Privacy Policy
Last updated: 4 March 2026
This Privacy Policy describes how Winny Speaking EOOD ("Winny Speaking", "we", "us", "our") collects, uses, and protects personal data when you use our website, waitlist flow, mobile app, and related services.
1. Controller details
Winny Speaking EOOD
Crystal Business Center
38-40 Osogovo St.
Sofia, Bulgaria
Email: hi@winnyspeaking.com
2. Who this service is for
Winny Speaking is intended for users aged 13 and older. It is not directed to children under 13.
3. Data we collect
Depending on how you use our services, we may process:
- Account and sign-in details (such as email, display name, provider identifiers).
- Session data from the app (audio recordings, transcripts, context selections, scores, and feedback).
- Technical and usage data (app version, device metadata, diagnostics, and event analytics).
- Website/waitlist information you submit (name, email, role, message, and form metadata).
- Support communications when you contact us.
4. How we use data
- Operate and improve app and website functionality.
- Generate speech transcripts, score communication performance, and return feedback.
- Provide support, troubleshoot issues, and enforce security safeguards.
- Measure product performance and conversion using aggregated analytics.
- Comply with legal obligations.
5. Legal bases
- Performance of a contract (to provide requested app and service features).
- Legitimate interests (security, product improvement, and abuse prevention).
- Consent where required (for certain analytics/cookie settings or optional communications).
- Compliance with legal obligations.
6. AI and third-party processing
We use third-party cloud and AI providers to deliver service features such as authentication, transcription, and feedback generation. This may include Firebase/Google Cloud services and related processors. We limit data transfer to what is needed for feature operation and apply reasonable security controls.
7. Data retention
- Audio recordings and transcripts are generally retained for about 30 days, then deleted/anonymized.
- Account and scoring history may remain until account deletion is requested.
- Technical logs and analytics are retained for limited operational periods.
8. Data sharing
We share data only with service providers needed to run hosting, analytics, support, and security. We do not sell personal data to advertisers.
9. International transfers
Where cross-border transfers occur, we rely on appropriate legal safeguards as required by applicable law.
10. Your rights
Depending on your jurisdiction, you may request access, correction, deletion, restriction, portability, or objection. Contact hi@winnyspeaking.com to exercise rights.
11. Security
We apply technical and organizational safeguards, including encryption in transit, access controls, and operational monitoring. No system can be guaranteed 100% secure.
12. Payments and purchases
If paid app plans are introduced, iOS purchases are processed by Apple. We do not receive full payment card details from Apple transactions.
13. Changes to this policy
We may update this policy from time to time. Material updates are reflected by revising the "Last updated" date and, where appropriate, in-app or email notice.