The privacy of Accentlo users matters to us. This policy explains what personal data we collect, for what purpose, on what legal basis, and what rights you have under the General Data Protection Regulation (GDPR).
1.Data controller
The controller of your personal data is Łukasz Zawiśliński, Łukowo 50, 06-425 Karniewo, Poland, the owner and provider of the Accentlo service (accentlo.com).
For matters concerning the protection of personal data, you can contact us at: support@accentlo.com.
2.What data we collect
Depending on how you use the platform, we may process:
- Account data: email address, username, encrypted password.
- Subscription and payment data: subscription plan, payment history, subscription status (payments are handled by an external provider — see point 5).
- Voice recordings: audio files recorded during pronunciation exercises (see point 4).
- Progress data: exercise results, number of recordings made, learning statistics.
- Technical data: IP address, browser and device type, system logs.
3.Purposes and legal bases for processing
- Providing the service (access to the platform, exercises, pronunciation scoring) — Article 6(1)(b) GDPR (performance of a contract).
- Handling payments and subscriptions — Article 6(1)(b) and (c) GDPR (legal obligations, e.g. tax).
- Contact and handling enquiries — Article 6(1)(b) and (f) GDPR (legitimate interest).
- Analysis and improvement of the service — Article 6(1)(f) GDPR (legitimate interest).
- Marketing (where applicable) — Article 6(1)(a) GDPR (consent), which you can withdraw at any time.
4.Voice recordings
Pronunciation practice is at the heart of Accentlo, which is why we process recordings of your voice. We want you to know exactly how this works:
- Recordings are created only when you start recording within an exercise yourself.
- The recording is sent to a speech recognition and scoring service in order to transcribe it and generate feedback on your pronunciation.
- To analyse the recording and generate feedback, we use AI models provided by Groq (running on open models such as Llama), which process the recording on our behalf.
- Recordings are not stored — they are processed only in real time to generate the score, and then deleted immediately. We do not save them on our servers. We also do not store the content of conversations or conversational exercises.
If, in your case, voice recordings are considered a special category of data, their processing takes place on the basis of your explicit consent (Article 9(2)(a) GDPR). It is worth confirming this classification with a lawyer or data protection officer.
5.Data recipients
Your data may be entrusted to trusted entities that process it on our behalf under data processing agreements:
- Hosting provider — OVHcloud (VPS server, infrastructure in the European Union).
- AI model provider — Groq (pronunciation analysis and feedback generation based on open models such as Llama).
- Text-to-speech (TTS) provider — ElevenLabs and Accentlo's own solution (generating reference recordings).
- Payment processor — Stripe or PayPal (depending on the method chosen). Payment card details are handled solely by the payment processor and are not stored by Accentlo.
- Analytics tools — Google Analytics, activated only after you consent to cookies (see point 9).
We do not sell your personal data.
6.Transfers of data outside the EEA
Hosting is provided by OVHcloud using infrastructure in the European Union. Some of our providers process data outside the European Economic Area, including in the United States — these are Groq, ElevenLabs, Google (Google Analytics) and the payment processors Stripe and PayPal. In such cases, the transfer takes place on the basis of appropriate safeguards referred to in the GDPR, in particular the standard contractual clauses approved by the European Commission and, for providers holding the relevant certification, also on the basis of the Data Privacy Framework (EU–US).
7.Data retention period
- Account data — for as long as you hold an account, and after its deletion for the period required by law.
- Payment data — for the period required by tax regulations (as a rule, 5 years).
- Voice recordings — not stored; processed in real time and deleted immediately after the score is generated.
- Technical data and logs — stored for up to 24 months, or, if you request the deletion of all your data earlier, until that request is carried out.
8.Your rights
Under the GDPR, you have the right to:
- access your data and obtain a copy of it;
- rectification (correction) of your data;
- erasure of your data ("the right to be forgotten");
- restriction of processing;
- data portability;
- object to processing;
- withdraw consent at any time (without affecting the lawfulness of processing carried out beforehand);
- lodge a complaint with the President of the Polish Personal Data Protection Office (UODO).
To exercise these rights, email support@accentlo.com.
9.Cookies
The platform uses cookies and similar technologies (e.g. browser storage) in three categories:
- Essential — necessary for the site to function: logging in, maintaining your session, security, and remembering your cookie choice. They don't require consent and are always active. We store your consent choice in your browser's storage (localStorage).
- Analytics — help us understand how you use the site so we can improve it. We use Google Analytics. Disabled by default — they activate only after you give consent.
- Marketing — allow us to tailor messaging and measure its effectiveness (e.g. the Meta/Facebook pixel, Google Ads). Disabled by default — they activate only after you give consent.
Analytics and marketing scripts load only after consent is given in the cookie banner. You can change your choice at any time using the "Change cookie consent" link, and you can also manage cookies in your browser settings.
10.Changes to this privacy policy
We may update this policy, for example in connection with changes to the law or the scope of our services. We will notify you of material changes in a visible way. The current version is always available on this page.