1. Information We Collect
We collect the following types of information from and about users of the Services:
- Contact details — your email address (and name, if you choose to provide it) when you create an account or contact us, plus your log-in credentials.
- Authentication data from third-party platforms — if we later let you sign in with Google, Apple, or a similar provider, we may receive your name, email address, profile photograph, and a unique authentication identifier.
- Language preferences — the language(s) you are interested in learning and your stated proficiency level.
- Voice recordings and speech data — when you practice with our AI tutor, we collect audio recordings, transcripts, and related data. This is sensitive personal information processed only to deliver and improve the Services. On mobile, recording is only possible after you grant the App microphone permission, which you can revoke at any time in your device settings.
- Usage data — clickstream data, records of actions in the Services, session length, feature use, ratings or feedback you give on AI responses, and performance data such as crash reports.
- Device and technical data — device model, operating system, browser type, language settings, IP address (from which we may derive approximate location), and similar identifiers.
- Mobile identifiers — when you use the Mobile App, we may process mobile advertising identifiers and device identifiers such as Apple’s Identifier for Advertisers (IDFA), Apple’s Identifier for Vendor (IDFV), and Google’s Advertising ID (GAID), where available and permitted by your device settings and applicable law.
- Push-notification tokens — if you opt in to push notifications in the Mobile App, we store the token issued by Apple Push Notification service or Firebase Cloud Messaging so we can deliver notifications you have asked for.
- Purchase data — if you buy a subscription or other paid feature, our payment providers (such as the Apple App Store, Google Play Store, or Stripe) share limited transaction data with us, such as purchase status and order identifiers. We do not receive your full payment card details.
- Communications — records of messages you send us, including support requests and product feedback.
We collect this information when you visit the Website, download the Mobile App, create an account, contact us, or use the Services. We may also receive aggregated traffic and usage insights from analytics providers.
2. How We Use Your Information
We use the information we collect for the following purposes:
To provide the Services and fulfill your requests
To operate and maintain the Services, authenticate users, respond to inquiries, send administrative messages such as changes to our terms, and diagnose service and quality issues. The legal basis is performance of a contract or our legitimate interest in responding to you.
To improve the Services and develop new features
Including to evaluate, maintain, test, and improve the quality, accuracy, safety, and personalization of the Services. This may use text prompts, chat messages, voice and audio recordings, corrections, feedback, and related usage logs and metadata. The legal basis is our legitimate interest and, where required, your consent.
To personalize your experience
To understand your interests and preferences and tailor the Services to your level and goals. Legal basis: legitimate interest, and, in the EU, your consent where required.
For internal business purposes
Such as evaluating usage, analyzing trends, and generating de-identified or aggregated data that we may use for any purpose. Legal basis: legitimate interest.
For legal, safety, and security reasons
To comply with legal obligations, protect the rights, property, and safety of Kalbo, our users, and others, and prevent and detect fraud or misuse.
For marketing
To send you product updates, learning tips, and other marketing-related emails consistent with your choices. In the EU, we rely on your consent for marketing email. You can opt out at any time using the unsubscribe link in our emails.
Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
3. With Whom We Share Information
We may share your information with:
- Service providers acting on our behalf — including hosting, database, analytics, customer-support, email delivery, AI model providers, and speech-processing providers. They process data only as needed to provide their services to us.
- Government authorities, law enforcement, or other third parties — to comply with legal obligations, enforce our terms, or protect the rights, property, or safety of Kalbo, our users, or others.
- A third party in connection with a corporate transaction — such as a merger, acquisition, financing, or sale of assets, including in bankruptcy or similar proceedings.
- Analytics and product-measurement providers — to understand how the Services are used and to improve them. Where required, this is subject to your consent.
We use Google’s AI services to provide certain speech and conversational features. Google processes relevant data solely as our service provider to deliver these features on our behalf.
We do not sell your personal information.
4. Your Choices & Rights
You have a number of choices regarding our processing of your information:
- Marketing email — click the “unsubscribe” link in any marketing email. This will not affect administrative or transactional messages.
- Cookies — manage your preferences via the consent banner or your browser settings (see Section 6).
- Your account and data — you can delete your account and its associated data at any time from within the Mobile App, via our account deletion page, or by contacting us.
Depending on where you live, you may have additional rights under data-protection law, including the right to:
- access, correct, or delete your personal information;
- receive a copy of your personal information in a portable format;
- restrict, object to, or opt out of certain processing, including by withdrawing previously given consent; and
- lodge a complaint with your local data-protection or consumer-privacy authority.
To exercise these rights, contact us at hello@kalbo.ai. These rights are not absolute and may be balanced against other considerations, including the privacy rights of other people.
5. Voice Recordings & AI Services
Because Kalbo is a voice-first tutor, we process your speech — audio recordings, transcripts, and related metadata — when you practice with the AI. These are handled by our third-party AI service providers acting on our behalf (see Section 3) to recognize what you said and generate the tutor’s response. Your voice recordings, transcripts, and related metadata may also be used to provide, evaluate, troubleshoot, and improve the Services.
Where required by applicable law, we apply appropriate safeguards, such as removing direct identifiers, aggregation, or pseudonymization. We do not sell your voice recordings, and we do not use them for advertising.
6. Cookies & Tracking Technologies
The Website uses cookies and similar technologies (such as web beacons and pixels) to remember preferences, measure performance, analyze usage, and — with your consent — support marketing measurement. Some cookies last only for a single session; others persist across sessions.
You can accept or reject non-essential cookies via our consent banner and adjust your browser settings at any time. We do not currently respond to browser “do not track” signals.
7. Analytics
We use third-party analytics tools (such as Google Analytics) to understand how the Services are used and how to improve them. These tools may use cookies and similar technologies to collect information about your interactions, including pages visited, session duration, and referring source.
You can learn more about Google Analytics at policies.google.com/privacy/partners and opt out using the Google Analytics opt-out browser add-on at tools.google.com/dlpage/gaoptout.
8. Mobile App, Permissions & Advertising Identifiers
The Mobile App requests certain device permissions to function. These include microphone access (required for voice practice), and optionally notifications, speech recognition, and local storage. You can grant or revoke any of these permissions at any time in your device settings. Some features will not work without the required permissions.
If you use the Mobile App on an iOS device (iOS 14.5 and later), we ask for your permission before accessing your Identifier for Advertisers (IDFA) for cross-app tracking. If you deny the permission, we will not access your IDFA for cross-app tracking and may instead rely on privacy-preserving measurement tools such as Apple’s SKAdNetwork. You can change your choice at any time under Settings › Privacy & Security › Tracking on your iOS device.
On Android, our advertising and attribution partners may use your Google Advertising ID (GAID) to measure campaign performance and to serve interest-based advertising. You can opt out of interest-based advertising, reset your GAID, or delete it through your Android device settings.
We may also share a pseudonymous account identifier with our attribution partners to help attribute app installs and in-app events, measure campaign performance, prevent fraud, and maintain accurate analytics. We do not share your email address with these partners for this purpose.
9. Retention
We retain personal information for as long as needed to fulfill the purposes for which it was collected and to comply with applicable law. Relevant factors include:
- the length of our ongoing relationship with you (for example, while you have an active account);
- any legal obligation that requires us to retain certain records; and
- whether retention is necessary in light of our legal position (for example, statutes of limitations, litigation, or regulatory investigations).
Anonymous demo conversations (transcripts from the try-before-you-sign-up session, which are not linked to an account) are retained for up to 60 days to improve the tutoring experience, then deleted.
10. Children
The Services are not directed to children under the age of 16 and we do not knowingly collect personal information from anyone under 16. If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.
11. Third-Party Services
This Privacy Policy does not address the privacy or other practices of any third party, including any website or service to which the Services link. The presence of a link does not imply our endorsement, and we are not responsible for the practices of organizations such as Google, Apple, Microsoft, or other platform or service providers.
12. Security
We use reasonable organizational and technical measures to protect personal information, including encryption in transit, access controls, and a hosting environment with row-level security. No system can be guaranteed 100% secure. If you believe your account or your interaction with us is no longer secure, please contact us immediately.
13. International Data Transfers
Your personal information may be stored and processed in any country where we or our service providers operate. By using the Services you understand that your information may be transferred to countries other than your country of residence, which may have data-protection rules that differ from those in your country.
For transfers from the European Economic Area, the United Kingdom, or Switzerland to countries that have not been recognized as providing an adequate level of data protection, we put in place appropriate safeguards, such as the European Commission’s Standard Contractual Clauses. You can request a copy by contacting us.
14. Additional Information for EU, UK & Swiss Residents
If you are located in the European Economic Area, the United Kingdom, or Switzerland, Curly Media, MB (Republic of Lithuania) is the data controller for the personal information described in this Privacy Policy. You have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or place of an alleged infringement. A list of EU authorities is available on the European Data Protection Board website. In the United Kingdom, you can contact the Information Commissioner’s Office at ico.org.uk.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will update the “Last updated” date above and, where required by law, provide additional notice. Please check this page periodically to stay informed about how we collect, use, and protect your information.
16. Contact Us
Kalbo is operated by Curly Media, MB, a company registered in the Republic of Lithuania, which is the controller of your personal information.
If you have any questions about this Privacy Policy or our privacy practices, please contact us at hello@kalbo.ai.