1. Controller and contact
The final legal entity, postal addresses, privacy contact, EU representative where required, and Brazilian data-protection contact must be supplied before this notice becomes effective.
2. Data we intend to process
Account identifiers, versioned consent and age attestations, learning attempts, mastery and review records, preferences, device and security events, support reports, and reconciled subscription status. Voice audio is transient. Sayora does not retain the birth date entered into the age check.
3. Why we process it
To provide and secure the service, synchronize progress, calculate reviews and entitlements, respond to requests, comply with law, and—only after explicit consent—run nonessential analytics or AI-assisted feedback. Applicable GDPR and LGPD legal bases require counsel confirmation by purpose and market.
4. Retention
Raw audio is deleted immediately after processing and never kept beyond 24 hours. Transcripts and raw AI conversation payloads expire after 30 days; export archives after seven days; security logs after 90 days; encrypted backups after 35 days. Learning summaries remain until deletion. Billing and immutable administrative records may be retained for up to seven years, subject to counsel-approved requirements.
5. Providers and international transfers
Planned subprocessors include infrastructure, authentication, AI, billing, email, notification, security, and consented analytics providers. A final subprocessor list, processing locations, transfer safeguards, and regional hosting commitments must be published before launch.
6. Analytics and sensitive learning data
Nonessential analytics stays off until you opt in. Answers, recordings, transcripts, and inferred weaknesses are not sent to analytics or crash-reporting providers.
7. Your choices and rights
Depending on your location, you may request access, correction, portability, deletion, restriction, objection, consent withdrawal, or an appeal. Use the Privacy center for authenticated requests. A final regulator and complaint-contact list requires regional legal review.
8. Age eligibility and changes
Sayora is not offered to people under 16 at launch. Material notice changes will receive a new version and appropriate notice or renewed consent where required.