a conversation.
• Sign-in details (optional) — if you sign in with Apple or Google, we receive your email, a stable provider user identifier, your name (where provided), and a profile photo URL (Google only; Apple does not provide one). Signing in is optional. We do not store your Apple/Google passwords or OAuth tokens.
• Device & usage data — a securely stored device ID for your anonymous account, internal user/session identifiers (refresh tokens are stored only as a hash), AI-usage metadata (model, token counts, estimated cost, timestamps) for rate-limiting and cost control, and standard server logs (such as IP address) processed transiently for security and reliability.
• Analytics data — we use Google Firebase Analytics to understand how the app is used (for example, which screens you view and basic session and device information, tied to an app-generated analytics identifier). We have disabled the advertising identifier (IDFA), so this is not used to serve ads or to track you across other apps or websites.
• Subscription data — if you subscribe, RevenueCat and the app store provide your subscription status, product, store, and purchase/expiry dates. Your payment is processed by Apple or Google — we never receive your full card or banking details. If you arrived from an Apple Search Ads campaign, Apple’s on-device AdServices provides RevenueCat with first-party attribution (which campaign led to your purchase) so we can measure our advertising; this does not use a cross-app tracking identifier.
• Device permissions — microphone (required for spoken conversations, captured only during an active session) and motion sensors (optional, used only for the on-screen parallax effect; processed on-device and not stored).

2. Voice, conversations & AI

During a voice session, your microphone audio is streamed in real time to our AI provider, OpenAI, over an encrypted connection set up with a short-lived token, so the tutor can understand and respond and your speech can be transcribed.

Text transcripts of what you said and the tutor’s replies are stored on our servers so you can review your history and continue conversations. We also generate and store translations, hints, corrections, end-of-session reports (new vocabulary, recurring mistakes, a short evaluation), and a running list of words you have encountered.

OpenAI processes this content as our service provider. Per OpenAI’s API terms, your inputs and outputs are not used to train their models. Please avoid sharing sensitive personal information (financial, health, or government-ID details) in conversations, since they are transcribed and stored.

3. How we use your information

• Provide, personalize, and maintain the Service, including running conversations tailored to your language, level, and goals, and saving your history.
• Create and secure your account, authenticate you, and prevent fraud and abuse.
• Process and manage your subscription and apply usage limits.
• Respond to support requests and operate the invite feature.
• Monitor, debug, and improve the reliability, safety, and performance of the Service.
• Comply with legal obligations and enforce our Terms of Use.

4. Legal bases (EEA/UK & Türkiye)

Where the GDPR or Türkiye’s Law No. 6698 on the Protection of Personal Data (KVKK) applies, we rely on: performance of a contract (to deliver the Service); consent (microphone access and optional sign-in, which you can withdraw at any time); legitimate interests (to secure the Service, prevent abuse, control costs, and improve our product); and legal obligation (to comply with applicable law).

5. How we share information

We share personal data only with service providers who help us run the Service, and only as needed. We do not sell personal data.

• OpenAI — AI tutor responses, speech transcription, and translations.
• RevenueCat — subscription management and Apple Search Ads attribution.
• Google (Firebase Analytics) — in-app usage analytics.
• Apple & Google — sign-in and in-app purchase / payment processing.
• Cloudflare — content delivery and security.
• Cloud hosting provider — hosting our servers and database.

We may also disclose information to comply with law or valid legal process, to protect the rights and safety of our users or STOCKIMG AI, and in connection with a merger or acquisition (with notice of any change in control).

6. International data transfers

We are based in Türkiye, and some providers (such as OpenAI, RevenueCat, Cloudflare, Apple, and Google) process data in the United States and other countries. For cross-border transfers we rely on appropriate safeguards such as the EU Standard Contractual Clauses and equivalent mechanisms required under KVKK.

7. Data retention

• We keep your account, profile, conversations, and learning data for as long as your account is active.
• You can delete individual conversations at any time within the app.
• You can ask us to delete your account and personal data by emailing support@stockimg.ai; we will action this within the time required by applicable law.
• We retain limited records (such as transaction and log data) where necessary for legal, accounting, security, or dispute-resolution purposes.

8. Security

We use technical and organizational measures including encryption in transit (HTTPS/TLS), short-lived session tokens, hashed credentials, and access controls. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we work to protect your information and to notify you and the relevant authorities of incidents where required by law.

9. Your privacy rights

Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal data; to restrict or object to certain processing; and to withdraw consent. Under KVKK you also have the rights set out in Article 11. Under the CCPA/CPRA you have the right to know, delete, and correct your personal information and to not be discriminated against — and we confirm we do not sell or “share” personal information for cross-context behavioral advertising.

To exercise any right, email support@stockimg.ai. We may need to verify your identity before responding. You may also lodge a complaint with your local data-protection authority (in Türkiye, the Personal Data Protection Authority — KVKK Kurumu).

10. Children’s privacy

The Service is not directed to children. You must be at least 13 years old (or the minimum age of digital consent in your country) to use the app. Some characters are intended for adults (18+) and may use mature language. We do not knowingly collect personal data from children under 13; if you believe a child has provided us data, contact us and we will delete it.

11. Analytics & tracking

We use Google Firebase Analytics to understand how the app is used (such as which screens are viewed and basic session and device information) so we can improve it. We have disabled the advertising identifier (IDFA), and we do not include third-party advertising SDKs, serve ads, or track you across other apps or websites.

We also use Apple Search Ads attribution through RevenueCat to measure which campaigns lead to subscriptions. This relies on Apple’s first-party, on-device AdServices and does not track you across other apps or websites.

12. Changes & contact

We may update this Privacy Policy. When we make material changes we will update the date above and, where appropriate, notify you in the app. Your continued use of the Service after an update means you accept the revised policy.

STOCKIMG AI YAZILIM TEKNOLOJİLERİ A.Ş. · support@stockimg.ai