Privacy Policy

This Privacy Policy describes how Sueta FZE LLC (“we”, “us”, or “our”) handles personal data in the Fluenza mobile applications and the fluenza.ai website. We are the data controller for that processing.

It does not cover third-party services you reach from ours — the app stores, or the payment pages of our payment processor — which have their own policies.

What you give us

• Your email address. It identifies your account, and it is also what connects a subscription bought on our website to your account in the app.
• Learning content. Answers to exercises, text you write, and audio you record for pronunciation and conversation practice.
• Quiz and onboarding answers. What you tell us in the quiz on our website or in the app: the name you want to be called, your age, gender, native language, English level, goals, interests, and preferences. We use them to build your plan. On the website the answers stay in your browser until you pay; after a successful payment they travel with the payment record through Stripe to our servers, so the app can open with your plan ready.
• Support correspondence. What you write to us and what we reply.

What we collect automatically

• Usage data. Which lessons you open, how far you get, streaks, and similar progress signals.
• Device and technical data. Device model, operating system, app version, language, IP address, and crash diagnostics.
• Analytics events. Product analytics about how the app, the quiz, and the checkout are used: which screens you see, which plan you choose, whether a payment succeeds. Analytics events do not include your email address, your name, or the text of your answers.
• Session recordings. On our website we may record how pages are used — clicks, scrolling, and navigation — to find what is confusing or broken. Text you type into fields is masked, and payment details are entered on Stripe's forms, which are never recorded.
• Advertising measurement. When you reach our website from an ad, an advertising pixel reports to the ad network that you viewed the quiz, started checkout, or completed a purchase, with the plan and amount but without your email, name, or answers. See Cookies and Advertising.

What we do not collect

We never receive your full card number. Payments are taken by Stripe, which collects card details directly on its own infrastructure; we see only the outcome of the payment, the last four digits, the card brand, and the billing country.

• to provide the Services and keep your progress across devices;
• to generate lessons, corrections, and feedback adapted to your level;
• to take payment, manage your subscription, and unlock paid features for the account matching your email;
• to send service messages, reminders, and receipts;
• to diagnose crashes, prevent abuse and fraud, and keep the Services secure;
• to understand, in aggregate, which parts of the product work and which do not;
• to measure which of our ads lead to purchases, and to show our ads to people likely to be interested in them;
• to comply with legal obligations.

Where the law requires a legal basis, we rely on performance of our contract with you (providing the Services and billing), our legitimate interests (security, abuse prevention, product improvement), your consent where the law requires it (including for advertising cookies in some countries), and compliance with legal obligations.

Conversation practice, corrections, and explanations are produced by AI models, some of which are operated by third-party providers. To generate a response, the text or audio you submit — together with the context of the exercise — is sent to the provider and processed there.

We contract with these providers so that your content is used to serve your request and not to train their general-purpose models. We do not sell this content, and we do not use it for advertising.

Please do not submit sensitive personal data, credentials, or confidential material to the AI features. You can ask us to delete your practice history at any time — see Your Privacy Rights.

We do not sell personal data. We share it only with service providers who process it on our behalf, under contract, for the purposes above:

• Payments. Stripe, which processes card payments and manages subscriptions and the billing portal.
• Subscription management. Apphud, which records which subscription belongs to which account so paid features unlock in the app. It receives your email address as the identifier tying the two together.
• AI providers. As described in the previous section.
• Analytics. PostHog, which receives the analytics events and session recordings described above.
• Advertising. Meta Platforms, through the Meta Pixel, which receives the advertising events described above and the cookie and device data its pixel collects.
• App download links. AppsFlyer, which records the click when you follow our link to the App Store or Google Play, so we can tell which installs came from our website.
• Infrastructure. Cloudflare, which hosts our website, and our hosting and crash-reporting providers for the app.

We may also disclose personal data where we are legally required to, to protect our rights or someone's safety, or as part of a merger, acquisition, or sale of assets — in which case we will say so before your data becomes subject to a different policy.

Our website uses cookies and similar browser storage: to keep your quiz answers and your place in the checkout, to prevent payment fraud, to understand how the website is used, and to measure our advertising. Our Cookie Policy lists them and explains how to block or delete them.

Under some US state privacy laws, letting an advertising network collect data through its pixel can count as “sharing” personal information for cross-context behavioural advertising, or as a “sale”. We do not sell personal data for money. You can opt out of advertising measurement by blocking or deleting cookies in your browser, by adjusting your ad preferences with Meta, or by writing to hello@sueta.co.

We use encryption in transit, access controls, and the security practices of our infrastructure providers to protect personal data. No system is perfectly secure, and we cannot guarantee absolute security.

We keep personal data for as long as your account is active, and after that for as long as we need it to meet legal, tax, accounting, and dispute-resolution obligations — records of payments in particular are kept for the period tax law requires. Learning content is deleted on request, or when your account is deleted.

Depending on where you live, you may have the right to access a copy of your personal data, to correct it, to delete it, to restrict or object to certain processing, to data portability, and to withdraw consent you have given. Residents of the EEA and the UK have these rights under the GDPR; residents of California and other US states with privacy laws have comparable rights, including the right not to be discriminated against for exercising them.

To exercise any of them, write to hello@sueta.co from the email address on your account. We answer within the time the applicable law allows — one month under the GDPR, 45 days under most US state laws. You also have the right to complain to your local data-protection authority.

We operate internationally, and our service providers are located in several countries, including the United States and the European Union. Where personal data is transferred out of the EEA or the UK, we rely on the European Commission's Standard Contractual Clauses or another transfer mechanism permitted by law.

The Services are not directed to children under 16, and we do not knowingly collect their personal data. If you believe a child has given us personal data, write to hello@sueta.co and we will delete it.

We may update this policy. The “Last updated” date above shows when it last changed, and we will notify you in the app or by email before a material change takes effect.

Sueta FZE LLC — questions about this policy, or any request about your data, go to hello@sueta.co.