Legal

Privacy Policy

Last updated: August 2026

Short version: Eloqui collects only what it needs to run the app and improve your learning experience. There are no user accounts, we do not sell your data, and we do not show you ads. You can request deletion of your data at any time.

1. Who We Are

Eloqui is an AI-powered language learning application operated by ELOQUI LTD, a company registered in the United Kingdom ("we", "us", or "our"). This Privacy Policy explains how we collect, use, share, and protect your personal data when you use the Eloqui app or website at eloqui.es (collectively, the "Service").

For questions about this policy, contact us at: privacy@eloqui.es

2. Data We Collect

No account: Eloqui does not require you to register. We do not ask for your name, email address or a password. Your learning progress is stored on your device rather than in an account.
Learning data: the languages you study, lessons completed, vocabulary known, quiz results, streaks and practice session history — used to personalise your learning path.
Conversation data: the text and voice input you exchange with your AI tutor, used to generate responses and power your lessons.
Usage data: device type, operating system, app version, session duration, and feature interactions — used for analytics and bug fixing.
Payment data: subscriptions are processed by Google Play Billing on Android and by Apple's App Store on iOS, and are managed through RevenueCat. We never receive or store your card details.
Microphone / voice input: captured only while you are actively using a speaking feature. When you talk with your tutor, or use a pronunciation drill, your speech is streamed live to Google's Gemini Live API, which listens and answers in the tutor's voice in real time. Some screens still use Apple's on-device speech recognition, where the audio never leaves your iPhone; on Android, audio may also pass to your device's built-in recognition service, usually Speech Services by Google. Where our earlier pronunciation scoring is used instead, a short recording is sent to Microsoft Azure Speech in the European Union, graded, and discarded. We keep no recordings of your voice, and every speaking screen also accepts typed input.

3. How We Use Your Data

Provide, personalise, and improve the Eloqui learning experience
Maintain your account and progress across sessions and devices
Send you product updates, lesson reminders, and streak notifications (you can opt out at any time)
Detect fraud, abuse, and security incidents
Comply with legal obligations

We never sell your data and we never use it to serve third-party advertising.

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA) or the UK, we process your personal data on the following legal bases:

Contract performance: to deliver the Service you signed up for
Legitimate interests: to improve product quality and prevent fraud
Consent: for optional features such as marketing emails
Legal obligation: where required by law

5. Data Sharing & Sub-processors

We do not sell your personal data. To run the Service we share limited data with a small set of trusted providers, each bound by data-processing agreements:

Anthropic — powers your tutor's conversational intelligence. The text of your tutor conversations is sent to Anthropic's Claude models to generate responses. Anthropic does not use data submitted through its API to train its models.
ElevenLabs — provides the text-to-speech and voice technology that gives each tutor their voice.
Render — hosts the secure backend service that routes requests between the app and our AI providers and keeps our API keys off your device.
Google — powers the live voice tutor through the Gemini Live API. While a speaking session is running, your speech is streamed to Google, understood, and answered aloud in real time; the tutor's voice is generated by Google. Google also distributes the Android app through Google Play, processes Android subscription payments through Google Play Billing, and provides Android speech recognition under your device settings. Eloqui uses a paid tier of the Gemini API, so Google does not use this audio to train or improve its models; it is processed only to produce the tutor's reply.
Apple — distributes the iOS app and processes iOS subscription payments and, where enabled, sign-in.
RevenueCat — manages subscription entitlements using an anonymous app identifier that is not linked to your name or email.
Microsoft — provides the Azure Speech pronunciation assessment that scores how you say a word. Short audio clips of your spoken attempts are sent to Microsoft servers located in the European Union, scored for accuracy, fluency and intonation, and not retained afterwards. Microsoft does not use them to train models.
TelemetryDeck — privacy-first product analytics. Receives anonymous usage events such as which screens are opened and which features are used. It receives no user identifier, no advertising ID, and no part of your conversations.
LiveKit — carries the real-time connection for live video avatar tutor calls, on the plans and devices where that feature is available.
Legal requirements: we will disclose data if required by law, court order, or to protect our rights.

6. Data Retention

We retain your account and learning data for as long as your account is active, or as needed to provide the Service. If you delete your account, we will delete or anonymise your personal data within 30 days, except where we are required by law to retain it longer.

7. Your Rights

Access: request a copy of the data we hold about you
Correction: update inaccurate or incomplete data
Deletion: request that we delete your account and personal data
Portability: receive your data in a structured, machine-readable format
Objection / restriction: object to or restrict certain processing activities
Withdraw consent: for any processing based on consent, at any time

To exercise any of these rights, contact us at privacy@eloqui.es. We will respond within 30 days.

8. Children's Privacy

Eloqui is not directed at children under 13 years of age (or under 16 in the EEA). We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal information, we will delete it promptly.

9. Data Security

We use industry-standard security measures including TLS encryption in transit, encryption at rest, and access controls limiting who can view your data. Because Eloqui has no accounts, there is no password for you to manage or for anyone to steal. No system is 100% secure, but we do not store your conversations or recordings on our servers beyond what is needed to answer the request in front of us.

10. International Data Transfers

Your data may be processed in countries outside your own. When transferring data from the UK or EEA to third countries, we rely on appropriate safeguards such as Standard Contractual Clauses.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, for material changes, notify you via the app or email.

12. Contact Us

ELOQUI LTD — Privacy Team
Email: privacy@eloqui.es

UK and EEA users may also lodge a complaint with their local data protection authority.