1. INTRODUCTION
Welcome to SpeakLuma.
SpeakLuma ("we," "us," or "our") is an AI-powered English-language learning platform operated by SpeakLuma, a sole proprietorship registered in India.
Registered Address: 466, Civil Line, Unnao, Uttar Pradesh – 209801, India.
Website: https://speakluma.com
Email: hello@speakluma.com
We are committed to respecting your privacy and protecting your personal information.
This Privacy Policy explains how SpeakLuma collects, uses, processes, stores, shares, and protects information when you use our mobile application, website, and related services.
The current public launch website has a narrower scope than the learning application; its waitlist and browser-only features are described separately below.
It also explains the choices and rights available to you regarding your personal information.
2. INFORMATION WE COLLECT
We collect information necessary to provide and improve our English-learning services.
2.1. Account Information
When you create an account, we collect your name, email address, phone number, password or authentication credentials, and unique account identifiers.
This information is used to register your account, authenticate access, communicate with you, and provide account-related assistance.
Creating an account is required to use SpeakLuma's learning services.
2.2. Learning and Personalization Information
SpeakLuma collects information about your English-learning activities, including your English proficiency level, learning objectives, assessment responses, personalized learning plans, completed lessons, exercise scores, learning progress, and areas requiring improvement.
We use this information to personalize lessons, recommend practice activities, track progress, and help you continue learning when you return to the application.
2.3. Voice and Conversation Information
SpeakLuma provides AI-powered speaking and conversational learning features.
When you participate in these activities, microphone audio is processed to recognize speech, generate AI responses, and provide language feedback.
SpeakLuma does not intentionally store original voice recordings as part of your permanent learning history.
However, audio may be transmitted to third-party speech-processing providers for temporary processing. Those providers may have their own processing and retention practices.
Conversation transcripts, AI-generated responses, language corrections, and relevant learning outcomes may be saved to your account to support personalization and progress tracking.
2.4. Technical and Usage Information
On the current public launch website, the waitlist is stored in a managed MySQL database and may include an email address, optional learning goal, consent timestamp and notice version, and age or guardian declaration timestamp.
For abuse prevention, the launch website may use a pseudonymous keyed network-address hash and request counters.
A browser appearance preference, practice points, and practice scenarios remain browser-only.
The launch website does not provide account creation and does not collect microphone recordings, app-learning records, or payment details. The separate learning application may process the account, learning, conversation, and voice information described in this policy when those services are used.
We may process information about your device, operating system, app version, connection status, application errors, and interactions with SpeakLuma.
This information helps us troubleshoot technical issues, maintain application reliability, and improve the learning experience.
3. HOW WE USE YOUR INFORMATION
We use collected information to provide and maintain SpeakLuma's learning services, create and manage accounts, authenticate users, generate personalized lessons, evaluate assessments, enable AI-powered conversations, provide corrective feedback, save learning progress, and improve educational content.
We may also use information to respond to support requests, process subscriptions, maintain security, investigate technical problems, communicate important updates, and comply with applicable legal obligations.
Where consent is required by applicable law, we will seek the appropriate consent before processing personal information for the relevant purpose.
4. ARTIFICIAL INTELLIGENCE AND VOICE PROCESSING
SpeakLuma integrates artificial intelligence and voice-processing technology to support interactive language learning.
When you use AI-powered learning features, relevant inputs may be transmitted to technology providers, including OpenAI and ElevenLabs.
These inputs may include conversation text, audio submitted during speaking exercises, learning preferences, assessment responses, and other information necessary to generate educational feedback.
SpeakLuma uses this information to provide conversational responses, pronunciation assistance, language corrections, and personalized exercises.
We do not intentionally retain original audio recordings as permanent learning records.
Third-party providers may process and retain submitted information according to their applicable service terms, contractual arrangements, and data-processing practices.
AI-generated educational content may occasionally contain errors or inaccuracies.
5. MICROPHONE ACCESS
SpeakLuma requests microphone permission to enable voice-based English-learning features.
Microphone access is used when you initiate speaking exercises or AI conversations requiring audio input.
You may manage or revoke microphone permission through your device settings.
Certain voice-based features may become unavailable when microphone access is disabled.
6. THIRD-PARTY SERVICE PROVIDERS
SpeakLuma uses third-party technology providers with different roles for the learning application and the public launch website.
The learning application providers supplied for SpeakLuma include:
MongoDB for database infrastructure and storage of learning-application user accounts and learning information.
OpenAI for AI-powered language processing and educational feedback in the learning application.
ElevenLabs for voice-related technologies in the learning application.
Emergent for learning-application development and associated technical services.
Manus for development and hosting of the actual public launch website.
GoDaddy for domain registration and DNS management, not website hosting.
Google Workspace for official business email and communications, only when activated.
Razorpay as the intended payment processor for eligible transactions, if and when relevant payment arrangements are enabled.
The learning-application providers above are distinct from the managed MySQL waitlist storage used by the current Manus-hosted launch website.
These providers may process information necessary to deliver the services they support.
We seek to use appropriate technical and contractual safeguards when engaging third-party service providers.
Some providers may process information outside India.
7. DATA STORAGE AND SECURITY
SpeakLuma uses database and hosting services to store information needed for the relevant service. The current launch website stores waitlist information in managed MySQL; the separate learning application may store account information and learning records.
Stored information may include account details, learning preferences, assessment results, conversation transcripts, and progress history.
We take reasonable measures to protect personal information against unauthorized access, loss, alteration, disclosure, and misuse.
The specific safeguards, access controls, retention settings, geographic locations, encryption, certifications, and security architecture used for a particular service may vary and are not promised by this policy.
However, no electronic storage or transmission method can guarantee absolute security.
8. LEARNING HISTORY AND PERSONALIZATION
SpeakLuma maintains learning-related information to provide continuity between sessions.
Returning users may access their saved learning plans, assessment information, lesson history, and progress where supported by the application.
This information may also be used to recommend lessons, identify areas requiring improvement, and adjust learning difficulty.
9. PAYMENTS AND SUBSCRIPTIONS (FUTURE ELIGIBLE TRANSACTIONS; NOT ENABLED ON LAUNCH WEBSITE)
The current launch website accepts no payments. The following provisions apply only to future eligible transactions if and when relevant payment arrangements are enabled; they do not assert that a Razorpay checkout, Google Play Billing, or alternative billing arrangement is currently live.
SpeakLuma uses Razorpay to facilitate eligible subscription payments and other financial transactions.
Where applicable, payments made through our Android application may also be processed through Google Play Billing or another billing arrangement permitted under Google Play's applicable policies.
Payment providers may collect billing details, payment information, transaction identifiers, and contact information necessary to process transactions.
SpeakLuma may receive transaction confirmations, subscription statuses, and limited payment-related information necessary to manage subscriptions, resolve billing issues, and provide customer support.
Payment information is handled according to the applicable payment provider's privacy practices.
For more information about Razorpay, please visit https://razorpay.com/privacy-policy/.
10. COMMUNICATIONS AND MARKETING
SpeakLuma may contact you regarding account activity, learning services, technical issues, subscription information, and important operational updates.
We may also send promotional communications, educational offers, and announcements where permitted by applicable law.
Where legally required, we will obtain consent before sending promotional communications.
The current newsletter sender and the hello@speakluma.com operational mailbox have not been verified as active. Google Workspace is conditional and applies only when activated. Do not assume that a communication, consent, or deletion-request channel is connected or operational until it has been confirmed.
Users may opt out of promotional emails through available unsubscribe mechanisms or by contacting the applicable operational channel once it is active.
11. ANALYTICS AND FUTURE FEATURES
Google Analytics, Firebase Analytics, and Meta Pixel are not currently implemented on this launch website.
This policy does not claim that analytics or advertising technologies are active in the learning application; any application implementation requires its own review and updated disclosures.
SpeakLuma may introduce analytics and performance-monitoring technologies in the future.
Such technologies may process information regarding application performance and user interactions.
We will update our privacy disclosures and obtain any legally required permissions before introducing materially different tracking or advertising practices.
No child or unknown-age analytics or advertising is activated on this launch website. Additional safeguards and a legal and Google Play Families review are required before enabling relevant child-facing tracking or advertising.
12. INFORMATION SHARING
We may share relevant information with authorized service providers when necessary to operate SpeakLuma.
We may also disclose information where required by law, a valid legal process, or legitimate security investigations.
If SpeakLuma undergoes a business restructuring or transfer, relevant information may be transferred subject to applicable legal requirements.
13. CHILDREN'S PRIVACY
SpeakLuma is intended to support English-language learners, including school students and users under 18.
We recognize that children's personal information requires additional protection.
Where applicable law requires parental or guardian consent, SpeakLuma must obtain the necessary authorization before processing children's personal information.
Additional age-related safeguards may apply to account registration, payments, communications, and third-party technologies.
Parents and legal guardians may contact us regarding children's accounts, personal information, or deletion requests.
Any age or guardian checkbox or declaration on the launch website is a declaration only, not verification. Dedicated child-safety and parental-consent workflows have not been confirmed as implemented and tested.
No child or unknown-age analytics or advertising is activated on the launch website. Applicable legal and Google Play Families requirements must be reviewed before enabling relevant features.
14. DATA RETENTION
We retain personal information for as long as reasonably necessary to provide SpeakLuma's services, maintain account functionality, and fulfil applicable legal obligations.
Account details and learning records may remain associated with an active account to preserve learning progress.
For the launch website, waitlist information and associated consent and age-declaration timestamps may be retained as reasonably necessary for enrollment communications, abuse prevention, legal compliance, and related operations. No fixed deletion deadline is stated here.
When information is no longer required, or when a valid deletion request is processed, we will take appropriate steps to delete or anonymize the relevant information, subject to applicable retention requirements.
Third-party service providers may maintain separate retention practices for information processed through their services.
15. ACCOUNT DELETION AND DATA ERASURE
Users may request deletion of their SpeakLuma accounts at any time. To request account deletion within the application, open the Profile section and select ‘Delete Account.’
Users may also request account deletion by emailing hello@speakluma.com. Account-deletion information can be accessed at https://speakluma.com/delete-account.
Account deletion removes the account and its associated personal information, learning progress, assessment results, personalized learning plans, and saved conversation history, except information that SpeakLuma is legally required to retain.
Deletion requests will be handled securely. Where necessary, SpeakLuma may require reasonable identity or account-ownership verification before processing a request to protect against unauthorized deletion.
Users may also contact us regarding access, correction, or other privacy-related requests.
16. YOUR PRIVACY RIGHTS
Subject to applicable law, users may request access to personal information, correction of inaccurate information, deletion of personal information, or withdrawal of consent where processing is based on consent.
Users may also contact SpeakLuma with privacy concerns or complaints.
We will review and respond to requests in accordance with applicable legal requirements.
17. INTERNATIONAL DATA PROCESSING
SpeakLuma initially intends to serve users primarily in India.
Certain service providers may process or store information in other countries.
Where international processing occurs, we will take appropriate steps to comply with applicable legal requirements.
18. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy to reflect changes to our services, technology, business operations, or legal obligations.
The latest version will be published through our website or application.
Where appropriate or legally required, we will notify users of material changes.
19. CONTACT INFORMATION
SpeakLuma Sole Proprietorship
Registered Address: 466, Civil Line, Unnao, Uttar Pradesh – 209801, India
Email: hello@speakluma.com
Website: https://speakluma.com