PRIVACY POLICY
This Privacy Policy outlines how APERION LABS LIMITED ("we," "us," or "our") collect, use, and disclose your personal information when you use any of our mobile applications available on the Apple App Store (collectively, the "Apps") and related services. It also explains your privacy rights and the legal protections afforded to you. We are committed to safeguarding the personal information of our users and their contacts.
By using any of our Apps or services, you consent to the collection, use, sharing, and processing of your personal information as described in this policy. We use your personal data to enhance and deliver our services effectively.
PERSONAL INFORMATION COLLECTED
Types of Data Collected:
Personal Information User Provide
Our Service automatically gathers data when you interact with it, enabling us to better understand your needs and enhance your experience.
Microphone Audio: We collect and access the device microphone only when you actively start a voice-based lesson or free-talk session. Audio captured from the microphone is processed through Apple’s speech recognition framework solely to convert your speech into text. Raw microphone audio is not uploaded to, stored on, or retained by Nativibe’s servers. Only the resulting text transcript is transmitted to Nativibe’s server for AI tutor processing, such as understanding your response and generating appropriate feedback or conversation replies.
Speech Transcription Text: We may generate and store text transcripts from your spoken English through Apple Speech Recognition (SFSpeechRecognizer). The resulting transcript is transmitted to Nativibe’s chat backend solely as input for the AI tutor to process the current conversation turn, evaluate your response, and generate the next message or learning feedback.
Image/Photo: We collect images, photos selected and uploaded by you and transmitted to AWS S3 through a secure, temporary presigned URL for profile-related features. These images are stored solely for the purpose of displaying and managing your profile image and related functions within the App. The App does not upload photos unless you actively select and submit them.
Email Address: We collect and store on servers your email address for account registration, authentication, account management, and account recovery purposes. Where you sign in using Apple Sign In, the email address provided may be either your actual email address or an Apple Private Relay address (e.g., @privaterelay.appleid.com) generated by Apple to help protect your privacy.
Information Collected Automatically
Firebase Crashlytics: We automatically collect and transmit crash reports, non-fatal error information, and related technical diagnostics through Firebase Crashlytics solely for application stability monitoring, troubleshooting, and identifying issues that may affect app performance and your experience.
IDFA (ATT): We collect and store on servers the device’s Advertising Identifier (IDFA), where you have granted permission through Apple’s App Tracking Transparency (ATT) framework, and share such identifier with attribution and advertising partners, such as Adjust and Facebook, solely for advertising attribution, campaign measurement, performance analytics, and related advertising features.
Local Cached: We collect and store automatically limited cache data locally on your device through SwiftData, including status information, URLs, and timestamps, solely to support app functionality, loading performance, and local state management. This information is stored locally on your device and is not transmitted to our servers.
User Preferences: We collect automatically and store your preference and app state information locally on your device through UserDefaults, including onboarding status, session count, and first launch date, solely to personalize the in-app experience, maintain app state, and avoid repeating completed setup steps. This information is stored locally and is not transmitted to our servers.
Cookies: Our services utilize cookies to collect information to enhance user experience, understand user engagement and improve our services.
Data Obtained from Third Parties
Firebase Analytics: We collect information related to your interactions, screen views, and app events, solely to understand app usage patterns, evaluate feature performance, improve your experience, and support analytics-related features.
Firebase Remote Config: We collect remote configuration values from Firebase Remote Config solely in order to dynamically manage and adjust app behavior, including onboarding flows, feature settings, use case configurations, and other app experience parameters, without requiring an app update.
Adjust SDK: We collect information about attribution and analytics data through the Adjust SDK for purposes such as install attribution, campaign measurement, revenue tracking, deferred deep linking, and related performance analytics. Where applicable, the device IDFA is accessed and used only after you grant Apple’s App Tracking Transparency permission.
Facebook SDK (FBSDKCoreKit): The App may collect analytics and attribution-related data through the Facebook SDK (FBSDKCoreKit), including automatically logged app events, advertiser identifier information, and deep link data, solely to support app event analytics, advertising attribution, campaign performance measurement, and related functionality.
User ID: We can collect and store on servers a stable unique user identifier from third-party sign-in providers, such as Apple or Google, when you sign in through those services. This identifier, such as Apple sub or Google sub, is used solely as the primary account key in our backend system to create, authenticate, and manage your account consistently across sessions.
Authentication Tokens: We collect authentication tokens from third-party sign-in providers, such as Apple identity tokens (JWT) or Google ID tokens, when you sign in through those services. These tokens are transmitted to our backend solely to verify your identity, authenticate the sign-in request, and establish a secure app session. It is used only for authentication and session management purposes and is not used for advertising or unrelated profiling.
Other Sources: Data about you may also be collected from publicly available sources to further enhance our services and customer understanding.
YOUR CONSENT AND USAGE PERSONAL INFORMATION
Granting Consent:
By registering or creating a profile on our platform, you explicitly agree to our processing of your personal data as detailed in this Privacy Policy.
How We Utilize Your Information:
We use the personal information collected to:
Enhance Service Delivery: Provide and maintain the quality of our services.
Personalize Experience: Tailor content and advertisements to better match your interests and improve your overall service experience.
Manage Your Account: Support the management of your service usage, enabling access to various functionalities as a registered user.
Communicate: Contact you with updates, security alerts, and promotional messages through email or other forms of communication.
Security and Fraud Prevention: To detect, prevent, and address fraud, security risks, and other malicious or illegal activity.
Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.
Enforcing Terms: To enforce our Terms of Use and other policies.
Analytical Use and Compliance:
We analyze anonymized or aggregated data to enhance our services and ensure compliance with legal requirements, aiding in the prevention of fraud and illegal activities.
Advertisements and Analytics:
Third-party analytics may be used to understand service usage patterns and improve service delivery. These analytics are derived from data collected through cookies and similar technologies, which do not contain personally identifiable information.
Cookies:
Cookies are utilized to understand user interactions and store preferences related to your service use. You can manage these settings to adjust your privacy preferences.
Your Privacy Rights:
You have the right to opt out of receiving promotional communications and can manage, access, or modify your personal data, except where retained for legitimate business or legal reasons.
Policy Updates:
This Privacy Policy is subject to updates, which will be reflected in the revised document available on our platform. We encourage you to review this policy periodically. Continued engagement with our services after such updates constitutes your acceptance of the terms.
By using our services, you confirm that you understand and agree to the terms set out in this Privacy Policy, ensuring a secure and transparent user experience.
SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We do not share your data with other companies, organizations and individuals unless one of the following circumstances applies:
Sharing with your Consent:
We do not share your personal information with third parties without your explicit consent. Where consent is required for sharing specific data, we will seek this consent separately.
Legal Compliance and Protection of Rights:
We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to:
Comply with a legal obligation, subpoena, court order, or other valid legal process.
Protect and defend our rights or property.
Prevent or investigate possible wrongdoing in connection with the Service.
Protect the personal safety of users of the Service or the public.
Protect against legal liability.
Service Providers and Partners:
We may share only the minimum personal information necessary with third parties to provide, improve, promote, and protect our services. These include:
Service Providers: We may share Personal Data with third-party vendors, consultants, and other service providers who perform services on our behalf (e.g., cloud hosting, data storage, payment processing (e.g., Apple App Store In-App Purchase, Google Play Billing), customer support, analytics (e.g., Google Analytics, Firebase Analytics), marketing, and advertising (e.g., Google AdMob, Apple Search Ads). These service providers are contractually obligated to protect your data, and are granted access only to the information necessary to perform their functions. They are prohibited from using your personal information for other purposes.
Business Partners: We may share limited data such as: Contact details and demographic information, … with our business partners with whom we collaborate to provide you the best services or promotional offers. This is only done with your explicit consent and is strictly controlled under confidentiality agreements, ensuring compliance with privacy laws and limiting use to the agreed purposes.
Business Transfers:
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data may be shared or transferred as part of such a transaction, subject to standard confidentiality arrangements.
Public Interactions:
If you engage in activities on public areas of our services, your information can be seen by others and may be read, collected, or used by them. You are advised to exercise caution when deciding to disclose your personal information in these areas.
Cookies:
We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interactions. This helps us offer better site experiences and tools in the future. You may manage your cookie preferences through your browser settings.
APP-SPECIFIC PERMISSIONS
The main Permissions used by Interact AI - Language Tutor are described below.
Permission 1: NSMicrophoneUsageDescription
The permission allows the application to access the device microphone so you can speak with the AI English tutor during lessons, free-talk sessions, and pronunciation exercises. Microphone audio is captured only when you actively use voice-based features and is processed solely for speech transcription, pronunciation assessment, real-time conversation, and personalized learning feedback - the function that Nativibe helps you to learn and speak language.
Permission 2: NSSpeechRecognitionUsageDescription
The permission allows the application access to speech recognition to convert your spoken English into text during free-talk sessions, pronunciation exercises and to have an understanding of your sentences. Speech recognition may be performed using Apple’s on-device or server-based speech recognition services and is used solely to generate transcripts, assess pronunciation, measure fluency, pace, and intonation, and support adaptive next turn responses and pronunciation learning feedback from the AI tutor.
Permission 3: NSUserTrackingUsageDescription
We request your permission to track activity across other companies’ apps and websites using a limited advertising identifier. If you grant permission, Nativibe may use this identifier to measure advertising performance, understand which lessons, onboarding flows, and learning paths help you improve your English, provide more relevant recommendations and offers in the App and in partner apps, and support the continued development of our learning content and AI tutor features. The permission is requested to improve and personalize your learning experience, and enhance the core services. You may change this permission at any time in Setting.
These permissions are essential for the app to function properly and are strictly used in accordance with App Store's regulations to ensure a secure, efficient, and user-respecting operation. The app prioritizes user rights and privacy, implementing these permissions to enhance user experience without compromising privacy and security.
INFORMATION SECURITY AND TRANSFER OF PERSONAL INFORMATION
International Data Transfers:
Your personal information may be transferred to and processed in countries outside of your country of residence, including where our servers are located or where our service providers operate. These countries may have data protection laws that are different from those in your jurisdiction.
We take appropriate measures to ensure that your personal information remains protected according to the security standards outlined in this Privacy Policy, regardless of where it is processed. This includes implementing strong contractual arrangements (such as Standard Contractual Clauses) and security measures to protect your data during international transfers.
Safeguarding Measures:
We implement strong contractual arrangements and security measures to protect your data when it is transferred internationally. This includes using encryption, secure data transfer protocols, and ensuring that all data handlers comply with our data protection and privacy standards.
Data Security Practices:
To protect your personal information from unauthorized access, loss, or misuse, we employ a variety of security technologies and procedures. These include encryption, firewalls, and access controls that restrict who can access your data and how it is used. Our security measures are designed to provide a level of protection that matches or exceeds industry standards.
Handling Data Risks:
While we endeavor to secure your data, the transmission of information over the internet can never be guaranteed to be completely secure. We encourage you to take precautions to protect your personal information when using digital services, including monitoring your account settings and access privileges.
Data Security
We implement appropriate technical and organizational security measures designed to protect the security of any personal information we process, including encrypting data at rest and in transit, access controls, and secure development practices. However, please note that no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Data Retention And Deletion
We retain your Personal Data only for as long as necessary for the purposes stated in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
Account Information: We generally retain your account information for as long as your account remains active.
User-Generated Content and Usage Data: We retain user-generated content and usage data for as long as necessary to provide the services you use or for legitimate business purposes, unless you request earlier deletion.
Other Data: Other types of data are retained for periods necessary to fulfill the purposes for which they were collected.
When your account is deleted or upon receiving a valid data deletion request, we will securely delete or anonymize your Personal Data according to our internal procedures and applicable law, subject to any legal obligations or legitimate business needs (e.g., fraud prevention, dispute resolution) requiring us to retain certain information. Please note that residual copies may take some time to be fully removed from backup systems.
Correcting and Updating Your Information:
You have the right to request access to, correction of, or deletion of your personal information. If your personal data changes, or if you no longer wish to use our service, you may correct, update, or remove the information by making a direct request to us.
ACCESSING AND UPDATING PERSONAL INFORMATION
Your Rights to Access and Control Personal Data:
You have the right to access, review, and manage your personal data stored by us. Under applicable laws, you can request information about the data we hold on you, as well as request updates, corrections, or deletions of any inaccuracies.
How to Manage Your Information:
You can exercise your data protection rights through several options:
Update and Correct: Directly modify your personal details via your account settings.
Privacy Controls: Adjust settings to manage the use of your data, including opting out of targeted advertising and managing communication preferences.
Limitations on Access:
In certain circumstances, as permitted or required by law, your ability to access or control your personal data may be limited. The scope of access may also vary by the specific services and products you utilize.
Processing Requests:
We endeavor to promptly fulfill requests to access or modify personal information. You can initiate these requests through the contact options available on our platform.
Additional Support:
If certain personal data cannot be accessed or controlled via our standard tools or if you have specific inquiries regarding your data rights, please reach out to us directly for assistance.
Transparency and Accountability:
We regularly review and report on the requests we receive to access or control personal data, ensuring transparency and accountability in our data handling practices.
MINORS
Data Collection and Consent:
Our Service is not intended for use by children under the age of 13 (or a higher age threshold if required by applicable law in your jurisdiction). We do not knowingly collect personally identifiable information from children under this age without verifiable parental consent. If we become aware that we have collected Personal Data from a child without verification of parental consent, we will take steps to remove that information from our servers promptly. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.
Parental Rights:
Parents or guardians have the right to review, manage, and delete their child’s information. We provide tools and support to facilitate these actions.
Revoking Consent:
At any time, parents or guardians can revoke their consent and request the deletion of their child’s information from our systems.
Reporting Issues:
For issues regarding the protection of minors’ data, please contact us immediately.
CHANGES TO THIS PRIVACY POLICY
We may revise our Privacy Policy from time to time to reflect changes in our practices or service offerings. When updates are made, we will notify you by sending an email and/or displaying a prominent notice on our service. Additionally, we will update the 'Last updated' date at the top of the Privacy Policy, which can be viewed on this page.
For significant changes, we may also send a push notification directly through the service.
We encourage you to review our Privacy Policy periodically to stay informed of how we are protecting the personal information we collect. Continued use of the service after any updates signifies your agreement to the revised policy.
CONTACT
If you have any questions about our Privacy Policy or wish to make a request regarding certain personal information, you are encouraged to contact us. The contact information is:
APERION LABS LIMITED
support.interactai@gmail.com