Privacy Policy

Last updated: November 2, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • "Account" means a unique account created for You to access our Service or parts of our Service.
  • "Application" means the software program provided by the Company downloaded by You on any electronic device, named Our Mobile Applications.
  • "Company" (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Floude LLC, 30 N Gould St Ste N, Sheridan, WY 82801.
  • "Country" refers to: US
  • "Device" means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • "Personal Data" is any information that relates to an identified or identifiable individual.
  • "Service" refers to the Application.
  • "Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

We do not collect personally identifiable information such as your name, email address, or address. However, we do collect Usage Data which may include unique device identifiers that could potentially be used to identify your device.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), device name, operating system version, the configuration of the app when utilizing our Service, the time and date of Your use of the Service, and other statistics.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We use third-party services that collect, monitor and analyze this type of information in order to increase our Service's functionality. These third-party service providers have their own privacy policies addressing how they use such information.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

  • Data from HealthKit and other health and fitness-related data.

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Information from Apple HealthKit

This section applies only to our applications that explicitly request access to Apple's HealthKit framework. If the application you are using does not request HealthKit access, this section does not apply to you.

Our Service may, with your explicit permission, connect to Apple's HealthKit framework. This connection is solely for the purpose of reading and/or writing certain health and fitness data to your device's Health App database to provide the core functionality of our Service.

Important: All HealthKit data is processed and stored locally on your device only. We do not have access to, nor do we store, your personal HealthKit data on our servers. This data never leaves your device.

You have full control over the HealthKit data you share with our Application. You can grant or revoke permissions at any time through the Apple Health app on your device.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • 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

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Your Data Protection Rights

Depending on your location, you may have certain rights under data protection laws such as the GDPR or CCPA. These may include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request the transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of these rights, please contact us.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Data Deletion Requests

If you would like to request deletion of your personal data collected through our mobile application, please send an email to info@floude.com with the subject line "Data Deletion Request".

Please include the email address or any information you used in the app so we can identify your account. After verifying your request, we will delete or anonymize your data within a reasonable period of time in accordance with this Privacy Policy.

Dictara — Application-Specific Information

This section applies to the Dictara application only. Where it differs from the general sections of this Privacy Policy, this section prevails for Dictara.

Information we collect in Dictara

  • Voice recordings. When you start a practice session, audio from your microphone is streamed to our servers so the AI coach can listen and respond. The microphone is used only during sessions you start.
  • Transcripts and feedback. The text of what you and the coach said, and the feedback recap generated from it (which quotes your own words), are stored so you can review them in History.
  • Practice choices. The topics, role-play situations and interview industry, role and company you select.
  • Device and usage data. A randomly generated user ID, device country and language, app version, in-app analytics events and subscription status.

How we use it

We use this information to run your practice sessions, generate your feedback, show your history, personalize suggestions and improve Dictara. We do not sell your information and do not use your recordings or transcripts for advertising.

Third-party AI processing

Before your first practice session, Dictara asks for your permission to send your audio to OpenAI. No audio is sent unless you agree. If you decline, practice sessions are not available until you give permission. To provide voice coaching and feedback, your audio, transcripts and the practice details you choose (such as an interview role or company) are sent to OpenAI, L.L.C., which processes them on our behalf through its API. Data sent through OpenAI's API is not used to train OpenAI's models. OpenAI may retain it for a limited period (currently up to 30 days) to detect abuse, after which it is deleted. OpenAI processes this data only on our instructions and is contractually required to protect it with safeguards equal to or greater than those described in this Privacy Policy. We do not send your user ID, device identifiers, subscription details or analytics data to OpenAI. OpenAI's privacy policy: https://openai.com/policies/privacy-policy

Access by our team

Authorized members of our team may access session transcripts and feedback when needed to provide support, investigate a problem you report, or keep the service secure. We recommend not sharing sensitive personal, financial or health information during practice sessions.

Retention

  • Audio is kept until you request deletion.
  • Transcripts and feedback recaps are kept until you request deletion.
  • Onboarding answers and usage data are kept while you use the app and deleted on request.
  • When your data is deleted, it is removed from our active systems straight away. Copies in our backups are permanently erased within 30 days.

Refund requests

If you ask Apple for a refund, we may share information about your use of Dictara's paid features with Apple to help it decide the request. This never includes your recordings or transcripts.

Deleting your Dictara data

Email info@floude.com with the subject "Data Deletion Request" and include the User ID shown on the Profile screen in Dictara. We will delete your recordings, transcripts, feedback and profile answers within 30 days.

Quetal — Application-Specific Information

This section applies to the Quetal: Learn Spanish AI Tutor application only. Where it differs from the general sections of this Privacy Policy, this section prevails for Quetal.

Information we collect in Quetal

  • Voice recordings. When you talk to your tutor, audio from your microphone is sent to our servers and turned into text. The microphone is used only while a conversation is open. We do not store the recordings after they are transcribed.
  • Conversations and words. What you say or type, your tutor's replies, the corrections and scores generated from them, and the words saved from your conversations are stored so you can see your results, history and word review.
  • Learning preferences. Your native language, the Spanish you want to learn, your goal and level, your tutor, your daily practice minutes and your reminder time.
  • Device and usage data. A randomly generated ID stored in your device's Keychain (Quetal has no sign-in, so this ID is how we recognize your data), app language, region, time zone, app version, a push notification token if you allow notifications, in-app analytics events, crash reports and subscription status.

Quetal does not collect your name, email address, phone number, contacts, photos, precise location or advertising identifier, and does not track you across other companies' apps or websites.

How we use it

We use this information to run your conversations, generate corrections and results, build your word review, personalize lessons, send the daily reminder you set, manage your subscription, fix crashes and improve Quetal. We do not sell your information and do not use your recordings, conversations or words for advertising.

Third-party AI processing

Before your first conversation, Quetal asks for your permission to send your voice recordings and messages to OpenAI. Nothing is sent unless you tap Allow. If you decline, conversations are not available until you give permission. To hear and answer you, your voice recordings, your messages, the conversation text and your learning preferences (such as your level and native language) are sent to OpenAI, L.L.C., which processes them on our behalf through its API for speech-to-text, the tutor's replies and corrections, translations, and the tutor's voice. Data sent through OpenAI's API is not used to train OpenAI's models. OpenAI may retain it for a limited period (currently up to 30 days) to detect abuse, after which it is deleted. OpenAI processes this data only on our instructions and is contractually required to protect it with safeguards equal to or greater than those described in this Privacy Policy. We do not send your ID, device identifiers, subscription details or analytics data to OpenAI. OpenAI's privacy policy: https://openai.com/policies/privacy-policy

Other service providers

  • Amazon Web Services hosts our servers and database in the United States.
  • RevenueCat receives your random ID and purchase information to manage your subscription. We never see your payment details; payments are handled by Apple.
  • Google Firebase receives your random ID, analytics events, crash reports and push token to provide analytics, crash reporting and notifications.

Access by our team

Authorized members of our team may access conversation text and results when needed to provide support, investigate a problem you report, or keep the service secure. We recommend not sharing sensitive personal, financial or health information during conversations.

Retention

  • Voice recordings are not stored after transcription.
  • Conversation text, corrections, results and saved words are kept until you request deletion.
  • Learning preferences and usage data are kept while you use the app and deleted on request.
  • When your data is deleted, it is removed from our active systems straight away. Copies in our backups are permanently erased within 30 days.

Refund requests

If you ask Apple for a refund, we may share information about your use of Quetal's paid features with Apple to help it decide the request. This never includes your recordings or conversations.

Deleting your Quetal data

In Quetal, open Profile and tap Contact support, or email info@floude.com with the subject "Data Deletion Request". We will reply to help identify your data and delete your conversations, words and preferences within 30 days.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: