PRIVACY POLICY

01. Who is responsible for your information?

For data-protection purposes, Learnest is provided by The Digital Creative Box Ltd, a company registered in England and Wales.

The Digital Creative Box Ltd is the controller of personal information processed through Learnest.

For privacy questions or requests, contact: hello@getlearnest.com

02. Who can use Learnest?

Learnest is intended for people aged 13 and over.

If you are below the minimum permitted age, you must not create a Learnest account or join the Learnest waitlist.

Where the law where you live requires permission from a parent or guardian, you should only use Learnest with that permission.

03. Information we collect

The information we collect depends on how you use Learnest.

3.1 Website and waitlist information

When you join the Learnest waitlist, we collect your email address and record whether you have separately chosen to receive ongoing marketing emails.

Our website hosting provider may also process limited technical information required to operate and secure the website, such as IP address, browser or device information and server logs.

3.2 Account information

When you create or use a Learnest account, we may process information including:

• name;
• email address;
• authentication and account identifiers;
• native language;
• learning language or languages;
• selected language variants, such as British or American English or Castilian or Latin American Spanish;
• learning level;
• learning preferences;
• daily learning target;
• information received from Apple or Google if you choose to sign in using those services; and
• other account information you choose to provide.

We do not need your precise location in order to provide the normal Learnest experience unless a feature specifically tells you otherwise.

3.3 Language-learning information

Learnest may process information about your learning activity, including:

• languages you are learning;
• CEFR level and progress;
• sentences, vocabulary and learning material studied or mastered;
• lessons and Topics completed;
• Study, Move and Cards activity;
• Level Test results and history;
• learning streaks;
• milestones and badges;
• league participation, ranking and points;
• learning statistics;
• AI Conversation activity and progress;
• pronunciation and speaking practice;
• daily learning goals; and
• other progress information required to provide the learning experience.

Where you learn more than one language, Learnest may retain separate progress information for each learning language.

Certain account-wide features, such as an overall learning streak, league position or account-level achievements, may combine eligible activity across more than one learning language.

3.4 My Topics and content you add

Learnest allows you to create your own learning Topics and add material relevant to what you want to learn.

Depending on the feature you use, we may process:

• Topics you create;
• sentences or vocabulary you enter;
• translations;
• learning material generated for you;
• edits or corrections you make;
• photos you upload for the purpose of extracting learning content;
• text extracted from uploaded material; and
• other learning content you choose to save.

If you photograph material such as a menu, sign, book page or other real-world content, you are responsible for ensuring you are entitled to upload and use that material.

Where Learnest processes a photograph solely to extract text, the original image may be processed temporarily for that purpose.

3.5 Voice, pronunciation and AI Conversation

Some Learnest features involve speaking, listening and conversation practice.

Depending on the feature, Learnest or selected service providers may process:

• speech or audio you submit;
• transcriptions of your speech;
• pronunciation information;
• conversation content;
• language corrections;
• feedback generated from your conversation;
• selected voice or language variant; and
• technical information required to provide voice features.

Where recordings are not intended to be stored after processing, they may still be processed temporarily by the relevant service provider to provide the requested feature.

3.6 Usage and activity information

We may process information about how you use Learnest, including:

• lessons studied;
• learning modes used;
• downloaded lessons;
• Topics accessed;
• favourites or saved content;
• recent activity;
• streaks and progress;
• league activity;
• milestones and badges;
• feature usage;
• notification preferences; and
• information required to maintain your learning progress.

3.7 Technical and diagnostic information

We may process technical information such as device and app information, installation identifiers, diagnostic data and crash information.

Firebase Crashlytics may be used to help identify and diagnose app crashes.

3.8 Notifications

If you enable notifications, Firebase Cloud Messaging may process device or installation identifiers and notification-related information required to deliver notifications to your device.

Notifications may include learning reminders, streak information, progress prompts, league updates or service messages.

Where available, league-related notifications can be controlled separately from league participation.

You can change notification permissions through Learnest and/or your device settings.

3.9 Subscription information

Subscriptions are processed through the Apple App Store or Google Play.

Learnest may receive information such as your subscription status, entitlement, transaction or purchase identifiers and renewal status.

We do not receive or store your full payment-card details where your purchase is processed by Apple or Google.

04. How we use your information

We use personal information to:

• create and manage your account;
• provide the Learnest service;
• maintain your language-learning progress;
• determine and display your CEFR learning position;
• provide lessons, Topics, sentences and flashcards;
• provide Study, Move and Cards functionality;
• provide AI Conversation and speaking practice;
• provide pronunciation and language feedback;
• generate learning material relevant to your chosen language and level;
• process My Topics;
• extract learning content from material you upload;
• provide Level Tests and retain results;
• maintain streaks, milestones, badges and statistics;
• operate leagues and rankings where you participate;
• enable switching between multiple learning languages;
• maintain downloaded/offline learning content;
• send notifications you have chosen to receive;
• manage subscriptions and paid access;
• provide customer support;
• improve the reliability and security of Learnest;
• diagnose technical problems;
• prevent misuse, fraud or abuse;
• communicate with you about the service; and
• send marketing where you have specifically agreed to receive it.

05. Our lawful bases

Depending on the processing involved, we rely on one or more lawful bases:

• Contractual Necessity: We generally process information necessary to create your account and deliver Learnest because it is necessary to provide the service you have requested.
• Legitimate Interests: We may rely on our legitimate interests where reasonably necessary to operate, secure, troubleshoot and improve Learnest, provided those interests do not override your rights and interests.
• Consent: We rely on consent for activities requiring consent, including optional marketing communications.
• Legal Obligation: We may process information where necessary to comply with a legal obligation.

06. Artificial intelligence

Learnest uses artificial intelligence to provide certain language-learning features. These may include:

• AI Conversation;
• generating sentences and learning material;
• creating material within My Topics;
• analysing or responding to learner input;
• language correction and feedback;
• adapting content to the learner's selected language and level; and
• processing imported material for learning purposes.

Relevant learning context may be sent to selected AI service providers where necessary to provide the requested feature. We aim to send only information reasonably relevant to the feature being provided rather than unnecessarily sending unrelated account information.

AI-generated language content may occasionally contain errors and should be used as a learning aid rather than treated as infallible.

07. Voice and audio services

Learnest uses selected third-party services to provide voice, narration, pronunciation, speech recognition and/or conversation functionality.

Relevant text, audio, language selection and other information required to provide those features may be processed by those providers.

08. Who we share information with

We use selected third-party service providers to operate, maintain and improve Learnest. These may include providers of:

• artificial intelligence services;
• speech recognition and conversational AI;
• AI voice and narration;
• translation or language-processing technology;
• app hosting, database and technical infrastructure;
• crash reporting, diagnostics and performance monitoring;
• push notifications;
• authentication and account sign-in;
• subscription and payment processing;
• email, waitlist and marketing communications;
• website hosting; and
• other technical services required to operate and secure Learnest.

These providers may process personal information on our behalf where necessary to provide their services to Learnest and subject to appropriate contractual and data-protection safeguards.

We may also disclose information where required by law or where reasonably necessary to protect our legal rights, our users or the security of Learnest.

09. International processing

Learnest is designed for users internationally and some of the providers we use operate in multiple countries.

This means personal information may sometimes be processed outside the United Kingdom.

Where applicable data-protection law requires safeguards for an international transfer, we use appropriate recognised safeguards, contractual protections or other lawful transfer mechanisms.

You can contact us at hello@getlearnest.com if you would like further information about international transfers that apply to your information.

10. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including to provide Learnest, maintain learning progress, comply with legal obligations, resolve disputes and protect the service.

While your account remains active, information such as your learning languages, levels, progress, Topics, Level Test history, milestones, badges, league information and other learning records may be retained so that Learnest can preserve your learning journey.

Waitlist-only information is retained for as long as reasonably necessary to administer the waitlist and launch communications.

Marketing information is normally retained until you unsubscribe or otherwise withdraw your consent.

If you unsubscribe from marketing, we may retain limited information on a suppression list to ensure that we respect your choice.

11. Account deletion

You can initiate account deletion through Learnest.

When you request deletion, the deletion process is initiated and personal data associated with your account in our active production database and application systems will be deleted as part of that process, unless we are legally required or otherwise lawfully permitted to retain particular information.

Residual copies may remain temporarily in backups, security logs or other protected systems until they are overwritten or removed through normal retention cycles.

We may retain limited records where necessary for legal, accounting, fraud-prevention, security or dispute-resolution purposes.

Deleting a Learnest account does not necessarily cancel an active Apple App Store or Google Play subscription. Subscriptions must also be managed through the relevant store.

12. Marketing emails

Joining the Learnest waitlist does not require you to agree to ongoing marketing.

If you separately choose to receive marketing emails, we may send you Learnest product news, learning content, new features, offers and similar marketing communications.

You can unsubscribe at any time.

Marketing consent is optional and is kept separate from joining the waitlist or using Learnest.

13. Cookies and website tracking

If non-essential tracking technologies are introduced, any consent controls required by law will be implemented.

14. Your rights

Depending on where you live and the circumstances, you may have rights relating to your personal information, including rights to:

• access information we hold about you;
• correct inaccurate information;
• request deletion;
• restrict certain processing;
• object to certain processing;
• withdraw consent where we rely on consent; and
• receive certain information in a portable format where applicable.

You can exercise your rights by contacting: hello@getlearnest.com

If you are in the United Kingdom, you also have the right to complain to the Information Commissioner's Office.

If you live elsewhere, you may also have rights under your local privacy law.

15. Security

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, alteration, misuse or disclosure.

However, no online service can guarantee absolute security.

16. Changes to this Privacy Policy

We may update this Privacy Policy where Learnest, our technology or applicable law changes.

Where a change is significant, we will take reasonable steps to bring it to your attention.

The latest version will display the date it was updated.

17. Legal information and contact

Learnest is provided by:

The Digital Creative Box Ltd
Company number 07769016
Registered in England and Wales

Registered office:
c/o Sempar Accountancy and Tax Limited
Office 2.026, Innovation Centre 7
Keele University, Keele, Staffordshire, ST5 5NU, United Kingdom