Privacy Policy

TalkBravely is run by UAB “Minderse”, company code 306238029, VAT code LT100015812514, Laisvės al. 110, LT-44253 Kaunas, Lithuania. That company is responsible for your personal data (the “controller”). “We” and “us” mean that company.

For anything in this policy, write to [email protected]. That address also reaches the person who handles data protection for us, including as our contact (encarregado) under Brazil’s data protection law, the LGPD.

We collect what we need to build your plan, take payment and run your lessons, and no more.

Most of this comes from you. Device and usage data is collected as you browse. Stripe tells us whether a payment went through.

We don’t ask for sensitive data, like health details, and we ask you not to share it with your tutor.

The law asks us to name a legal basis for each use. Article numbers refer to the EU General Data Protection Regulation (GDPR).

In Brazil, the LGPD has matching legal bases: performing a contract, meeting a legal obligation, legitimate interest and consent.

We don’t make decisions about you by automated means that have legal or similarly significant effects. Your tutor’s corrections are feedback on your speaking, not decisions about you.

The tutor app is not open yet. This is how it will work. If anything changes, we will update this page before the app opens.

• To run a lesson, your voice and text are sent to AI providers. They turn your speech into text, write the tutor’s reply and turn it back into speech. OpenAI is the provider we plan to use. If we add another, for example to score pronunciation, we will name it here before it receives your voice.
• These providers act only on our instructions. Your recordings and transcripts are not used to train their AI models, or any other company’s.
• OpenAI may keep lesson data for up to 30 days to detect abuse, and then deletes it.
• We don’t keep audio recordings after a lesson ends.
• We keep transcripts, pronunciation scores and your learner profile while your account is open, so your tutor remembers you. We delete them within 30 days after you close your account, or sooner if you ask.
• We don’t use your voice to identify you.

Please don’t tell your tutor anything you would not want stored, like passwords, card numbers or health details.

Card payments, including Apple Pay and Google Pay, are handled by Stripe. Your card details go straight to Stripe and never touch our servers. With your agreement at checkout, Stripe saves your card for renewals and for one-time offers you choose. Stripe also uses payment data to prevent fraud and to meet financial laws, as a controller under Stripe’s privacy policy.

Some emails are part of the service: your plan, receipts, renewal reminders and cancellation confirmations. You get these while you have a plan.

We send tips and offers only where the law allows: if you have agreed to them, or, as a customer, about similar TalkBravely products. Every one of these emails has an unsubscribe link that works in one tap. Our email provider sends our emails for us.

Your browser stores a few things for us.

Needed for what you asked for. These don’t need your consent:

• tb.funnel.v1 and tb.funnel.started: your quiz answers, kept in your browser so a reload doesn’t lose them.
• tb.order and tb.offer entries: your order and where you are in the offers after checkout. They are cleared when you close the tab.
• tb.steps and tb.steps.ad: which funnel steps this tab has already counted, so a refresh counts once. They are cleared when you close the tab.
• tb.quiz.step: where you are in the quiz, so a reload brings you back to the same screen. It is cleared when you close the tab.
• __stripe_mid and __stripe_sid: Stripe’s cookies at checkout, to prevent fraud.

Funnel statistics. We count how many visitors reach each step of the quiz and the plans page each day: one number per step, language and whether the visit came from an ad. These counts hold no visitor number, email, IP address or quiz answer, so nobody can be identified from them, and we use them to see where the funnel loses people.

Your city. One quiz step shows the city you are in, and you can change it. Our server asks GeoJS for the approximate city of your IP address, and sends what you type in the search box to Photon, a city search run by komoot on OpenStreetMap data. Neither gets your email or your quiz answers, your browser never contacts them directly, and we don’t keep your IP address or your searches from this step.

Microphone. One quiz step lets you say a sentence out loud, if you choose to. Your browser measures only how loud the sound is, on your device. Nothing is recorded, saved or sent to us.

Advertising. On every visit we use the Meta pixel, Meta’s measuring tool, with Meta’s cookies _fbp and _fbc. It tells Meta when you view a page (PageView), start the quiz (OnboardingStart), answer its first question (ViewContent), leave your email (CompleteRegistration, Lead), see the plans and prices (PaywallView), open checkout (AddToWishlist) or buy (Purchase, Subscribe), with the amount and currency of a purchase. Our server sends Meta the same events through Meta’s Conversions API, so they arrive even when the pixel is blocked, with a scrambled (hashed) copy of your email address once you have given it, a scrambled random visitor number, your IP address and browser details, so Meta can match them to the ad you saw. Each event is counted once. We don’t send Meta your name or your quiz answers.

Meta uses this data to measure our ads and to show them to people likely to be interested, under Meta’s privacy policy. For collecting and sending it, Meta and we are joint controllers. You can object at any time: email us and we stop sending your purchases to Meta; block third-party cookies or use a tracker blocker in your browser to stop the pixel; and choose how Meta uses this in your Facebook or Instagram ad settings.

Clearing your browser’s data for our site removes everything listed here. Meta’s _fbp cookie otherwise lasts 90 days.

We never sell your personal data. We share it only with companies that help us, and only what each needs:

• Stripe handles payments and prevents fraud.
• Our hosting and database providers store the site and our records.
• Our email provider sends our emails.
• AI providers (OpenAI is planned) run your lessons.
• Meta measures our ads (the Meta pixel and Meta’s Conversions API).
• Advisers and authorities, such as our accountants and lawyers, or a court or regulator when the law requires it.

Each provider works under a data processing agreement and may use your data only to serve us, except Stripe and Meta for their own purposes described above. If TalkBravely is ever sold or merged, your data may pass to the new owner, who must keep to this policy.

We are in Lithuania, in the EU. Some of our providers, such as Stripe, Meta and OpenAI, are based in the United States or handle data there.

When your data leaves the European Economic Area, we protect it with the European Commission’s Standard Contractual Clauses, or rely on the EU-US Data Privacy Framework where the provider is certified under it. For users in Brazil, transfers use the safeguards the LGPD allows, such as standard contractual clauses. Email us for a copy of the safeguards.

• Quiz answers and email, if you don’t buy: 12 months after we last heard from you, then deleted. Sooner if you ask.
• Your account, plan and learner profile: while your account is open, then deleted within 30 days of closing it.
• Lesson audio: not kept after the lesson. Transcripts follow your account.
• Orders, invoices, payments and your checkout agreement: as long as Lithuanian tax and accounting law requires, currently up to 10 years.
• Messages to us: as long as we need them to help you and to keep a record of what we agreed, and no more than 3 years after your last message.
• If you unsubscribe: we keep your email on a do-not-email list, so we don’t email you again.
• Browser storage: until you clear it. Order and offer entries go when you close the tab.

You can ask us to:

• give you a copy of your data, also in a format you can take elsewhere;
• correct it;
• delete it, apart from records the law makes us keep;
• limit how we use it;
• stop using it for marketing, at any time, or where we rely on our legitimate interests, unless we have strong reasons that override yours;
• withdraw your consent at any time. This doesn’t affect what we did before.

In Brazil, the LGPD also lets you confirm whether we process your data, have it anonymised, and learn who we share it with and what happens if you don’t consent.

Email [email protected] from the address you used with us. We reply within one month. If a request is complex, we may need up to two more months, and we will tell you why. We don’t charge for this.

If you are unhappy with how we handle your data, please tell us first. You can also complain to a data protection authority:

• In Lithuania, where we are based: the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), vdai.lrv.lt.

Or to the authority in your own country:

• Italy: Garante per la protezione dei dati personali
• Spain: Agencia Española de Protección de Datos (AEPD)
• Portugal: Comissão Nacional de Proteção de Dados (CNPD)
• France: Commission Nationale de l’Informatique et des Libertés (CNIL)
• Poland: Urząd Ochrony Danych Osobowych (UODO)
• Brazil: Autoridade Nacional de Proteção de Dados (ANPD)

TalkBravely is for adults. You must be 18 or older to buy, and we don’t knowingly collect data from anyone under 16. If you think a child has given us data, email us and we will delete it.

The site runs over encrypted HTTPS, and only the people who need it can see customer records. Card payments are handled by Stripe, which is certified to PCI DSS Level 1, the payment industry’s highest security standard. No system is perfectly secure. If a breach puts you at risk, we will tell you, as the law requires.

When our practices change, we update this page and the date at the top. If a change matters to you, we email you before it applies. Our other terms are in our Terms of Service.

Email [email protected] with “Privacy request” in the subject line. A person reads every message and replies within one working day.

By post: UAB “Minderse”, Laisvės al. 110, LT-44253 Kaunas, Lithuania.