Privacy Policy

01Your privacy choices at a glance

• Delete a message: Use the deletion control in your conversation history to remove an individual message.
• Clear your history: Use the option in your history to clear all conversation records covered by that control.
• Delete your account: Use the account deletion option to close your account and request deletion of associated personal information.
• Get help: Email [email protected] if you cannot access a control, need a copy of your information, or have a privacy concern.

The scope of these actions, including limited record-retention exceptions, is explained below.

02Information we collect

The information we process depends on the features you use and what you choose to provide.

Some conversation content can reveal sensitive personal information. You do not need to provide information about your health, beliefs, identity documents or other private matters to practice a language. Please avoid entering passwords, complete payment-card details, or another person's confidential information into conversations or support messages.

We need certain information to provide particular features. For example, an account requires information that lets us identify and authenticate it, voice feedback requires processing the voice input you submit, and a purchase requires transaction information. If you decline to provide information necessary for a feature, that feature may be unavailable. You can use text-based conversation without submitting voice input.

03How we use information

We use personal information for the following purposes:

• Creating and managing accounts, authenticating access and remembering learning preferences.
• Providing AI conversations, speech processing, translations, grammar and pronunciation feedback, roleplay and related learning features.
• Adapting practice to your selected language, goals, conversation context and estimated level.
• Maintaining history, displaying progress and providing learning certificates when you use those features.
• Processing purchases, managing subscriptions, confirming payments and handling billing questions or refunds.
• Providing support, investigating errors and responding to privacy requests.
• Maintaining service reliability, measuring feature performance and improving the learning experience.
• Detecting fraud, misuse and security incidents, protecting accounts and enforcing our service terms fairly.
• Sending essential account, purchase, security and service communications.
• Sending optional promotional communications or using optional measurement technologies subject to applicable notice, consent and opt-out requirements.
• Meeting legal obligations and establishing, exercising or defending legal claims.

We limit processing to information reasonably needed for the relevant purpose. A materially different use requires appropriate notice and a lawful basis before it begins, including consent where required.

04Legal bases for processing

Where applicable data-protection law requires a legal basis, we rely on the basis appropriate to each activity:

You can withdraw consent at any time. Withdrawal applies to future consent-based processing and does not make earlier processing unlawful. Reading this policy, registering an account or continuing to browse does not substitute for a separate consent required by law.

05AI conversations, voice processing and learning assessments

To provide an AI response or voice feature, we process the content you submit and the relevant context needed for that feature. This can include sending a message, voice input, transcript or relevant conversation history to providers of AI, speech recognition, speech synthesis or related technical services.

These providers process information needed to generate responses, perform speech functions and support the operation, security and reliability of those services. We restrict access to identifiable learning content to personnel and providers who need it for the purposes described in this policy, subject to appropriate confidentiality and data-protection obligations.

Generating a response, checking pronunciation and resolving a service problem are distinct processing purposes from training a general-purpose AI model. This policy does not grant unrestricted permission to use private conversations or voice recordings for unrelated model training. Any separate training use of identifiable content requires a clear explanation of that purpose, an appropriate legal basis and any consent required by applicable law before that use begins.

Learning assessments use information such as your responses, language choices and practice performance to estimate proficiency and suggest suitable practice. AI-generated corrections, scores and CEFR-aligned estimates can be inaccurate. They support language learning and are not decisions by PortuguesePal about admission, employment, credit or legal eligibility. You can contact us about an assessment or information you believe is incorrect.

06When information is disclosed

We disclose personal information only where relevant to the purposes described in this policy, including to:

• Service providers: Hosting, storage, technical infrastructure, AI and speech services, authentication, customer support, communications, security and analytics providers. The information disclosed depends on the function being provided.
• Payment providers: Information required to process purchases, manage recurring payments, prevent payment fraud and meet payment-related obligations.
• Professional advisers and legally authorized recipients: Information reasonably necessary for accounting, legal advice, compliance, a valid legal process, or protection of rights and safety, as permitted or required by law.
• Business transaction participants: Information necessary for a proposed or completed merger, financing, reorganization or transfer of the relevant business, subject to appropriate confidentiality and continued protection of personal information.
• Recipients you choose: Information you direct us to disclose, including information displayed through a certificate or other sharing feature you use.

Where a provider acts on our behalf, we require appropriate contractual restrictions on its processing. Providers acting independently, such as a payment provider carrying out its own fraud or regulatory checks, are responsible for that independent processing.

If your access is provided through a school, employer or other organization, the applicable organizational agreement and notice explain that organization's role and the learning information available to authorized administrators.

When you share a learning certificate or other result, its displayed information may become accessible to recipients and others with access to the shared page or file. Consider the information shown before sharing. Contact us for help removing a PortuguesePal-hosted public display. Copies already downloaded or independently shared by others may remain outside our control.

07Payments and subscriptions

Purchases are handled through the payment method and provider presented at checkout. Payment credentials are submitted through that payment process. We use the transaction and subscription information needed to activate paid access, manage billing, assist with refunds, prevent fraud and keep required business records.

Payment providers may retain their own records to meet legal, accounting, security and financial-compliance obligations. Account deletion does not require a provider to erase information it must lawfully retain for those purposes. Contact us if you need help understanding the payment information associated with your PortuguesePal account.

Clearing conversation history does not cancel a subscription. If you are deleting your account and also want to stop recurring billing, use the available subscription cancellation option or contact [email protected] so both requests can be addressed. Subscription cancellation, account deletion and refund eligibility are separate matters. Our Refund Policy explains refund conditions, subject to your mandatory legal rights.

08Cookies, analytics and privacy signals

Cookies and similar technologies can support sign-in, security, preferences and other requested functions. Optional technologies can help measure service usage, understand how people find PortuguesePal, evaluate campaigns or support advertising.

Where optional technologies are used, the relevant on-site notice or controls explain their purposes and choices. Where prior consent is required, we keep those technologies inactive until you choose to allow them. You can refuse or withdraw optional consent without disabling technologies genuinely necessary to provide a service you request.

You can use the cookie controls presented on the service and your browser's settings to manage relevant preferences. Browser settings can also clear stored cookies, although blocking necessary cookies may affect sign-in or other functions. Email [email protected] for assistance with your choices.

Advertising or measurement disclosures involving online identifiers, device information and browsing or conversion events may qualify as a “sale,” “sharing” or targeted advertising under some U.S. privacy laws, even when no money is exchanged. Where such disclosures take place, we provide applicable notices and opt-out controls. We assess the actual disclosure when applying these requirements, including disclosures described as analytics.

Where legally required, we recognize applicable browser-based opt-out signals, including Global Privacy Control, for the processing and browser or device to which the signal applies. A legacy “Do Not Track” setting is not treated as a substitute for a legally recognized privacy signal or a specific consent choice.

09How long we keep information

We retain personal information only for as long as needed for the purpose for which it was collected, or for another permitted purpose explained in this policy. Retention is determined by the feature you use, your deletion choices, the sensitivity of the information, security needs and applicable legal requirements.

When information is no longer needed, we delete it or make it no longer identifiable. Information that has been irreversibly anonymized may be retained for statistics or service evaluation; merely replacing your name with an identifier does not make information anonymous.

10Deleting messages, clearing history and deleting your account

Delete an individual message. Open your conversation history and use the deletion control for the message you want to remove. This lets you manage specific content without closing your account.

Clear all conversation history. Use the history-clearing option to remove all conversation records covered by that control. Clearing conversations does not close your account. Separate account, billing or learning-progress records may remain; you can request broader deletion if needed.

Delete and close your account. Use the account deletion option in your account controls. If you cannot sign in or complete the process, email [email protected]. We will verify the request as appropriate, close the account and delete or anonymize associated personal information unless a limited lawful retention ground applies.

These controls remove the relevant content from the available history or account and initiate the applicable deletion process. Deletion is not a promise that every copy disappears from every system at the same instant. Limited information may need to remain for legal compliance, necessary security investigations or legal claims. Where retained, access and use are restricted to the retention purpose, and we delete the information when that purpose ends.

Deleted information awaiting removal from backups is kept beyond ordinary use until it is overwritten or deleted. If a backup is restored, we reapply applicable deletion instructions. Where required, we also communicate valid deletion requests to providers and other recipients that received the information.

You do not need to close your account to request deletion of particular personal information. If only part of a request can be completed, we will explain the relevant limitation unless the law prevents us from doing so.

11Your privacy rights and how to exercise them

Depending on your location and the law that applies, you may have rights to:

• Learn whether we process your information and obtain access to it.
• Request correction of inaccurate or incomplete information.
• Request deletion, restriction, blocking or anonymization where applicable.
• Receive eligible information in a portable format.
• Withdraw consent and object to eligible processing.
• Opt out of applicable data sales, sharing, targeted advertising or certain profiling.
• Limit certain uses and disclosures of sensitive information.
• Request review of a decision on your privacy request.

You can object to direct marketing at any time. Use an unsubscribe option in a promotional message or email us. Essential account, transaction and security messages may still be sent when necessary.

To make a privacy request, email [email protected] and describe what you need. Where possible, use the email address associated with your account. We may ask for proportionate information to verify your identity or an authorized representative's authority. You do not need to open a new account to submit a request, and we will not request your password or complete payment-card number for this purpose.

We respond within the time required by applicable law. EEA and UK rights requests are generally handled within one month; applicable California requests to know, correct or delete are generally handled within 45 days. If a legally permitted extension is needed, we explain the reason and revised timeframe within the required period. Shorter or different local deadlines apply where required. Requests are ordinarily free; any lawful fee or refusal will be explained. We do not unlawfully discriminate against anyone for exercising privacy rights.

For an internal review of a privacy-request decision, reply to our response or email the same address with “Privacy Appeal” in the subject line. We will review the request and explain the outcome and any further rights required by applicable law.

EEA and United Kingdom. Applicable rights include access, correction, erasure, restriction, portability, withdrawal of consent and objection. You also retain the right to lodge a complaint with a competent data protection supervisory authority.

United States. Applicable state laws, including California law where it applies, may provide additional information, correction, deletion, opt-out, sensitive-information and appeal rights. The collection categories, sources, purposes and recipient categories are described above. Advertising-related disclosures and browser-based privacy signals are addressed in Section 8.

Brazil. Where the LGPD applies, rights may include confirmation and access, correction, information about shared use, portability, withdrawal of consent and anonymization, blocking or deletion of unnecessary, excessive or unlawfully processed data. Requests about automated processing can also be sent to our privacy contact.

Switzerland, Canada, Australia and other locations. We handle applicable access, correction, consent, deletion and privacy-concern requests according to the law that governs the relevant processing. No provision of this policy limits a right or remedy that applicable law makes mandatory.

12International processing

Cloudvale LLC is registered in the United States, and providing an international online service can involve processing information outside your country. This can include processing in the United States and in locations used by the providers supporting the feature you use. Privacy laws in another country may differ from those where you live.

Where international-transfer safeguards are required, we use a lawful transfer mechanism. Depending on the applicable law and recipient, this can include a recognized adequacy decision, approved contractual safeguards such as the European Commission's Standard Contractual Clauses, appropriate UK transfer arrangements, or another legally permitted mechanism. We do not rely on your use of the website as blanket consent to international transfers.

Contact [email protected] for information about processing locations relevant to your data and copies or details of applicable safeguards, subject to necessary protection of confidential information.

13Security

We maintain administrative, technical and organizational safeguards appropriate to the nature of the information and the risks of processing. These include measures for access control, secure transmission, protecting systems and responding to incidents.

No online service or storage system can guarantee absolute security. Please protect your login information and contact us promptly if you suspect unauthorized access. Where an incident triggers a legal notification obligation, we provide the required notifications within the applicable timeframe.

14Children and younger learners

Our general consumer service is not directed to children under 13. Where processing a child's information requires parental authorization or another specific legal safeguard, we require that safeguard before the relevant collection or use. A higher local age threshold applies where required by law.

A parent, guardian or authorized representative can contact [email protected] with questions about a child's information or to request appropriate access or deletion. If we become aware that information was collected without legally required authorization, we take appropriate steps to stop the affected processing and delete the information or otherwise resolve the issue lawfully.

An educational context or a child-friendly feature does not replace legally required notice, authorization or protection of children's information.

15Changes to this policy

We may update this policy to reflect changes in PortuguesePal, our processing activities or applicable requirements. We publish the revised policy on this page and update the date above.

For material changes affecting how personal information is handled, we provide appropriate notice through the service or another suitable channel. If a change requires new consent, we obtain it before carrying out the relevant processing. An update does not remove rights you have under applicable law.

16Contact PortuguesePal

For privacy questions, data access, correction, deletion, account closure or help with a privacy concern, contact:

?Privacy questions