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Draft — pending legal review

This text is an internal draft for product design. It has no legal effect until reviewed by counsel and published as an official version.

Consent policy by purpose

You never agree to “everything” at once. Each purpose is its own switch, explained before we ask, and can be turned off at any time.

Updated 2026年9月22日Version 0.1-draft

1. Principles

  • One switch per purpose, off by default, with a history of changes.
  • Only the two voice purposes are needed for speaking; the other five can wait.
  • We explain before asking for the microphone; no surprise browser dialogs.
  • Withdrawal takes effect within 60 seconds and the data for that purpose is hard-deleted.
  • Organisations and partners may only add purposes of their own; they can never edit or remove these seven.

2. The seven purposes

These are exactly the seven switches you see under Me → Privacy, with the same explanations.

  1. 01

    Record your speaking

    Needed for speaking
    Why we need it
    To hear you speak and give feedback. Without recordings there are no speaking tasks; you can still learn with text.
    Who hears or sees
    You, and the rater or teacher assigned to that turn. No managers, no support staff.
    How long
    30 days, then deleted; longer only as evidence for a verified claim and with your consent. You can delete earlier.
    How to withdraw
    Switch off under Me → Privacy. Effective within 60 seconds; recordings are hard-deleted; your plan switches to text tasks.
  2. 02

    Analyse your voice for feedback

    Needed for speaking
    Why we need it
    To measure latency, pauses and keywords for fast feedback and scoring. Never used to identify you or read emotions.
    Who hears or sees
    Automated systems; the results (features, transcripts) are visible only to you and your assigned rater.
    How long
    Same as the source recording: 30 days, or longer if you consent to keeping it as evidence.
    How to withdraw
    Switch off under Me → Privacy. Effective within 60 seconds; features and transcripts are deleted with the recording.
  3. 03

    Use the documents you upload

    Why we need it
    Only to pull your real vocabulary and situations into practice tasks. Documents are untrusted content for the AI: structured extraction only, no raw logging.
    Who hears or sees
    Only you. No coach, no manager, no operations staff (except audited emergency access).
    How long
    Until you delete the document or withdraw consent.
    How to withdraw
    Switch off under Me → Privacy or delete individual documents. Effective within 60 seconds; extracted vocabulary is removed from new tasks.
  4. 04

    Share progress with your manager

    Why we need it
    So the organisation providing your account can see how the team is moving towards mandatory outcomes.
    Who hears or sees
    Your organisation's managers and admins — aggregates only: progress, verified claims, participation. Groups under 5 show totals only. No recordings, no transcripts, no rankings.
    How long
    Aggregate reports are kept per the organisation's contract; the underlying data follows the other purposes.
    How to withdraw
    Switch off under Me → Privacy. Effective within 60 seconds; you drop out of reports from then on. An organisation may require this consent as a condition of the seat, but can never force access to private data.
  5. 05

    Share with a sponsor

    Why we need it
    When someone else pays for your learning (a parent company, a scholarship), they need to know whether you are using it and progressing.
    Who hears or sees
    A person with a sponsor profile designated by the organisation — aggregates only, plus the ability to submit a Sponsor Evidence Form confirming capability at the workplace.
    How long
    For the duration of the sponsorship.
    How to withdraw
    Switch off under Me → Privacy. Effective within 60 seconds.
  6. 06

    Record live sessions

    Why we need it
    For re-scoring and quality control of teaching. Only when everyone in the session agrees; without full consent, nothing is recorded.
    Who hears or sees
    You, the session's teacher, and the assigned quality reviewer.
    How long
    30 days, then deleted.
    How to withdraw
    Switch off before the session under Me → Privacy, or decline in the room. Withdrawing afterwards: the recording is hard-deleted within 60 seconds.
  7. 07

    Anonymised use for research

    Why we need it
    To calibrate scoring and improve feedback for every learner. Data is anonymised and never re-linked to you.
    Who hears or sees
    The platform's content-quality team, on anonymised data; never shared with third parties in identifiable form.
    How long
    The anonymised copy is no longer personal data; the original follows the other purposes.
    How to withdraw
    Switch off under Me → Privacy. Effective within 60 seconds for new data; previously anonymised data cannot be removed because it is no longer linked to you.

3. Default retention

  • Voice recordings: 30 days.
  • Live session recordings: 30 days.
  • Transcripts and voice features: same as the source recording.
  • Uploaded documents: until you delete them.
  • Evidence for a verified claim: kept longer only with your consent; you can delete it and the claim moves to “no evidence” status.

The organisation providing your account may set a shorter retention for its tenant, never a longer one.

4. Withdrawing consent

Go to Me → Privacy and switch the purpose off. The system records the time and the version of the text you read, stops all new processing within 60 seconds, and hard-deletes the data for that purpose as in the table above.

Withdrawal does not close your account and does not lose your progress, claims or plan — only the parts that need that purpose stop (for example speaking tasks when recording is off).

5. Organisations and partners

Companies and partner centres use these same seven purposes. They may add purposes of their own (for example sharing with an internal HR team) with their own switch and explanation, and you may decline; they may not edit the explanations or remove your right to withdraw.

Tenant policy can only be stricter than the platform: shorter retention, realtime off, recording off.

6. Data requests (DSAR)

You export all your data or delete your account from inside the app; no email needed. If you cannot sign in, contact support and we verify your identity through your registered email.

  1. 1Go to Me → Privacy → My data
  2. 2Choose “Export data” — the request runs in the background; you receive a download link by email that expires after 7 days
  3. 3Or choose “Delete account” — 2 steps, the consequences spelled out, type DELETE to confirm
  4. 430-day grace period: sign in again to cancel the deletion; after that, data is hard-deleted
  5. 5Every request is answered within 30 days at most, as data-protection law requires

Already have an account? Manage my consents under Me → Privacy.

Questions about this document? Contact us.