Privacy Policy

Effective date: November 30, 2025

Last updated: November 20, 2025

Welcome to Speakly. This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you use our online education platform and related services.

At Speakly we are committed to protecting your privacy and being transparent about our data handling practices. This policy takes into account major data protection regulations and we strive to apply internationally recognized privacy principles.

1. Identification of the Data Controller

Speakly is the controller of your personal data.

Contact information for privacy inquiries:

• Email: info@speakly.fun
• Website: www.speakly.fun

This policy applies to all users of the Speakly platform, regardless of geographical location, including users in China, Europe, North America, and other regions.

2. Information We Collect

2.1. Registration and Account Data

When you create an account on Speakly, we collect:

• Full name
• Email and/or phone number: Used as primary identifier and for communications
• Password: Stored encrypted through secure hashing
• Country of residence: To determine prices, currency, and time zone
• Time zone: To facilitate calendar management

2.2. Profile Data

To personalize your experience, we collect:

• Avatar or profile picture (optional)
• Language preferences: Available interface display languages: Spanish, English, and German
• Notification preferences: Channels and types of notifications you wish to receive
• Parental control PIN (optional): If you activate this security feature

2.3. Student Sub-profile Data

If you create additional sub-profiles within your account (up to 3 sub-profiles), we collect:

• Student name
• Date of birth: To automatically calculate age and apply specific protections for minors
• Avatar or profile picture (optional)
• Gender

Minor protection: When a sub-profile corresponds to a minor, we apply special protection measures described in Section 7 of this policy.

2.4. Payment and Transaction Data

To process class package purchases:

• Payment information: Processed and stored securely by our payment service provider Airwallex.
• Transaction history: Date, amount, currency (CNY, EUR, USD), payment method, purchased package
• Applied coupons and discounts: For billing and analysis purposes

2.5. Academic and Service Usage Data

To provide quality educational services, we collect:

Class History:

• Scheduled, completed, canceled without penalty, canceled with penalty, and no-shows (absences without notice)
• Date, time, and duration of each class
• Class language
• Assigned teacher

Evaluations and Reports:

• Initial Placement Test (IPT): Initial assessment of proficiency level
• Progress Reports: Generated every 20 class hours
• Post-class feedback: Teacher comments within 24 hours after each session
• Academic observations from the teacher and Speakly's academic team

Balance Management:

• Available class balance by language
• Class types
• Package validity and expiration date
• Class consumption history

2.6. Class Video Recordings

All classes are automatically recorded through the ClassIn platform for educational and quality control purposes.

Recording content:

• Complete video and audio of the 30-minute class
• Visible participants (student and teacher)
• Materials shared during class
• On-screen interactions

Storage duration: Up to 3 months from the class date, after which they are automatically deleted according to ClassIn policies.

Access: Only the account owner student, the class teacher, and Speakly's authorized academic team have access to recordings.

Location: Recordings are stored on ClassIn servers, not on Speakly's own servers.

For more details about recordings, see Section 8 of this policy and Section 12.5 of our Terms and Conditions.

2.7. Communications and Support

When you communicate with us, we collect:

• Emails exchanged with our support team
• Messages sent through the platform

2.8. Third-Party Information

In certain cases, we may receive information about you from third parties:

• ClassIn: Class attendance confirmation, technical incident reports
• Airwallex: Confirmation of successful or failed transactions
• Referrals: If you were referred by another user

3. How We Collect Information

We collect information in the following ways:

3.1. Information Provided Directly by You

• When registering and creating your account
• When creating student sub-profiles
• When completing your profile
• When purchasing class packages
• When scheduling and canceling classes
• When communicating with our support team
• When participating in surveys or providing feedback
• When configuring your notification preferences

3.2. Automatically Collected Information

• Technical data when accessing the platform (IP, device, browser)
• Activity and functionality usage logs
• Automatic class recordings through ClassIn

3.3. Third-Party Information

• Payment verification data from Airwallex
• Attendance and technical performance information from ClassIn
• Public social media data if you link your account (optional)

4. Legal Basis for Data Processing

We process your personal data in accordance with the following legal grounds:

4.1. Contract Performance

We process your data when necessary to:

• Provide the educational services you contracted
• Create and manage your account
• Process payments and transactions
• Schedule and conduct classes
• Generate academic reports
• Provide customer support

4.2. Legal Obligation

We process your data when necessary to comply with legal obligations:

• Tax and accounting obligations (retention of transaction data)
• Minor protection requirements according to applicable laws
• Legal requests from competent authorities
• Compliance with data protection regulations
• Record retention according to applicable laws

5. How We Use Your Information

We use your personal information for the following purposes:

5.1. Provide and Administer Educational Services

• Create, maintain, and manage your account and sub-profiles
• Authenticate your identity through OTP (one-time password) verification
• Facilitate class scheduling according to teacher availability
• Synchronize your profile with ClassIn for live class access
• Manage your class balance by language and type
• Apply package validity and expirations
• Process cancellations
• Manage absences (no-shows) and refund policies
• Provide access to class recordings for educational review

5.2. Payment and Transaction Processing

• Process class package purchases
• Apply adapted prices according to region and language
• Process promotional coupons and discounts
• Generate electronic receipts and invoices
• Manage refunds according to our policy (exceptional cases)
• Maintain transaction history accessible to the user
• Prevent fraud and unauthorized transactions
• Comply with tax and accounting obligations

5.3. Academic Evaluation and Report Generation

• Evaluate competencies, skills, and academic progress
• Provide personalized pedagogical recommendations

5.4. User Communications

Critical notifications (non-deactivatable):

• Registration confirmation and account verification
• Package purchase confirmation and receipts
• Scheduled class reminders
• Cancellation and rescheduling confirmations
• Account security alerts
• Package expiration notifications

Optional communications (configurable):

• Promotions and special offers
• Exclusive discounts and coupons
• Reminders of unused classes nearing expiration
• Speakly news and updates
• Satisfaction survey invitations
• Educational content and learning tips

5.5. Experience Personalization

• Show teacher availability according to your time zone
• Adapt interface according to your notification preferences
• Consolidate class calendar
• Provide personalized dashboard with relevant metrics

5.6. Service Improvement and Development

• Analyze usage patterns to improve the platform
• Identify and correct technical errors
• Develop new functionalities based on user needs
• Optimize platform performance
• Evaluate pedagogical methodology effectiveness
• Generate aggregated and anonymized statistics

5.7. Quality Control and Academic Supervision

• Review class recordings to evaluate teaching quality
• Identify areas for improvement in teacher performance
• Ensure compliance with pedagogical standards
• Resolve disputes between students and teachers
• Validate authenticity of academic reports
• Detect inappropriate behaviors or policy violations

5.8. Security and Fraud Prevention

• Detect and prevent unauthorized account access
• Monitor anomalous usage patterns
• Investigate terms and conditions violations

5.9. Marketing and Analysis (only with consent)

• Send promotional communications about new services or discounts
• Personalize offers according to your interests and behavior
• Analyze marketing campaign effectiveness
• Segment audiences for specific communications
• Use of recordings for promotional purposes: Only with explicit, prior, informed, and separate consent, with guaranteed anonymization (see Section 8.4)

6. With Whom We Share Your Information

Speakly never sells your personal data to third parties for marketing or advertising purposes. We only share your information in the following limited circumstances:

6.1. Essential Service Providers

We share data with external providers who help us provide our services:

6.1.1. ClassIn (Live Class Platform)

Information shared:

• Student name
• Unique student identifier
• Scheduled class times
• Basic profile information for class access

Purpose: Facilitate live classes and automatic recording for educational purposes.

ClassIn privacy policy: ClassIn has its own independent privacy policy. We recommend reviewing it on their official website. https://www.classin.com/agreement/?type=privacy

6.1.2. Airwallex (Payment Processor)

Information shared:

• Credit/debit card information (processed directly by Airwallex)
• Account holder name
• Billing address (if required)
• Transaction amount, currency, and description

Purpose: Process payments securely in multiple currencies (CNY, EUR, USD) and payment methods (cards, WeChat Pay, Alipay, PayPal).

Security: Airwallex complies with PCI-DSS (Payment Card Industry Data Security Standard) standards. Speakly does not store complete card numbers.

6.2. Speakly Teachers

Information shared:

• Student name
• Initial proficiency level
• History of previous classes with that teacher
• Relevant academic information to personalize teaching
• Observations from previous teachers (if relevant for pedagogical continuity)

Information NOT shared:

• Payment or financial data
• Contact information
• Data from other sub-profiles in the account

Purpose: Allow teachers to prepare personalized classes and generate accurate academic reports.

Confidentiality: Teachers are subject to contractual confidentiality obligations.

6.3. Speakly Academic Team

Information shared:

• Reports generated by teachers (for validation)
• Class recordings (for quality control)
• Post-class feedback
• Aggregated academic data for methodology analysis

Purpose: Validate academic reports (two-phase process), ensure pedagogical quality, and improve educational services.

Restricted access: Only authorized academic personnel with confidentiality agreements.

6.4. Infrastructure and Technology Providers

We use hosting, cloud storage, database, and technical service providers to operate the platform:

• Hosting/cloud computing services: To store user data and operate the platform
• Email services: To send notifications and communications
• SMS services: To send OTP verification codes
• Analytics tools: To understand platform usage (anonymized data when possible)

Information shared: Only the minimum necessary for them to provide their technical services.

6.5. Legal Authorities and Regulatory Compliance

We may disclose your information when:

• Legally required: In response to court orders, subpoenas, or valid legal requests
• To protect rights: When necessary to enforce our Terms and Conditions or protect our legal rights
• Prevent fraud or crimes: To investigate or prevent illegal activities, fraud, security threats
• Protect safety: When necessary to protect the safety of our users, employees, or the public

7. Minor Data Protection

Speakly takes the privacy protection of minors very seriously. This section describes our specific practices for minor protection, in line with internationally recognized principles. As established in our age of majority declaration policy, we require account owners to be of legal age.

7.1. Minor Class Recordings

Minor classes are automatically recorded like adults', but with additional protections:

Recordings for educational purposes:

• Applicable to all (minors and adults)
• Implied consent when using the service (clearly explained to the parent/guardian)
• Restricted access: only student (supervised by parent/guardian), teacher, and academic team

Recordings for promotional purposes:

• Requires explicit, separate, and verifiable consent from the parent/guardian
• Completely optional and revocable at any time
• Anonymization measures: covered, blurred, or pixelated faces, removal of names and identifiable data
• For minors: reinforced parental verification process

Parental consent verification process for promotional recordings:

1. Confirmation email sent to Account Owner
2. Detailed explanation of proposed use with visual examples
3. Independent checkbox (not pre-checked)
4. Prominent and easy-to-exercise right of revocation

7.2. Rights of Parents/Guardians

Fathers, mothers, or legal guardians have special rights over minors' data:

Right of access:

• View all information collected about the minor
• Access reports, class history, and recordings

Right of rectification:

• Correct inaccurate information in the minor's profile

Right of deletion:

• Request deletion of the minor's sub-profile
• Request deletion of recordings (within the 3-month period they are available)

Right of objection:

• Object to certain minor data processing

Right of revocation:

• Withdraw consent at any time without affecting legality of prior processing

How to exercise these rights:

• From the Owner's account settings
• By contacting: info@speakly.fun
• Response time: Generally within 30 days (may be extended in complex cases as permitted by applicable laws)

7.3. Parental Control and Supervision Tools

Speakly offers tools for parents/guardians to supervise platform use by minors:

Parental Control PIN:

• Protects account settings
• Prevents unauthorized changes to minors' sub-profiles
• Restricts access to payment information
• We recommend activating this functionality

Consolidated Calendar:

• Allows the Owner to view all scheduled classes from all sub-profiles
• Facilitates supervision of minor's educational activity

Notifications to Owner:

• Confirmation of each class scheduled by a minor sub-profile
• Availability of new academic reports
• Absence alerts (no-shows)

7.4. Enhanced Security for Minors

We apply additional security measures to protect minors:

• Direct messaging prohibition: Minors cannot send direct messages to teachers outside the class context
• Content monitoring: Proactive review of recordings to detect inappropriate behaviors
• Incident reporting: Quick mechanism for parents/guardians to report concerns

7.5. Minor Protection Principles

We apply the following minor protection principles:

• Verifiable parental consent: We do not collect personal information from minors without consent from the father, mother, or legal guardian
• Transparency: Clear notification to parents/guardians about our data collection and use practices
• Parental rights: Parents/guardians can review, correct, and delete the minor's data at any time
• Data minimization: We only collect information strictly necessary to provide the educational service
• Enhanced protection: Additional security measures for minors' data
• Data sharing restriction: We do not share minors' information with third parties without explicit parental consent

8. Class Recordings: Detailed Privacy Policies

8.1. Automatic Recording for Educational Purposes

All classes on Speakly are automatically recorded through the ClassIn platform.

Purpose of automatic recording:

• Educational review: Allow the student to review class content
• Quality control: Evaluate and improve pedagogical quality
• Legal protection: Documentary backup for disputes or incidents
• Academic supervision: Validate teaching methodologies

Consent:

By using Speakly services, you expressly accept automatic class recording for educational purposes. This consent is incorporated in the acceptance of our Terms and Conditions.

Recording content:

• Complete class video (30 minutes)
• Student and teacher audio
• Materials and presentations shared on screen
• Interactions during class

8.2. Storage and Access to Recordings

Storage location:

• Recordings are stored on ClassIn servers (not on Speakly's own servers)
• ClassIn is responsible for the physical and technical security of recordings

Retention period:

• Up to 3 months from the class date
• After this period, recordings are automatically deleted according to ClassIn retention policies
• We do not make backup copies outside of ClassIn

Restricted access:

Only authorized personnel can access recordings, including:

• The profile holder student (or parent/guardian if minor)
• The teacher who taught the class
• Speakly's authorized academic team (for validation and quality control)
• Technical staff when necessary to resolve incidents or ensure service operation

Access is limited to the minimum necessary to fulfill the educational and operational purposes described in this policy.

Access security:

• Authentication required to view recordings
• Access logs recorded for audit
• Access links expire after the 3-month period

8.3. Prohibitions of Unauthorized Use

It is strictly prohibited for all users:

Download recordings outside the ClassIn platform

Screen capture or take screenshots of recorded classes

Make secondary recordings (record the screen while playing the class)

Share, distribute, or publish recordings by any means (social media, YouTube, messaging platforms, etc.)

Allow unauthorized third parties to view recordings

Use recordings for commercial purposes or outside personal educational context

Reasons for these prohibitions:

• Teacher privacy protection
• Protection of other participants (in future group classes)
• Compliance with applicable data protection laws
• Protection of intellectual property of Speakly educational materials

Consequences of violation:

• Immediate account cancellation without refund
• Report to competent authorities in serious cases
• Civil liability for damages caused

8.4. Use of Recordings for Promotional Purposes (OPTIONAL)

Speakly WILL NOT use class recordings for marketing, advertising, or promotional purposes WITHOUT your explicit, prior, informed, and written consent.

8.4.1. Optional and Voluntary Consent

This consent is:

• Completely OPTIONAL: Not a requirement to use Speakly services
• Voluntary: There is no negative consequence for refusal
• Separate: Independent from consent for educational recording
• Revocable: You can withdraw it at any time without affecting your class access

Lack of response or silence does NOT constitute consent.

8.4.2. Consent Process

When requested:

• During account registration (clearly separated checkbox and NOT pre-checked)
• At any time from your account management panel

8.4.3. Anonymization Guarantees

If you grant consent for promotional use, Speakly will implement the following measures:

Face anonymization:

• Student faces covered, blurred, or pixelated using professional editing techniques
• Reasonable efforts to hinder visual identification of the student
• Review of edited material before publication

Removal of identifiable data:

• Removal of materials containing sensitive student data

Brief fragments:

• Only short fragments used (typically 10-30 seconds)
• Selected to demonstrate methodology and pedagogical effectiveness

Appropriate context:

• Use only in educational/promotional context of Speakly
• No use that could embarrass, defame, or harm the student
• Internal review before publication to ensure privacy protection

8.4.4. Consent for Minors

If the student is under 18 years old:

• Consent MUST be granted by the father, mother, or legal guardian (Account Owner)

The minor CANNOT grant this consent directly.

8.4.5. Promotional Use Channels

Only if you grant consent, Speakly may use edited and anonymized fragments on:

• Official Speakly website (www.speakly.fun)
• Corporate social media (Instagram, Facebook, YouTube, LinkedIn, TikTok)
• Asian social media (WeChat, Weibo, Douyin, Xiaohongshu)
• Digital marketing materials (online ads, landing pages)
• Commercial presentations and investor pitch decks
• Educational fairs and industry events

Will never:

• Be sold or licensed to third parties for their own use
• Be used in inappropriate contexts or unrelated to education
• Be modified to change the message or misrepresent student experience

8.4.6. Right of Revocation

You can withdraw your consent at any time:

How to revoke:

• From your account settings ("Privacy and Consents" section)
• By sending email to: info@speakly.fun
• Without need for justification

Effects of revocation:

• Speakly will stop using new material from that moment
• Already published material will be removed within a reasonable period (typically 30 days) from all digital channels directly controlled by Speakly
• Printed materials, in previous presentations, or shared by third parties may remain in circulation due to technical limitations inherent to those media
• Revocation does NOT affect your class access or service quality
• You will receive email confirmation when your request is processed

8.4.7. Transparency and Right to Information

At any time, you can request:

• Information about whether your recordings are being used for promotional purposes
• Which specific channels have published material
• What specific fragments are being used
• Expected duration of use

Response time: Generally within 30 days

Contact: info@speakly.fun

8.5. Procedure in Case of Objections to Educational Recording

If you have objections to the process of automatic class recording for educational purposes (Section 8.1):

You must contact us BEFORE taking your first class at: info@speakly.fun

Explain:

• Your specific privacy concerns
• Request NON-recording of live classes
• As a consequence you accept that no class will be recorded on ClassIn

9. Information Security

The security of your personal data is a fundamental priority for Speakly. We implement robust technical and organizational measures to protect your information.

9.1. Technical Security Measures

9.1.1. Authentication and Access Control

• Two-factor authentication (2FA): OTP verification by email or SMS when logging in
• Session expiration: Inactive sessions automatically expire after period of inactivity
• Password management: Complexity requirements (minimum 8 characters, uppercase, number)

9.2. Organizational Security Measures

9.2.1. Confidentiality Agreements

• Employees: All sign non-disclosure agreements (NDA)
• Teachers: Contracts with confidentiality clauses about student data

9.3. Payment Data Security

• Processing by certified third parties: Airwallex is our payment processor.
• No storage of complete card data: Speakly does not store complete card numbers, CVV, or expiration dates

9.4. Class Recording Security

• Storage on ClassIn: Physical and technical security responsibility of ClassIn
• Authenticated access: Only authorized users with prior authentication
• Access logs: Record of who accesses what recordings and when
• Automatic deletion: After 3 months, without additional copies

9.5. Your Responsibility in Security

You are responsible for:

Maintain secure passwords:

• Do not use obvious or easy-to-guess passwords
• Do not reuse passwords from other platforms
• Change your password if you suspect compromise

Not share credentials:

• Do not share your username and password with anyone
• Do not allow third parties to access your account

Log out on shared devices:

• Always log out if you use Speakly on public or shared computers

Maintain secure devices:

• Use antivirus and keep your operating system updated
• Do not access Speakly from unsecured public WiFi networks without VPN

Report suspicious activity:

• If you notice unauthorized activity on your account, immediately contact: info@speakly.fun

Verify communications:

• Speakly will never ask for your password by email
• Verify that emails come from @speakly.fun
• Beware of phishing attempts impersonating Speakly

10. Data Retention

Speakly retains your personal data only for the time necessary to fulfill the purposes described in this policy, unless the law requires or permits a longer retention period.

10.1. Account Deletion by User

Process:

You can request deletion of your account at any time:

• From Account Settings > Privacy > Delete Account

Last updated: November 30, 2025

Version: 1.0