Privacy Policy

Overview

Ricki ("the App") is an AI-powered language tutoring application that supports 25+ languages. This Privacy Policy explains how we collect, use, and protect your personal information when you use our service.

Information We Collect

• Account information: email address, name, and language preferences you provide during signup
• Voice recordings: audio captured during voice conversations with Ricki, processed in real-time for speech-to-text transcription and deleted after processing
• Conversation transcripts: text of your conversations stored to track progress and personalize your learning experience
• Learning data: vocabulary, error patterns, pronunciation scores, session history, and proficiency metrics
• Device information: push notification tokens and device platform for sending reminders

How We Use Your Information

• To provide personalized language tutoring adapted to your level and goals
• To track your learning progress, vocabulary growth, and areas for improvement
• To remember context across sessions (things you've told Ricki about yourself)
• To send practice reminders and streak notifications (with your permission)
• To improve the quality of our AI tutoring service

Third-Party AI Services

Ricki uses the following third-party AI services to power your experience. Your data is shared with these services only as necessary to provide the App's functionality:

Audio data is processed in real-time and not stored by these AI providers beyond what is necessary to deliver the service. Your data is not used to train third-party AI models. Before your first conversation, you will be asked to acknowledge and consent to this data processing.

Data Storage & Security

Your data is stored securely on Supabase's infrastructure with row-level security policies ensuring you can only access your own data. Conversation transcripts and learning data are associated with your account and are not shared with other users. We use industry-standard encryption for data in transit and at rest.

Bridge Mode (Duo)

When using Bridge Mode, both participants' voice data is processed to facilitate translation. Conversation transcripts from duo sessions are stored with the session and accessible to both participants. Room codes expire after 30 minutes.

Children's Privacy & Ricki Kids

Ricki requires users to be at least 13 years old to create an account.

Ricki Kids is a feature that allows parents and guardians (age 13+) to set up language learning profiles for their children. Before using Ricki Kids, the parent or guardian must provide verifiable parental consent acknowledging:

• That voice recordings from their child will be processed by AI services (Anthropic, Deepgram, ElevenLabs) to provide language tutoring
• That conversation transcripts may be stored to track the child's learning progress
• That they consent to this data collection on behalf of their child

Voice data from Kids Mode sessions is processed in real-time and not stored beyond the session. Parents can delete their child's profile and all associated data at any time from the Kids tab. We comply with the Children's Online Privacy Protection Act (COPPA) and applicable children's privacy laws.

If you believe a child under 13 has used the App without parental consent, please contact us immediately at privacy@rickiapp.ai.

Content Reporting

Ricki provides tools for reporting inappropriate content, including AI-generated messages, user posts, and comments. Reports are reviewed by our team. You can also block other users to prevent seeing their content.

Account Deletion

You can delete your account and all associated data at any time from the Settings screen in the app. Account deletion is permanent and removes all your data including:

• Your profile and account information
• All conversation transcripts and session history
• Vocabulary, progress data, and learning metrics
• Kids profiles and their associated data
• Community posts, comments, and social connections
• Your authentication credentials

This action cannot be undone. You may also request account deletion by contacting privacy@rickiapp.ai.

Your Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information. Below we describe your general rights, followed by jurisdiction-specific rights in dedicated sections.

• Access: You can view all your data through the app's Progress and History screens. You may also request a copy of all personal data we hold about you.
• Correction: You can update your profile, language preferences, and account information at any time within the app. You may also request correction of inaccurate personal data by contacting us.
• Deletion: You can delete your account and all associated data from Settings, or by contacting privacy@rickiapp.ai. We will process deletion requests within 30 days.
• Portability: You can request an export of your learning data, conversation history, and profile information in a commonly used, machine-readable format.
• Restriction: You may request that we restrict processing of your personal data under certain circumstances, such as while we verify the accuracy of your data.
• Notifications: You can disable push notifications at any time through your device settings or within the app.
• AI Consent: You can withdraw consent for AI data processing by discontinuing use of voice and chat features. Withdrawal of consent does not affect the lawfulness of processing performed prior to withdrawal.
• Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

To exercise any of these rights, contact us at privacy@rickiapp.ai. We will respond to verified requests within 30 days (or sooner where required by law). If we need additional time, we will inform you of the reason and extension period.

GDPR Rights (European Users)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) and equivalent local laws. Ricki Technologies acts as the data controller for your personal information.

Your GDPR Rights:

• Right of Access (Article 15): You have the right to obtain confirmation as to whether your personal data is being processed and to access a copy of that data, along with information about how it is used.
• Right to Rectification (Article 16): You have the right to request correction of inaccurate personal data and to have incomplete data completed.
• Right to Erasure (Article 17): You have the right to request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when the data has been unlawfully processed.
• Right to Restriction of Processing (Article 18): You have the right to request restriction of processing when you contest the accuracy of data, when processing is unlawful, or when we no longer need the data but you require it for legal claims.
• Right to Data Portability (Article 20): You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.
• Right to Object (Article 21): You have the right to object to processing based on legitimate interests or for direct marketing purposes. Where you object, we will cease processing unless we demonstrate compelling legitimate grounds.

Legal Basis for Processing:

• Consent (Article 6(1)(a)): We process your voice recordings and AI-generated conversation data based on your explicit consent, which you provide before your first AI-powered session. You may withdraw this consent at any time.
• Performance of a Contract (Article 6(1)(b)): We process your account information, learning data, and subscription details as necessary to provide the language tutoring service you have signed up for.
• Legitimate Interests (Article 6(1)(f)): We process anonymous analytics data and usage metrics to improve our service, ensure security, and prevent fraud. We have conducted a balancing test and determined that these interests do not override your rights and freedoms.

Data Protection Officer: You may contact our Data Protection Officer at dpo@rickiapp.ai for any questions or concerns regarding how we process your personal data.

Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in the EU/EEA member state of your habitual residence, place of work, or place of the alleged infringement if you believe that our processing of your personal data infringes the GDPR.

Data Processing Agreements: We have entered into Data Processing Agreements (DPAs) with all third-party service providers (Anthropic, Deepgram, ElevenLabs, OpenAI, and Supabase) that process personal data on our behalf. These agreements ensure that our processors handle your data in accordance with GDPR requirements and our documented instructions.

International Data Transfers: When your data is transferred outside the EEA, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission as our transfer mechanism. We also conduct transfer impact assessments to ensure an adequate level of data protection is maintained.

Data Breach Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay.

CCPA/CPRA Rights (California Users)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

We Do Not Sell Your Personal Information. Ricki does not sell, and has not sold in the preceding 12 months, your personal information to third parties as defined under the CCPA/CPRA. We also do not share your personal information for cross-context behavioral advertising.

Your CCPA/CPRA Rights:

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purpose for collecting it, and the categories of third parties with whom we share it.
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions (such as completing a transaction, detecting security incidents, or complying with legal obligations).
• Right to Correct: You have the right to request correction of inaccurate personal information that we maintain about you.
• Right to Opt-Out of Sale/Sharing: Although we do not sell or share personal information, you have the right to direct us not to do so.
• Right to Limit Use of Sensitive Personal Information: You may direct us to limit the use and disclosure of your sensitive personal information to what is necessary to perform the services.

Categories of Personal Information Collected:

• Identifiers: Name, email address, unique account ID — used to provide and personalize the service
• Audio/Visual Data: Voice recordings during tutoring sessions — used for real-time speech-to-text transcription, then immediately deleted
• Internet/Network Activity: App usage data, session frequency, feature interactions — used to improve the service and provide analytics
• Education Information: Language proficiency levels, vocabulary progress, learning metrics — used to personalize the tutoring experience
• Inferences: Learning patterns, skill assessments, areas for improvement — derived from your usage to enhance tutoring quality

Global Privacy Control (GPC): We honor Global Privacy Control signals. If your browser or device sends a GPC signal, we will treat it as a valid opt-out request for the sale or sharing of personal information associated with that browser or device.

Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. You will not receive different pricing, a different quality of service, or be denied service for exercising your rights.

Authorized Agent: You may designate an authorized agent to submit requests on your behalf. The authorized agent must provide signed written permission from you and we may require you to verify your identity directly with us.

Contact for CCPA/CPRA Requests: To exercise your rights, contact us at privacy@rickiapp.ai or call our toll-free number at 1-888-RICKI-AI (1-888-742-5424). We will verify your identity before processing any request and respond within 45 days.

EU AI Act Compliance

Ricki uses artificial intelligence to power its language tutoring features. In accordance with the EU Artificial Intelligence Act (Regulation (EU) 2024/1689), we provide the following transparency disclosures:

• AI System Disclosure: When you use Ricki, you are interacting with an AI system. Ricki's conversational tutoring, pronunciation feedback, grammar corrections, and adaptive lesson planning are all powered by artificial intelligence, including large language models provided by Anthropic (Claude) and OpenAI.
• AI-Generated Content Transparency: All conversational responses, vocabulary suggestions, grammar explanations, and lesson content generated by Ricki are produced by AI. While we design our AI to be accurate and pedagogically sound, AI-generated content may occasionally contain errors. Users should not rely on Ricki as the sole source of language accuracy for professional, legal, or medical contexts.
• Risk Classification: Ricki is classified as a limited-risk AI system under the EU AI Act. As such, transparency obligations apply. We are committed to clearly informing users when they are interacting with an AI system and when content is AI-generated.
• Right to Know: You have the right to know when AI is generating the responses you receive. Ricki does not attempt to impersonate a human being. The app clearly identifies itself as an AI-powered language tutor throughout the user experience.
• Human Oversight: Our development team regularly reviews AI outputs, monitors for harmful content, and updates safety filters. Users can report inappropriate AI-generated content using the in-app reporting tools.

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy. Below are the specific retention periods for each category of data:

• Account Data: Retained while your account is active and for 30 days after account deletion to allow for recovery of accidental deletions. After this period, all account data is permanently deleted.
• Voice Audio: Deleted immediately after real-time transcription. Voice recordings are not stored on our servers or by our AI service providers beyond the duration of the transcription process.
• Conversation Transcripts: Retained while your account is active to provide session history and personalized learning. Permanently deleted upon account deletion.
• Learning Data: Vocabulary, progress metrics, proficiency scores, and error patterns are retained while your account is active. Permanently deleted upon account deletion.
• Anonymous Analytics: Aggregated, de-identified usage statistics (such as feature popularity, average session length, and language distribution) are retained indefinitely. These analytics contain no personal identifiers and cannot be linked back to individual users.
• Push Notification Tokens: Deleted upon account deletion or when the token is refreshed by the operating system. Inactive tokens are purged periodically.
• Kids Mode Data: All data associated with a child's profile (including conversation transcripts and learning progress) is permanently deleted when the parent or guardian removes the child's profile from the Kids tab.

If we are required to retain data for legal or regulatory compliance, we will do so for the minimum period required by law and restrict access to such data accordingly.

International Data Transfers

Ricki is operated from the United States. If you are accessing the App from outside the United States, please be aware that your personal information will be transferred to, stored, and processed in the United States where our servers and third-party service providers are located.

EU/EEA Transfers: For personal data transferred from the European Economic Area, the United Kingdom, or Switzerland to the United States, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission as our lawful transfer mechanism. We also evaluate the legal framework in the receiving country and implement supplementary measures where necessary.

Adequacy Decisions: Where the European Commission has issued an adequacy decision for a country, we may rely on that decision as the basis for transferring personal data to recipients in that country.

Third-Party Safeguards: All third-party service providers who process data on our behalf (Anthropic, Deepgram, ElevenLabs, OpenAI, and Supabase) maintain appropriate safeguards for international data transfers, including Standard Contractual Clauses and, where applicable, certification under recognized frameworks.

By using the App, you acknowledge that your information may be transferred to and processed in jurisdictions outside your country of residence, which may have different data protection laws than your jurisdiction.

Do Not Track / Global Privacy Control

Global Privacy Control (GPC): We honor Global Privacy Control signals sent by your browser or device. When we detect a GPC signal, we treat it as a valid opt-out request and limit data collection accordingly.

Do Not Track (DNT): We respect Do Not Track signals. When we detect a DNT signal from your browser, we limit non-essential data collection.

Cross-Site Tracking: We do not track users across third-party websites or applications. Ricki does not use third-party advertising trackers, retargeting pixels, or cross-site cookies. Analytics data is collected only within the Ricki app and is used solely to improve our own service.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes through the app or by email.

Contact Us

If you have questions about this Privacy Policy, contact us at: privacy@rickiapp.ai