Privacy Policy

Introduction

Welcome to ULO AI Learn (the "App"), a mobile language-learning application that helps you practice speaking, translate text and voice, complete role-play scenes, and follow a personalised learning roadmap using AI-assisted features.

Cyborgate ("we," "us," or "our") operates the App. This Privacy Policy explains what information we collect, how we use it, who we share it with, and the choices available to you.

By installing or using the App, you agree to the practices described in this policy. If you do not agree, please do not use the App. Your use is also governed by our Terms of Use (EULA).

Summary of Data Practices

• Learning on your device: Profile preferences, roadmap progress, streaks, and free-access timers are stored primarily on your device.
• AI features (Google Gemini): When you use Tutor, Translate, Role-play, quizzes, pronunciation, or related AI features and you have given permission in the App, the text and voice transcripts you submit (plus language preferences needed for the request) are sent to Google Gemini (Google LLC) to generate responses. See Section 5.
• Analytics: We use Firebase Analytics (Google) for app usage events (for example opens, screens, onboarding, paywall views).
• Payments: Subscriptions are processed by Apple. We do not receive your full payment card details.
• We do not sell your personal information.
• Photo library: The App does not provide photo-based translation features. A photo-library purpose string may appear because a system library references related APIs; the App does not request photo access for learning features.

Information We Collect

3.1 Information you provide

• Profile & preferences: Display name, bio, native language, learning language, level, daily goal, and interests.
• Learning content: Text you type into the tutor, translate, or role-play flows.
• Voice input: When you grant microphone and speech recognition permission, audio may be converted to text on-device or via system services and used as learning content.

3.2 Information collected automatically

• Device & technical data: Device type, operating system version, app version, language settings.
• Usage analytics: Events such as app open, screen views, onboarding steps, paywall views, and feature opens via Firebase Analytics.
• Local activity: Lesson completion, streaks, free-access time used, and similar progress data stored on-device.

3.3 Purchases & subscriptions

If you subscribe to Pro, Apple processes payment. We receive entitlement status (whether Pro or trial is active) so we can unlock features. We do not store your full card number or Apple ID password.

3.4 Permissions

• Microphone — for voice practice and live translation when you enable those features.
• Speech recognition — to convert speech to text for learning features.
• Notifications — optional practice reminders if you allow them.

You can revoke permissions anytime in iOS Settings → ULO AI Learn.

How We Use Information

• Provide AI tutoring, translation, quizzes, role-play, and progress tracking.
• Save preferences and learning progress on your device.
• Process and restore App Store subscriptions and free trials.
• Measure product usage and improve quality, safety, and performance.
• Send optional local practice notifications if enabled.
• Respond to support requests and enforce our Terms.

Third-Party AI Service (Google Gemini)

ULO AI Learn uses a third-party artificial intelligence service to power learning features. Before any personal content is shared with that service, the App explains what is sent, who receives it, and asks for your permission. You can decline; AI features that require processing will not run until you allow sharing.

5.1 Who receives the data

• Provider: Google LLC
• Service: Google Gemini API (generative AI models)
• Data is transmitted over the internet to Google's systems so the model can return tutoring replies, translations, quizzes, role-play dialogue, pronunciation tips, and similar feature output.

5.2 What data is sent

Only when you use an AI feature and have consented, we may send:

• Text you type in Tutor chat, Translate, Role-play, free talk, or similar fields.
• Voice transcripts (speech converted to text when you use microphone / speech recognition) for the same features.
• Context needed for the request, such as source and target language, learning level, lesson or scenario title, and recent messages in the same session so replies stay on-topic.

We do not intentionally send your payment card details, Apple ID password, or full device contact list to Google Gemini. Do not put passwords, government IDs, health or financial secrets, or other highly sensitive data into chat, translate, or voice fields.

5.3 How that data is used

• To generate translations, tutor messages, fill-in-the-blank quizzes, role-play dialogue, hints, and pronunciation guidance you requested.
• Processing is limited to delivering the feature you invoked. We do not sell your learning content to third parties for advertising.

5.4 Permission & your choices

• The App requests your permission before sharing personal content with Google Gemini. You may accept or decline.
• If you decline, AI-powered features that depend on Gemini will not process your submissions until you allow sharing (for example via the in-app prompt or Settings, where available).
• You can stop using AI features at any time. Revoking microphone or speech permissions in iOS Settings stops new voice capture.

Google processes data under Google's terms and privacy practices for the Gemini API. Learn more at Google Gemini API Terms and Google Privacy Policy. We expect service providers we use for this purpose to provide protection consistent with applicable requirements for the processing they perform.

Sharing of Information

We may share information with:

• Google LLC (Google Gemini API) — text and voice transcripts you submit for AI features, plus language/session context needed to generate responses, only after you grant permission in the App (see Section 5).
• Google Firebase Analytics — usage events (for example app opens, screens, onboarding, paywall views) to measure product performance.
• Hosting / infrastructure providers that help operate our services, under terms that limit use to providing their service.
• Apple for App Store billing, subscriptions, and platform services.
• Authorities when required by law or to protect rights, safety, and security.

We do not share your learning content for third-party advertising profiles, and we do not sell personal information.

Storage & Retention

Profile and learning progress are primarily stored on your device. Analytics data is processed by Google Firebase according to Google's policies. Server-side logs used for reliability may be retained for a limited period, then deleted or anonymized. Subscription-related records may be kept as required for accounting, fraud prevention, and legal compliance.

Children's Privacy

The App is not directed to children under 13 (or the minimum age required in your region). We do not knowingly collect personal information from children under that age. If you believe a child has provided personal information, contact us at support@cyborgate.com and we will take appropriate steps.

Your Choices & Rights

• Change language and profile settings in the App.
• Reset local profile data in Settings (where available).
• Revoke microphone, speech, or notification permissions in iOS Settings.
• Manage or cancel subscriptions in Settings → Apple ID → Subscriptions.
• Allow or decline sharing content with Google Gemini when prompted (required for AI features).
• Contact us at support@cyborgate.com for privacy questions or data requests.

Depending on your region (including the EEA, UK, and California), you may have rights to access, correct, delete, or restrict certain personal data we hold about you.

Security

We use reasonable technical and organizational measures to protect information. No method of transmission or storage is 100% secure. Please protect your device with a passcode and keep the App updated.

International Users

If you use the App from outside the country where our servers or providers operate, your information may be processed in other countries that may have different data protection laws. Where required, we take steps to protect transfers of personal data.

Third-Party Services

The App may use third-party services subject to their own privacy policies, including:

• Apple — App Store, StoreKit subscriptions, device speech / system services.
• Google LLC — Gemini API — generative AI for tutoring, translation, role-play, quizzes, and related features (see Section 5). Gemini API Terms · Google Privacy Policy
• Google Firebase Analytics — usage analytics.

Changes to This Policy

We may update this Privacy Policy from time to time. We will revise the "Last Updated" date at the top of this page. Continued use of the App after changes means you accept the updated policy.

Contact Us

Cyborgate
App: ULO AI Learn (com.cyborgate.aitutor)
Email: support@cyborgate.com
General: contact@cyborgate.uk

Related: Terms of Use (EULA)