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Privacy policy

Review draft — not yet in effect. This proposed policy explains how Lumi Labs AB handles personal data when you use the LingoLooper app and website, and the rights you have over that data.

Draft for review 18 October 2026

Who are we?

LingoLooper is a language-learning app that provides speaking practice with AI avatars. Lumi Labs AB, based in Gothenburg, Sweden, is responsible for the personal data described in this policy. You can find our contact details below.

LingoLooper is intended for people aged 13 and above. If you believe a child under 13 has provided personal data to us, please contact us so we can investigate and take appropriate action.

What information do we collect?

Account and profile information
Your name, email address, account and sign-in information, profile picture and profile details you provide, such as language preferences, age group or gender.
Conversations and learning information
Voice recordings, conversation text and transcripts, conversation summaries, preferences, learning progress and assessments generated through your use of LingoLooper.
Usage and technical information
Features you use, interactions with the app or website, account and device identifiers, IP address, approximate location derived from your IP address, app version, device type, operating system and diagnostic information.
Purchases and subscriptions
Subscription status, purchase history and transaction references needed to manage access to paid features. Payment details are handled by the relevant app store or payment provider.
Feedback and support
Messages, feedback and issue reports you send us. Relevant technical, account and conversation information may be associated with a report so we can investigate it.
Referrals and social features
Referral and campaign information, player codes and connections with other players. Your display name, profile picture and learning activity may be visible to other users through features such as friends and LingoLeague.

Some information is necessary to provide the feature you request; for example, we need your speech to provide speaking practice. Other information, such as an optional profile picture or feedback, is provided at your choice.

Website cookies and similar technologies

Our website uses necessary cookies and similar technologies to operate securely and remember preferences. We also use optional technologies for analytics and, where used, campaign measurement. Where consent is required, these optional technologies depend on your consent. You can change your choices using Privacy preferences in the website footer. These choices apply to the website.

Why do we use your information?

Providing LingoLooper
To create and manage your account, provide conversations, speech features and personalized learning, operate social features, and manage subscriptions. We rely on the performance of our contract with you where this processing is necessary to provide the service you request.
Quality, development and security
To understand and improve the quality and reliability of LingoLooper, investigate problems, respond to support requests, and prevent fraud or misuse. We rely on our legitimate interests in providing, maintaining and improving a useful and secure service, where those interests are not overridden by your rights and interests.
Optional tracking and communications
Where required, we rely on your consent for optional website tracking and marketing communications. You can withdraw consent without affecting the lawfulness of earlier processing.
Legal obligations
To meet applicable legal requirements, including accounting obligations and responding to data-protection requests.

As part of quality improvement, we use selected voice recordings and related conversation information to investigate issues and assess and improve our speech and learning features. Authorized people working on our behalf may listen to these recordings as part of this work.

We also use learning activity and preferences to personalize features, recommendations and relevant communications.

Who will your information be shared with?

We share relevant information with providers that support LingoLooper. The information shared depends on the feature and the provider's role. These providers include:

AI and speech services
OpenAI, Microsoft Azure, Anthropic, Groq, ElevenLabs, Soniox and TypeSafe AI, for AI-powered interactions and speech and language features. Relevant recordings, conversation content, learning information and identifiers may be processed for these purposes.
Hosting, storage and website delivery
Microsoft Azure and Cloudflare, to host, store, deliver and protect our services and data.
Analytics
Mixpanel, Google Analytics and Cloudflare Web Analytics, to understand usage and measure product and website performance.
Diagnostics and quality monitoring
Sentry and Grafana Cloud, to monitor, troubleshoot and improve our services. Depending on the issue, this may involve technical data, identifiers and relevant conversation content.
Communications, feedback and support
OneSignal, Tally and Slack, for notifications, communications, collecting feedback and handling support requests.
Subscriptions and purchases
RevenueCat, Apple and Google, to process or manage app-store purchases, subscriptions and access to paid features.
Attribution and referrals
AppsFlyer, to measure campaigns and app installs and support referral and deep-linking features.
Approximate location and security
ipdata, to derive approximate location from IP addresses and support security, service customization and analytics.

Authorized people working for us may access relevant information to provide support and carry out the purposes described in this policy. We may also disclose information where required by law or necessary to establish, exercise or defend legal claims.

How do we store, retain and protect your information?

Storage and international processing

We use European hosting for our core application infrastructure. Some providers may process or access personal data outside the European Economic Area. Where applicable, international transfers are covered by safeguards such as an adequacy decision or standard contractual clauses. You can contact us for information about the safeguards relevant to your data.

Retention

Account, conversation and learning records
We normally retain these records while you maintain an account so we can provide your learning history and personalized features, subject to your privacy rights and any applicable retention requirements.
Routine recordings and diagnostics
We retain ordinary recordings and diagnostic information for the periods needed to process speech, verify operation and investigate technical issues. Selected recordings may be retained longer for the quality-improvement purposes described below.
Selected recordings for quality improvement
We retain selected recordings and related information while they remain necessary to assess the quality and reliability of our speech and learning features, investigate issues and verify improvements. Recordings linked to you are included in our account-deletion and applicable erasure processes.
Support, security and business records
We retain these for the time needed to resolve requests, protect the service, meet legal obligations and handle disputes. Some records may need to be kept after an account is deleted.

Removal from active systems, service providers and backups may take additional time while deletion is completed or applicable retention periods expire. This does not mean your account remains available for use. Contact us if you need information about the retention or deletion of particular data.

Security

We use technical and organizational measures designed to protect personal data, including access controls appropriate to the information involved. No method of transmission or storage can guarantee absolute security.

How do we communicate with you?

We use your contact details to respond to you and send messages about your account, subscriptions, security and the operation of LingoLooper. We keep relevant correspondence to handle your request and any follow-up.

We may also send learning reminders, news and promotional communications in accordance with applicable law and your preferences. You can use the unsubscribe instructions provided or the relevant settings, where available. Essential account, transaction and legal notices may still be sent.

How can you review, update or delete your information?

Depending on applicable law, you may have the following rights:

  • Access and correction. Request access to your personal data and ask us to correct inaccurate or incomplete information.
  • Erasure. Ask us to delete your personal data, subject to applicable exceptions.
  • Restriction and objection. Ask us to restrict processing or object to processing based on our legitimate interests on grounds relating to your particular situation. You can object to direct marketing at any time.
  • Portability. Receive certain data you provided in a structured, commonly used, machine-readable format.
  • Withdraw consent. Withdraw consent where we rely on it, without affecting earlier lawful processing.

Objecting to quality-improvement processing. You can contact us about this processing without deleting your account. We will assess your objection and stop the relevant processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or need the data for legal claims.

You can update information in your profile settings and request account deletion in the app. See our account-deletion instructions. Account deletion includes associated conversation and learning records and selected recordings linked to you, subject to the retention rules above. Deleting an account does not automatically cancel an app-store subscription.

To exercise your rights, email contact@lingolooper.com. We may need to verify your identity. We normally respond within one month; where a lawful extension is necessary, we will explain it within that period.

You can also complain to your local data-protection authority, including the Swedish Authority for Privacy Protection (IMY).

Do we make updates to this policy?

We may update this policy as LingoLooper or applicable requirements change. We will update the revision date and communicate material changes through the app, email or another appropriate channel. Where required, we will inform you before changes take effect or before using your information for a new purpose.

Contact us

Lumi Labs AB, Hälleflundregatan 48, 426 58, Västra Frölunda, Sweden
Email: contact@lingolooper.com
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