Privacy Policy
Last updated: March 27, 2026
1. Data controller
Owner: Gonzalo Hafner Roda
Tax ID: 51107367X
Address: Calle Marte, Pozuelo de Alarcón 28224 Madrid
Contact email: privacy@fluentup.ai
Website: https://www.fluentup.ai
2. What data we collect
Registration data
Full name, email address, and password (stored encrypted with bcrypt). Optionally, a preferred name for coaches to address you by.
Voice and conversation data
When you have a practice session, your voice is transmitted in real time to ElevenLabs for processing (speech recognition and response generation). We do not store audio recordings. We do store the text transcript of the conversation to generate feedback and scores.
Usage and progress data
CEFR scores, AI-generated feedback (grammar errors, vocabulary suggestions, fluency metrics), session duration, monthly practice minutes, and session preferences (speed, correction style, subtitles).
Payment data
Payments are processed entirely through Stripe. We do not store credit card numbers or banking details on our servers. We only store a Stripe customer identifier, subscription ID, and its status.
Free assessment data
If you take the assessment without registering, results are stored temporarily in your browser (sessionStorage) and are not saved on our servers. If you provide your email to receive results, we store your email address and assessment data.
Technical data
IP address (to limit free assessment usage to 3 per day), browser type, and basic connection data.
3. How we use your data
| Purpose | Legal basis (GDPR) |
|---|---|
| Provide the service (practice sessions, feedback, progress tracking) | Performance of contract (Art. 6.1.b) |
| Manage your account and subscription | Performance of contract (Art. 6.1.b) |
| Process payments via Stripe | Performance of contract (Art. 6.1.b) |
| Send assessment results by email | Consent (Art. 6.1.a) |
| Analyze website usage to improve the service (Google Analytics) | Consent (Art. 6.1.a) |
| Prevent service abuse (rate limiting) | Legitimate interest (Art. 6.1.f) |
| Comply with legal and tax obligations | Legal obligation (Art. 6.1.c) |
4. Who we share your data with
We do not sell or share your personal data with third parties. The following providers act as data processors and access your data solely to provide the service:
| Provider | Function | Location |
|---|---|---|
| ElevenLabs | Voice processing (speech recognition and synthesis) | US / EU |
| Anthropic | AI feedback generation (Claude) | US |
| Stripe | Payment processing | US / Ireland |
| Amazon Web Services (AWS) | Application hosting, database and email delivery (SES) | Ireland (eu-west-1) |
| Google Ireland Limited | Web analytics (Google Analytics 4) | Ireland / US |
5. International data transfers
Some of our providers are located in the United States. These transfers are carried out under the EU-US Data Privacy Framework or, alternatively, through Standard Contractual Clauses approved by the European Commission. You can request information about the applicable safeguards by writing to privacy@fluentup.ai.
6. How long we keep your data
| Data type | Retention period |
|---|---|
| User account | While the account is active. After deletion, data is removed within 30 days |
| Sessions and transcripts | While the account is active |
| Billing data | 5 years after the last transaction (tax obligation) |
| Assessment leads | 12 months from capture, unless the user registers |
| IP addresses (rate limiting) | 24 hours (in memory, not stored in database) |
7. Your rights
Under the GDPR, you can exercise the following rights at any time:
- Access: know what personal data we process about you.
- Rectification: correct inaccurate or incomplete data.
- Erasure: request deletion of your data (“right to be forgotten”).
- Portability: receive your data in a structured, commonly used format.
- Objection: object to the processing of your data in certain circumstances.
- Restriction: request restriction of processing in legally prescribed cases.
To exercise any of these rights, write to privacy@fluentup.ai with your full name and the right you wish to exercise. We will respond within 30 days.
If you believe we have not adequately addressed your rights, you may file a complaint with the Spanish Data Protection Agency (AEPD) — www.aepd.es, or with your local supervisory authority.
8. Voice recordings
FluentUp processes your voice in real time to convert it to text (speech-to-text) using ElevenLabs. Audio is transmitted via WebSocket during the session and is not stored on our servers or by ElevenLabs once the session ends. We only retain the resulting text transcript, which is necessary to generate session feedback.
9. Cookies
FluentUp uses the following types of cookies:
Essential cookies
These do not require consent as they are strictly necessary for the service.
- fluentup-session: required to keep you logged in. Deleted when you log out or when it expires (30 days).
- fluentup-cookies: stores your analytics cookie preference. Expires in 1 year.
Analytics cookies (optional)
Only activated if you give explicit consent through the cookie banner.
- _ga, _ga_*: Google Analytics (GA4). These allow us to understand how the website is used anonymously (pages visited, visit duration, traffic sources). Data is processed in aggregate. They expire after 2 years.
We do not use advertising or social media cookies. You can change your cookie preference at any time by deleting the fluentup-cookies cookie from your browser, which will cause the banner to reappear.
Google Analytics
We use Google Analytics 4, a web analytics service provided by Google Ireland Limited. Google processes data on our behalf under its Data Processing Terms. You can review Google's privacy policy at policies.google.com/privacy. The legal basis for this processing is your consent (Art. 6.1.a GDPR).
10. Children's data
FluentUp is intended for users aged 16 and older. We do not knowingly collect data from children under 16. If you are a parent or guardian and believe a minor has provided personal data, contact us at privacy@fluentup.ai and we will delete it.
11. Changes to this policy
We may update this privacy policy from time to time. When we do, we will update the “last updated” date at the top. If the changes are significant, we will notify you by email or through a notice in the application.
12. Contact
For any questions about privacy or data protection, write to privacy@fluentup.ai.