Privacy Policy

Befluent.ai respects your privacy and is committed to protect the personal information thatyou share with us. Generally, you can browse through our website without giving us anyinformation about yourself (except for cookies and pixel tags, as provided in this privacypolicy). When we do need your personal information to provide services that you request orwhen you choose to use our application, an AI tool built to help you achieve English fluency(the “App” or the “Services”), or provide us with your personal information, for examplewhen you decide to contact us for additional information, this policy describes how wecollect and use your personal information.

Who is responsible for the processing of your personal data?

The entity responsible for the processing of your personal data is Befluent Inc., referred to as“Befluent.ai”, “our”, “we” or “us” in this privacy policy.


How we collect and use information, and legal basis for processing
Depending on your interaction with us, we collect two types of data:

"Non-Personal Data" meaning, information which does not identify a specific natural personand cannot reasonably be used for such identification. We collect Non-Personal Data duringyour interaction with us, such as your date and times of interaction, means ofcommunications, whether you have engaged with emails we sent you, etc. This data isconsidered as Non-Personal Data when collected on an aggregate or statistical basis, orotherwise not combined with online identifiers.

Non-Personal Data may be used by us without limitation and for any purpose, including forcommercial, research, or statistical purposes, in order to maintain and develop our website,App and Services including among others, to help prevent frauds, etc.

“Personal information” means any information that may be used to identify an individual,including, but not limited to, a first and last name, email address, a home, postal or otherphysical address, other contact information, title, birth date, gender, occupation, industry,personal interests, and other information required in order to provide a product or service yourequested.

We use the Personal Information we collect from you for a range of different businesspurposes according to different legal bases of processing. We may use or process yourpersonal information for the following purposes. One or more legal bases may applysimultaneously.


Information for providing you with Services

We may collect and store Personal Information such as name, address, email address,telephone number, gender, birth date, and other contact information in order to provide youwith Services. We may also collect and store Personal Information regarding your usage ofthe App, for example, the information you provide during a lesson offered by the App, thetranscript of the lessons, and your voice recording during the conversation.

The basis for our collection of data is the need to carry out the above processing ofinformation, as part of the performance of existing engagements with you.


Information for Customer Support and Inquiries

We may collect and store Personal Information, such as name, address, email address,telephone number and contact information, when you submit inquiries or requests withrespect to our App and Services. We will use such information to contact you only for thepurposes for which you sent the inquiry.

The basis for collection of data is the need to carry out the above processing of informationfor performance of existing engagements with you and our legitimate interest to conduct aneffective interaction with our users which are customers and/or potential customers.


Information for the maintenance and Improvement of our website, App, and Services

We may also use your Personal Information, such as personal information regarding yourusage of the App, as web server logs, IP addresses, cookies, local storage tools, pixel tags,web beacons when you send us inquiries regarding our App, Services or when you browsethe website, in order to administrate and improve the App, website, or our Services, for ourinternal records and for statistical analysis, as set forth in this Policy.

We also use data provided by you, including conversation data, to retrain and enhance theApp’s algorithms.

The basis for collection of data is the need to carry out the above processing of informationfor our legitimate interest to conduct such improvements and analysis, as well as for theperformance of our contract with you.


Information for Marketing and Promotional Purposes

In the event you sign up to receive our newsletter or other promotional materials, or wherewe are permitted to do so under applicable law, we will process your contact details, such asemail address, for sending you news, notices, newsletters and updates regarding our Services.In line with the law we will always give you the opportunity to opt in to our mailing list andwithout your explicit consent we will not add you to our mailing list to receive directmarketing or market research information Our lawful basis for the processing of this data isour legitimate interests, or, in certain cases your consent.

You may withdraw your consent at any time by clicking the “unsubscribe” link which will beincluded in the email we will send you. You may also contact us through the below means ofcontact and request to unsubscribe.

Cookies, pixels and web beacons

The website and the App may also collect cookies, pixels, web beacons and other similarinformation collected through application tracker and analytics tools.

We use such information to assist us in securing your use of the App and to enhance theperformance of our website, App and Services. Cookies are small text files sent from theserver to your device. Cookies used by us do not contain personal information nor do theycontain account or password information. They merely allow the App and the website torecognize that a page request comes from someone who has already logged on.

We may share website and App usage information with reputable advertising companies fortargeting our banner advertisements on our website, App and other websites and Apps. Forthis purpose, pixel tags (also called clear gifs or web beacons) may be used to note the pagesyou have visited. The information collected by the advertising company through the use ofthese pixel tags is not personally identifiable.

If you wish to block cookies, you may do so through your browser’s and application settings.You can delete cookies that are already on your computer or local storage, and you can setyour browser to prevent them from being placed going forward. However, please bear inmind that disabling cookies or local storage may adversely affect your user experience of theService.


Information sharing and disclosure

Your personal information may be shared with other Befluent.ai offices or subsidiariesaround the world. All such entities are governed by this Privacy Policy or are bound by theappropriate confidentiality and data transfer agreements.

Befluent.ai may share your personal information with other companies or people under any ofthe following circumstances:

1. When we have your consent to share the information;

2. We need to send the information to third parties who provide services to Befluent.ai(such as speech recognition or text to speech or speech-to-text technology), or workon behalf of Befluent.ai to provide you with certain customer service (we will onlyprovide those companies the information they need to deliver the service, and they areprohibited from using that information for any other purpose);

3. In the event of sale or transfer of all or substantially all of Befluent.ai or anyBefluent.ai affiliate’s shares or assets, in cases of mergers or in case of negotiationswith respect to the foregoing;

4. Where needed for corporate audits or to investigate or respond to a complaint orsecurity threat, to prevent illegal uses of our services, to defend ourselves against thirdparty claims and assist in fraud prevention or investigation; or

5. We will also disclose your personal information if required to do so by law, or inurgent circumstances, to protect personal safety, the public or our business.


We will not sell or otherwise transfer the personally identifiable information you provide tous at our App or website to any third parties for their own direct marketing use unless weprovide clear notice to you and obtain your explicit consent for your data to be shared in thismanner, when required by applicable law.


Data Retention

Befluent.ai stores the personal information as long as it is necessary to fulfill the purpose forwhich the data has been collected. This means that Befluent.ai deletes your personalinformation when such information is no longer necessary, unless we have a legitimateinterest to retain such data for longer periods or are required to do so by any applicable law.Statistics which have been anonymized may be saved thereafter.


Data Subject Rights

You may at any time request the rectification or erasure of your personal information. Pleasenote however that deletion could mean that Befluent.ai cannot process your requests orprovide you any requested services. You have the right to request a copy of your personalinformation from our record. You have the right to request a limitation of the use of yourpersonal information (for example if you deem the information to be incorrect) or thetermination of use of your personal information (for example as regards the use of theinformation to improve our services).


Data security

Befluent.ai safeguards the security of the data you send us with physical, electronic, andmanagerial procedures, taking into consideration the state of the art, the costs ofimplementation and the nature, scope, context and purposes of processing as well as the riskof processing your personal information. While we strive to protect your personalinformation, we cannot ensure the security of the information you transmit to us, and so weurge you to take every precaution to protect your personal data when you are on the Internet.


Third party sites


Our App and Website may contain links to other apps and websites operated by othercompanies. Befluent.ai does not share your personal information with those apps andwebsites and is not responsible for their privacy practices. We encourage you to learn aboutthe privacy policies of those companies. Some of these third-party apps and sites may havepermission to include the Befluent.ai logo, even though they are not operated or maintainedby Befluent.ai. Although we choose our business partners carefully, Befluent.ai is notresponsible for the privacy practices of apps and websites operated by third parties that arelinked to our website and App. Once you have left our website or App, you should check theapplicable privacy policy of the third-party website or app to determine how they will handleany information they collect from you. We may provide services based on third partyapplications and content tools on Befluent.ai’s website or App. These third parties mayautomatically receive certain types of information whenever you interact with us on ourwebsite or App using such third-party applications and tools, based on such third parties’privacy statements.

Changes to this privacy policy

Befluent.ai will amend this policy from time to time. If we make any substantial changes inthe way we use your personal information we will make that information available by postinga notice on Befluent.ai’s website.


Privacy Inquiries

Requests to exercise your rights as stated above shall be addressed to legal@befluent.ai