1. Data We Collect

We collect information you provide directly, such as your name, email address, phone number, and account type when you register. We also collect data about your use of the Service, including lesson progress, exercise scores, and session history, to provide and improve our learning features.

Depending on the features you use, we also collect:

• •Profile photo — optional. Shown on your profile and, if you are visible to recruiters, in employer search results.
• •Voice recordings — your optional spoken introduction, and recordings made during pronunciation exercises. Pronunciation recordings are processed to score your speech and are not shown to other users.
• •Precise location — optional, and only when you set your location on the map while editing your profile. It is used to show your approximate area to employers searching nearby and to sort results by distance. You can remove it at any time from your profile.
• •Payment records — the plan or lesson package purchased, the amount, and the payment reference from our payment provider. We never receive or store your card number.
• •Device permissions — camera and photo library (to set a profile photo), and microphone (for pronunciation exercises and 1:1 lessons). Each is requested only when you use that feature and can be refused without losing access to the rest of the Service.

1A. Review of Photos and Voice Recordings

Every profile photo and voice introduction is screened automatically before it is saved. Photos are checked for offensive content and for whether they show a single, clearly visible face; recordings are transcribed and the words checked for offensive content. Anything that fails is refused at the moment you upload it, with a reason, and is never stored on your profile. If the check cannot be carried out we ask you to try again rather than publish something unchecked.

Screening is automated and no person listens to or looks at your upload as part of it. A person becomes involved only if another user reports your profile afterwards. This protects everyone using the Service from offensive or impersonating content.

Automated screening is not perfect, and it errs on the side of refusing. If your photo or recording is refused and you believe that is wrong, contact us at the address at the end of this document.

If content is removed following a report, we keep a record of the decision so we can handle appeals and repeat problems. You can report or block another user at any time from their profile; blocking hides you from them and them from you.

2. How We Use Your Data

We use your data to:

• •Provide and personalize the Service
• •Process payments and manage subscriptions
• •Track your learning progress and completion
• •Send important service notifications
• •Improve our content and platform through analytics

2A. Data Shared Between Learners and Employers

If you are a learner and choose to make your profile visible to employers, the following information may be shared:

• •Your name, profile photo, language progress, completed courses, and any optional information you provide (e.g., work experience)

If you are an employer, your company name, job posts, and contact information may be visible to learners.

You control your visibility settings. Learners can opt out of employer discovery at any time in Account Settings.

2B. Employer Access to Learner Data (Corporate / LMS Feature)

If an employer purchases a paid subscription to the Learning Management System (LMS) feature, they may track the progress of learners who are part of their own business or organization only (e.g., their existing staff members). This includes:

• •Lesson completion
• •Quiz and exercise scores
• •Overall course progress

Employers may not access progress data of learners outside their organization. Learners will be informed when their employer enrolls them in the LMS, and continued use under that arrangement constitutes acknowledgment of data sharing with their employer.

FluentStaff does not share individual learner data with any third-party employer unless: the learner is actively employed by that business, the employer has a valid LMS subscription, and the learner has been notified.

Employers may not access data of learners who work for affiliated companies (e.g., sister companies, franchises, or parent organizations) unless those learners are explicitly employed by the same legal entity that holds the LMS subscription.

3. Data Sharing

We do not sell your personal data. We may share your data with trusted third-party service providers (such as payment processors and cloud hosting providers) solely to operate the Service. For corporate accounts with LMS access, we share relevant progress data with your organization's administrators as described in Section 2B.

4. Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Service. You may request deletion of your account and associated data at any time through Account Settings.

Special case for employer-sponsored LMS accounts: If your account is part of an employer-paid LMS subscription, your data deletion request may be delayed until the employer's subscription ends, the employer confirms in writing they have released your data, or 90 days pass after your employment ends (whichever is earliest).

You will be notified of any delay within 14 days of your deletion request. During this period, your data will only be visible to your employer, not to other users.

4A. No Sale of Data

We do not sell learner or employer data to third parties. Job post data is used only to facilitate connections on our platform.

5. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet is 100% secure.

6. Cookies and Analytics

Our mobile application does not use browser cookies. We may use analytics tools to understand how users interact with the Service. This data is aggregated and does not identify you personally.

7. Your Rights

You have the right to access, correct, or delete your personal data. You may also object to certain processing or request data portability. To exercise these rights, please contact us at mayra@fluent-staff.com.

8. Children's Privacy

The Service is not directed to individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, please contact us immediately.

9. Changes to This Notice

We may update this Privacy Notice periodically. We will notify you of significant changes via in-app notification or email. Your continued use of the Service constitutes acceptance of the updated Notice.

10. Contact

mayra@fluent-staff.com