LEGAL
Privacy Policy — langusta.me
Last updated: 15 June 2026
1. Controller
1.1. The controller of your personal data is SOFTBERRIES Krzysztof Grajek, ul. Zagonowa 1/1, 82-300 Elbląg, Poland, VAT ID (NIP): PL5782712816 (the "Provider", "we").
1.2. Contact for all privacy matters: support@langusta.me.
1.3. This policy explains how we process personal data when you use langusta.me, an AI voice language-tutor service ("Service"). Terms defined in the Terms of Service have the same meaning here.
2. How your voice is handled (read this first)
2.1. We do not record or store your voice audio. During a session, your speech is streamed in real time to our speech-to-text processor (AssemblyAI) for transcription; the resulting conversation text is processed by Anthropic (Claude) to generate the tutor's responses; and the tutor's replies are synthesized into speech by ElevenLabs. All of this happens transiently, to deliver the conversation as it happens.
2.2. Conversation transcripts are stored. So your tutor can continue across sessions like a real one, and so you can revisit past conversations, we save the text transcript of each session to your account. You can read your transcripts in the app (the History view) and remove them by deleting your account; deletion of individual transcripts can be requested at support@langusta.me. We still never store the underlying voice audio (section 2.1).
2.3. Your voice is not used for biometric identification. We do not create voiceprints and do not identify or verify anyone by the sound of their voice.
2.4. You are always talking to an AI tutor, not a human. No human listens to your sessions.
3. What data we process
3.1. Account data: e-mail address, password hash (or Google account identifier if you sign in with Google), account creation date.
3.2. Learning data persisted from sessions:
- vocabulary items you used (your flashcard deck);
- text transcripts of your conversations (so the tutor can recall recent sessions and you can browse your history);
- CEFR proficiency level estimates per language;
- learner profile: your learning goals and chosen tutor name;
- session metadata: session mode, language, start time and duration (duration is used for Minute billing).
3.3. Subscription and billing data: your Plan, subscription state, billing period, overage settings, and payment/invoice records held by Stripe. We do not see or store your full card details.
3.4. Voice audio: processed transiently only, as described in section 2; never stored. The text transcript of a conversation is stored as part of your learning data (sections 2.2 and 3.2).
3.5. Technical data: authentication cookie, server logs necessary for security and troubleshooting.
3.6. For analytics we use only a privacy-friendly, cookieless tool that we self-host (see section 8.2). We use no advertising data and do not track you across other sites.
4. Purposes and legal bases (GDPR)
| Purpose | Data | Legal basis |
|---|---|---|
| Providing the tutoring service, including transient real-time processing of your voice, transcription, AI response generation and speech synthesis | voice/transcripts (transient), learning data, account data | Contract performance — art. 6(1)(b) GDPR |
| Account management, login, subscription and Minute billing | account data, session metadata, subscription data | Contract performance — art. 6(1)(b) GDPR |
| Invoicing, tax and accounting records | billing data | Legal obligation — art. 6(1)(c) GDPR |
| Service security, fraud and abuse prevention, troubleshooting | technical data, session metadata | Legitimate interest — art. 6(1)(f) GDPR |
| Practice-reminder e-mails about your own learning (service-related, non-marketing) | e-mail address, reminder watermark | Legitimate interest — art. 6(1)(f) GDPR, with opt-out (section 7) |
| Handling complaints, withdrawal requests and legal claims | account and billing data, correspondence | Legal obligation and legitimate interest — art. 6(1)(c) and (f) GDPR |
4.1. CEFR level estimation is content personalization: it adjusts the difficulty of the tutor's language to your level. It produces no legal or similarly significant effect on you. We carry out no automated decision-making within the meaning of art. 22 GDPR.
5. Recipients and international transfers
We share data only with the processors needed to run the Service:
| Processor | Role | Location | Transfer mechanism |
|---|---|---|---|
| Anthropic | AI response generation (conversation text) | US | Standard Contractual Clauses (SCCs) |
| AssemblyAI | Real-time speech-to-text | US | EU–US Data Privacy Framework / SCCs per DPA |
| ElevenLabs | Speech synthesis (tutor voice) | US | EU–US Data Privacy Framework (certified) |
| Stripe | Payments, invoicing, customer portal | US | EU–US Data Privacy Framework |
| Sign-in with Google (OAuth) only | US | EU–US Data Privacy Framework | |
| Brevo | Transactional and reminder e-mails | EU (France) | n/a (EU) |
| Google Cloud Platform | Application hosting | EU (europe-central2) | n/a (EU region) |
| Self-hosted PostgreSQL | Database (account and learning data) | with our hosting | n/a |
| Self-hosted Umami | Cookieless usage analytics | with our hosting (EU) | n/a (self-hosted, EU) |
5.1. For US transfers we rely on the mechanisms listed above; copies of the relevant safeguards can be requested at support@langusta.me.
5.2. We do not sell personal data and do not share it with advertisers.
6. Retention
| Data | Retention |
|---|---|
| Voice audio | not stored at all |
| Conversation transcripts (text) | until account deletion, plus up to 30 days in backups |
| Analytics (cookieless; no IP stored) | aggregate usage statistics retained while the Service operates |
| Account data, flashcard deck, learner profile, CEFR estimates | until account deletion, plus up to 30 days in backups |
| Session metadata (billing) | as part of billing records, below |
| Billing and invoice records | 5 full tax years, as required by Polish tax law |
| Reminder watermark (when we last e-mailed you) | with the account |
7. Practice reminders (e-mail)
7.1. We send occasional practice-reminder e-mails about your own learning. These are service-related messages, not marketing, sent on the basis of our legitimate interest in supporting your use of the Service.
7.2. Reminders are enabled by default. You can turn them off at any time via the toggle in your account settings or the unsubscribe link in every reminder e-mail. We honour the opt-out immediately.
8. Cookies and local storage
8.1. We use only strictly necessary storage:
- `cuaderno_auth` — session authentication cookie, lifetime 30 days; required to keep you signed in;
- localStorage and a service worker — to cache the application shell so the app loads quickly.
8.2. For analytics we self-host Umami, a privacy-friendly, cookieless tool. It sets no cookies and uses no cross-site identifiers, and it does not store your IP address (an IP is used only transiently to derive an anonymous daily visit count). We use no advertising or third-party tracking cookies. Because no cookies or cross-site identifiers are used, no cookie consent banner is required. Legal basis: our legitimate interest in understanding aggregate Service usage (art. 6(1)(f) GDPR).
8.3. During checkout you are redirected to stripe.com, where Stripe sets its own cookies under its own policy: https://stripe.com/cookies-policy/legal.
9. Your rights
9.1. Under the GDPR you have the right to: access your data; rectification; erasure; restriction of processing; data portability; and to object to processing based on legitimate interest (including reminder e-mails — section 7).
9.2. To exercise any right, e-mail support@langusta.me. We respond within one month (extendable by two months for complex requests, with notice).
9.3. Account deletion: request it by e-mail to support@langusta.me; we execute deletion within 30 days. Backups are purged within a further 30 days. Billing records are retained as required by tax law (section 6).
9.4. Complaint to a supervisory authority: you may lodge a complaint with the President of the Personal Data Protection Office (Prezes UODO), ul. Stawki 2, 00-193 Warszawa, Poland, uodo.gov.pl — or with the supervisory authority of your habitual residence.
10. Children
10.1. The Service is intended for users aged 16 or older. We do not knowingly process data of children under 16. If you believe a child under 16 has created an account, contact us and we will delete it.
11. Security
11.1. We apply technical and organizational measures appropriate to the risk, including encrypted transmission (TLS), hashed passwords, access controls, and the data-minimizing design described in section 2 (no voice-audio storage).
12. Changes to this policy
12.1. We may update this policy, for example when we change processors or features. We will notify account holders of material changes by e-mail at least 14 days before they take effect. The current version is always available in the Service.