Effective Date: July 25, 2026

Thank you for using Fluent Ear (“we”, “our”, or “us”).

We take your privacy seriously. This Privacy Policy explains how we collect, use, store, share, and protect information when you use the Fluent Ear app (the “App”).

Depending on how you use the App and which features you enable, we may collect or process the following categories of information:

This may include information you choose to enter into the App, such as:

• Email address and account credentials
• Display name or profile details
• Learning preferences and settings (for example daily goals, lesson difficulty, voice preferences)
• Phrases, nouns, verbs, notes, and other learning content you add
• Family or speaker labels you create (for example names you assign to voice-note speakers)
• Feedback, support messages, or survey responses

If you use voice-note or related features, we may process:

• Audio recordings or files you upload (for example mp3 or m4a voice memos)
• Transcripts and translations generated from that audio
• Extracted phrases, quiz content, and related learning results
• Lesson progress, comprehension ratings, listening history, and practice activity

Some data may also be stored locally on your device, including:

• Offline lesson packs or cached audio
• Local preferences and settings
• Temporary files used for upload, playback, or offline practice

To provide cloud features and sync across devices, we may collect and securely store information such as:

• Email address
• Account identifier
• Authentication tokens or login-related identifiers
• Secure copies of your app data (including learning progress, phrase banks, and voice-note results)
• Device identifiers reasonably necessary for syncing, fraud prevention, or account security

To maintain, secure, and improve the App, we may collect limited technical data such as:

• App version
• Device type and model
• Operating system version
• Language and region settings
• Crash logs
• Performance diagnostics
• Anonymous or aggregated usage analytics
• Error reports
• Push notification tokens (if notifications are enabled)

We do not use this information to personally identify you unless reasonably necessary for support, security, fraud prevention, or legal compliance.

We may use your information to:

• Provide, operate, and maintain the App
• Create and manage your account
• Save and display your lessons, progress, phrase banks, and related learning data
• Process voice notes (including transcription, translation, phrase extraction, and quiz generation)
• Sync your data across devices
• Personalise learning features and preferences you choose
• Improve App features, performance, reliability, and security
• Provide customer support and respond to requests
• Prevent abuse, fraud, unauthorised access, or misuse
• Comply with legal obligations
• Enforce our terms, policies, and legitimate business protections

We do not sell your personal data.

Certain features of the App use artificial intelligence and related processing services to support learning, including:

• Speech-to-text transcription of uploaded audio
• Translation between Spanish and English
• Extraction of useful phrases, vocabulary, or practice items
• Generation of comprehension questions or quizzes
• Other AI-assisted learning help that may be introduced over time

When you upload or submit audio or text for these features:

• We process that content to provide the feature you requested
• Processing may be performed by trusted third-party AI providers acting on our behalf
• AI-generated output may be incomplete, inaccurate, or imperfect and is provided for language-learning support only

We do not use your personal learning content to sell advertising.

If we introduce AI-powered features that process your data in a materially new way, we may update this Privacy Policy and, where required, request any necessary consent.

The App may now or in the future use trusted third-party service providers and integrations to support functionality such as:

• Cloud hosting and secure storage
• Authentication / sign-in
• Database and file storage
• AI transcription, translation, and language-processing services
• Subscription billing and in-app purchases
• Crash reporting and diagnostics
• Product analytics
• Customer support tools
• Email delivery
• Push notifications
• Security and fraud prevention

Examples may include:

• Apple services, including App Store billing and related Apple platform services
• Supabase (authentication, database, and storage)
• OpenAI or similar AI providers (for transcription, translation, and learning assistance)
• Cloud infrastructure providers
• Subscription and billing platforms
• Analytics and crash-reporting tools
• Customer support and communications tools

We may share information with such providers only to the extent reasonably necessary for them to perform services on our behalf, subject to appropriate contractual, technical, or organisational safeguards where applicable.

If we introduce additional material third-party services, we may update this Privacy Policy accordingly.

We believe your data belongs to you.

Where available, we may provide tools that allow you to:

• Access your stored data
• Update profile and preference information
• Delete individual phrases, speakers, or learning items
• Delete your account and associated cloud-stored data
• Manage permissions on your device (for example microphone or file access, if used)
• Request deletion of cloud-stored data

If you need help managing or deleting your data, contact us using the email below.

We do not sell your personal data.

We may disclose or share limited information in the following circumstances:

• With service providers and processors that help us operate the App
• With AI and cloud providers needed to deliver features you use (such as transcription or storage)
• If required by law, legal process, or regulatory request
• To protect our rights, security, systems, users, or the public
• In connection with a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction (subject to applicable law)

We may also use or disclose aggregated, de-identified, or anonymised information where permitted by law.

Voice notes and other audio you upload may contain personal or sensitive information about you or other people.

You are responsible for only uploading content you have the right to upload and process.

We handle uploaded audio and derived transcripts with care and use them only to provide the features you request or enable.

We do not use your uploaded audio for advertising or sell it to third parties.

We retain data only for as long as reasonably necessary to:

• Provide the App and requested features
• Maintain backups or syncing
• Resolve disputes
• Enforce agreements
• Detect fraud or abuse
• Meet legal, tax, accounting, or regulatory obligations

Locally cached or offline data on your device is controlled primarily by you and your device settings.

Cloud account data may remain stored until you delete it, request deletion, or as otherwise required for legal, security, fraud-prevention, backup, or operational purposes.

We use reasonable administrative, technical, and organisational safeguards designed to protect your information.

However, no method of electronic storage, transmission, or internet-connected service is 100% secure, and we cannot guarantee absolute security.

The App is not intended for children under the age required by applicable law to consent to data processing in their jurisdiction, and we do not knowingly collect personal information from children in violation of applicable law.

If you believe a child has provided us with personal information unlawfully, please contact us and we will take appropriate steps.

If you use the App outside the country where our services or providers are located, your information may be processed in other jurisdictions that may have different data protection laws.

Where required, we will take appropriate steps to protect personal data in accordance with applicable law.

Depending on where you live, you may have rights under applicable law, including rights to:

• Access your personal data
• Correct inaccurate information
• Delete your personal data
• Export or receive a copy of your data
• Restrict or object to certain processing
• Withdraw consent where processing is based on consent

To exercise these rights, please contact us using the email below.

We may update this Privacy Policy from time to time.

When we do:

• The “Effective Date” above will be revised
• Material changes may be communicated through app updates, in-app notices, or other appropriate methods
• Changes will be made in accordance with applicable laws and platform requirements

If you have any questions, requests, or concerns about this Privacy Policy, please contact us at:

📧 fluentear@crimson.global

You can request deletion of the data associated with your Fluent Ear account at any time.

1. Open Fluent Ear
2. Go to Settings
3. Tap Delete Account / Delete My Data
4. Confirm the deletion when prompted

1. Email fluentear@crimson.global from the email address linked to your account
2. Use the subject line: “Delete my Fluent Ear account”
3. Include the email address used to sign in
4. We will process your request and confirm once deletion is complete

Deleting your account / data will permanently remove data stored by Fluent Ear for your account, including (where applicable):

• Your account and profile information
• Lesson progress and listening history
• Comprehension ratings and related learning stats
• Phrase, noun, and verb banks you created
• Family / speaker labels you created
• Uploaded voice notes and derived transcripts, translations, phrases, and quizzes
• Preferences and settings stored with your account

This action cannot be undone.

• Deleting your Fluent Ear account removes data stored by Fluent Ear
• It does not automatically remove copies cached only on your device until you uninstall the app or clear local app data
• It does not delete data held solely by third-party providers under their own independent records (for example Apple account billing history)
• If you granted microphone, file, or notification permissions, you can also revoke those in your device settings

If you have any trouble deleting your data, contact us at:

📧 fluentear@crimson.global

Effective Date: July 25, 2026

These Terms of Use (“Terms”) govern your access to and use of the Fluent Ear mobile application, website, and related services (collectively, the “Service”).

The Service is provided by Crimson Global Ltd (Company No. 14018900), a company registered in England and Wales, with registered office at County Hall, Belvedere Rd, London SE1 7PB, United Kingdom (“Crimson Global”, “we”, “our”, or “us”).

By downloading, accessing, or using Fluent Ear, you agree to be bound by these Terms. If you do not agree, do not use the Service.

You must be at least the age required by applicable law in your jurisdiction to use the Service and to consent to data processing.

If you are under the age of majority in your jurisdiction, you may only use the Service with the involvement and consent of a parent or legal guardian, where permitted by law.

Fluent Ear is a language-learning tool designed to help users improve listening comprehension and vocabulary through audio lessons, practice, progress tracking, and related learning features.

The Service may include features such as:

• Daily or structured listening lessons
• Audio playback, transcripts, and translations
• Comprehension questions and quizzes
• Phrase, noun, and verb banks
• Voice-note upload and AI-assisted processing
• Progress tracking and learning statistics
• Offline lesson access or cached content
• Optional AI-assisted learning help
• Optional subscriptions or premium features

Features may change over time and may vary by device, platform, location, or subscription tier.

Fluent Ear is an educational support tool for personal language learning.

The Service is provided for general informational and educational purposes only. It is not:

• An accredited school, college, or official language course
• A guarantee of fluency, exam success, or professional certification
• Immigration, legal, medical, or professional interpreting advice
• A substitute for qualified teachers, tutors, or formal language study where those are required

AI-generated transcripts, translations, explanations, and quizzes may contain errors. You remain responsible for how you use the content in real conversations or formal settings.

Many features of the Service require you to create an account and sign in.

If you create an account, you agree to:

• Provide accurate and current information
• Keep your login credentials secure
• Notify us promptly of unauthorised use or suspected security issues
• Accept responsibility for activity occurring under your account, except where prohibited by law

We may suspend or terminate access where reasonably necessary for security, fraud prevention, abuse prevention, legal compliance, or violations of these Terms.

Subject to these Terms, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to download, install, and use the Service for your personal, non-commercial use.

You may not:

• Copy, modify, adapt, or create derivative works from the Service except as permitted by law
• Reverse engineer, decompile, or disassemble the Service except where prohibited from restricting this by law
• Use the Service unlawfully or fraudulently
• Interfere with the security, integrity, or operation of the Service
• Use the Service to violate the rights of others
• Scrape, harvest, or bulk-extract content from the Service except as expressly allowed

You may enter, upload, or generate data within the Service, including profile details, learning progress, phrase banks, speaker labels, voice notes, and related information (“User Content”).

You retain ownership of your User Content, subject to the rights necessary for us to operate the Service.

By using the Service, you grant us a limited licence to host, store, process, transmit, display, and otherwise use your User Content solely as reasonably necessary to:

• Provide and operate the Service
• Sync and back up your data
• Transcribe, translate, analyse, and generate learning materials from content you submit
• Maintain security, reliability, and functionality
• Comply with law and enforce these Terms

You are responsible for the accuracy, legality, and appropriateness of the User Content you provide.

You must not upload audio or other content that you do not have the right to upload, including content that unlawfully records other people or infringes someone else’s rights.

The Service may include current or future AI-assisted features, such as:

• Speech-to-text transcription
• Translation
• Phrase extraction
• Quiz or comprehension-question generation
• Explanations or learning suggestions
• Progress insights

Any AI-generated output is provided for language-learning support only and may be incomplete, inaccurate, delayed, or inappropriate for your circumstances.

You are solely responsible for deciding whether and how to rely on any AI-generated output.

The Service may integrate with or rely on third-party services, platforms, or providers, including current or future services such as:

• Apple App Store
• Cloud hosting and database providers (including Supabase)
• AI providers (including OpenAI or similar services)
• Analytics providers
• Crash reporting tools
• Authentication providers
• Subscription billing providers
• Customer support or communications tools

Your use of third-party services may also be subject to their own terms, privacy policies, and rules.

We are not responsible for:

• Third-party services
• Their availability
• Their accuracy
• Their data practices
• Their security
• Their acts or omissions

Some features of the Service may require a paid subscription or in-app purchase.

If you subscribe through the Apple App Store, billing, payment processing, subscription management, cancellations, and refunds are generally handled by Apple, subject to Apple’s terms and policies.

Unless otherwise stated:

• Subscriptions may automatically renew
• Renewal may occur unless cancelled before the applicable renewal date
• You can manage or cancel subscriptions in your Apple account settings

We may change pricing, features, or subscription offerings at any time, subject to applicable law and platform rules.

We may modify, update, suspend, restrict, or discontinue any part of the Service at any time, with or without notice, to the extent permitted by law.

We do not guarantee that the Service, or any feature, integration, or content, will always be available, uninterrupted, error-free, or compatible with all devices or operating systems.

You agree not to use the Service to:

• Violate any law or regulation
• Infringe the rights of others
• Upload unlawful, abusive, threatening, defamatory, obscene, or harmful content
• Upload audio or personal information about others without appropriate rights or permission
• Attempt to gain unauthorised access to accounts, systems, or data
• Interfere with the Service or its infrastructure
• Use the Service in a manner that could create legal liability for us or others

We do not guarantee that use of the Service will:

• Make you fluent
• Improve comprehension by any specific amount
• Guarantee exam, school, work, or immigration outcomes
• Produce perfect transcripts or translations
• Match every dialect, accent, or speaking style
• Achieve any specific language-learning result

Individual results vary, and results are not guaranteed.

To the fullest extent permitted by law, the Service is provided on an “as is” and “as available” basis.

To the fullest extent permitted by law, we disclaim all warranties, whether express, implied, statutory, or otherwise, including implied warranties of:

• Merchantability
• Fitness for a particular purpose
• Non-infringement
• Accuracy
• Reliability
• Availability
• Quiet enjoyment

Nothing in these Terms excludes any warranty that cannot lawfully be excluded.

To the fullest extent permitted by law, Crimson Global Ltd and its directors, officers, employees, contractors, affiliates, licensors, and service providers shall not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or any loss of:

• Data
• Profits
• Revenue
• Business
• Goodwill
• Opportunity
• Use

arising out of or relating to the Service, even if advised of the possibility of such damages.

To the fullest extent permitted by law, our total aggregate liability arising out of or relating to the Service shall not exceed the greater of:

• The amount you paid us (if any) for the Service in the 12 months before the claim arose; or
• £50 GBP

Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited under applicable law, including liability for fraud, fraudulent misrepresentation, or death or personal injury caused by negligence where applicable.

To the extent permitted by law, you agree to indemnify and hold harmless Crimson Global Ltd and its directors, officers, employees, contractors, affiliates, licensors, and service providers from and against claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or related to:

• Your misuse of the Service
• Your violation of these Terms
• Your violation of applicable law
• Your infringement of the rights of any third party
• Content you upload or submit to the Service

You may stop using the Service at any time.

We may suspend or terminate your access to the Service, with or without notice, where reasonably necessary for:

• Security
• Fraud prevention
• Abuse prevention
• Legal compliance
• Protection of users or systems
• Violations of these Terms

Sections that by their nature should survive termination will survive, including those relating to ownership, disclaimers, liability, indemnity, governing law, and dispute resolution.

These Terms are governed by the laws of England and Wales, excluding conflict of law principles.

If a dispute arises out of or in connection with these Terms or the Service, the courts of England and Wales shall have exclusive jurisdiction, except where mandatory consumer protection laws in your place of residence provide otherwise.

We may update these Terms from time to time.

When we do:

• The “Effective Date” above will be revised
• Material changes may be communicated through app updates, in-app notices, website updates, or other appropriate means

Your continued use of the Service after updated Terms become effective means you accept the updated Terms, to the extent permitted by law.

If you have questions about these Terms, please contact us at:

📧 fluentear@crimson.global

Copyright © 2026 Peter-Joshua Davies, Crimson Global - All rights reserved