Last updated: September 4, 2026
This Privacy Policy and our Terms of Service are meant to be read together: session-governance rules (human review, no scoring, institutional opt-in) live in the Terms, and data handling lives here. Users and Institutional Accounts in Mexico are also covered by the Mexico Regional Addendum.
FluenTea (“we,” “us,” or “our”) operates the FluenTea language learning platform. This Privacy Policy describes how we collect, use, and disclose personal data when you use our Service, and the choices you have. By using the Service, you agree to the collection and use of information as described here.
2.3.1 Consumer/Individual Accounts. Voice recordings for language learning purposes; chat messages between users; video call metadata (duration, participants).
2.3.2 Institutional Accounts. If you access the Service through an Institutional Account (a school, university, corporation, or other organization) that has activated ChaCha's AI observation features, we additionally collect and generate:
Transcripts of practice conversations during a session, including breakout rooms, are available to the Facilitator for that session. For practice outside a scheduled session, full transcripts are not made available to Facilitators or Institutional Account staff; instead, the Institutional Account receives a limited, defined dataset of high-level metrics (for example, time spent practicing, growth areas, strengths).
ChaCha may retain a limited, user-visible memory of key facts you share with it and summaries of your recent sessions, to personalize coaching over time. This memory is transparent and editable in your account settings, and is not used to train or fine-tune FluenTea's underlying AI models.
FluenTea does not currently perform voice-fingerprinting, speaker identification, or other biometric identification. If this changes, we will provide biometric-specific notice, consent, retention, and destruction terms before that processing begins, consistent with applicable biometric privacy laws.
FluenTea's AI systems do not infer, and are not designed to infer, the emotional or affective state of any user. ChaCha's prompting has been affirmatively reviewed to confirm this as of August 2026 (see our Terms of Service, Section 5.1).
We use the collected data:
For Institutional Accounts, session transcripts are not used to improve or train FluenTea's models by default. An Institutional Account may opt in to this use via a separate written agreement. This is an institutional decision, not one collected from each student individually (see Section 2.3.2). For individual, personal accounts, session data may be used to improve the Service and FluenTea's AI models, consistent with this policy.
FluenTea personnel and select vendors (Section 10) may review session transcripts to draft coaching materials, refine product policy, and provide quality review, under human supervision. This is distinct from, and does not itself constitute, training or fine-tuning an AI model, and is subject to the same Institutional Account opt-in described in 3.1 where Institutional Account data is involved.
Self-service accounts require the account holder to be at least 16. This age floor is not available to be lowered for individual/consumer signups under any circumstance.
Where a school or educational Institutional Account provisions accounts on behalf of students, the following applies by age, consistent with our Terms of Service, Section 3.3:
This is institution-level consent; FluenTea does not separately collect consent from each student beyond the mechanism above. In Mexico, a different rule applies: see the Mexico Regional Addendum.
A parent or legal guardian of a provisioned User under 16 may contact FluenTea directly to review or request deletion of that minor's data, independent of the student's own access rights and independent of the Institutional Account.
Where FluenTea processes education records subject to the U.S. Family Educational Rights and Privacy Act on behalf of a US educational institution, FluenTea acts as a “school official” with a legitimate educational interest: it uses such records solely to provide the Service, does not redisclose them except as directed by the institution or required by law, and deletes or returns them at the institution's request consistent with our Terms of Service, Section 12.2.
We use industry-standard security measures, including encryption in transit, to protect your personal data. No method of transmission is completely secure.
In the event of a data breach affecting your personal data, we will notify affected Institutional Accounts and, where required by applicable law, affected individuals, without undue delay and in any event within 72 hours of becoming aware of the breach, consistent with GDPR's notification standard. Institutional Accounts may negotiate a different notification timeline in a separate written agreement.
We retain personal data only as long as necessary for the purposes described in this policy and the specific retention periods stated in Section 2. Upon deletion of your account, we delete your personal data within 30 days, except where retention is required by law, to resolve an active dispute, or to enforce our agreements (consistent with our Terms of Service, Section 12.1). For Institutional Accounts, this is subject to the education-records handling described in Section 4.4.
If you are in the EEA or UK, you have the right to:
We will respond to requests without undue delay, and in any event within one month of receipt, extendable by two further months for complex requests as permitted by law. To exercise these rights, contact privacy@fluentea.com or use your account settings.
Legal basis for processing depends on context: performance of a contract, your consent, our legitimate interests in operating and improving the Service, or compliance with legal obligations.
International transfers. Where we transfer personal data from the EEA/UK to the United States or other countries, we rely on Standard Contractual Clauses or another lawful transfer mechanism recognized under applicable law.
EU Representative. FluenTea has designated Nancy Wang, Berlin, Germany as its representative in the European Union under Article 27 GDPR for matters relating to this Service. Contact: eu-privacy@fluentea.com.
If you are in Mexico, you have ARCO rights under Mexico's Federal Law on Protection of Personal Data Held by Private Parties: Access to your personal data, Rectification of inaccurate data, Cancellation (deletion) of your data, and Objection to specific processing. To exercise these rights, contact privacy@fluentea.com. Where we transfer your personal data outside Mexico (including to the United States), we require the recipient to maintain data protection obligations consistent with Mexican law.
The Spanish-language Aviso de Privacidad Simplificado, the parental-consent rule for students under 18, and other Mexico-specific terms are in the Mexico Regional Addendum.
California residents have the right to know what personal information we collect, request deletion, correct inaccurate information, and limit use of sensitive personal information, and may not be discriminated against for exercising these rights.
We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. Our analytics tools (Google Analytics, Microsoft Clarity; see Section 10) are used solely for internal product analytics and are not used for cross-context ad targeting or ad-network data sharing. Because of this, a “Do Not Sell or Share My Personal Information” opt-out is not applicable to our current practices; if this changes, we will implement the required opt-out mechanism before doing so.
To exercise your California rights, contact privacy@fluentea.com.
We use cookies and similar tracking technologies to operate and understand use of the Service. You can instruct your browser to refuse cookies or alert you when they are set.
We share personal data with the following sub-processors, who process it only on our behalf and only to provide their part of the Service:
We will provide notice before adding a new sub-processor that will process Institutional Account data, and Institutional Accounts may object consistent with any applicable written agreement. We do not sell personal data and do not share it with third parties for their own independent purposes.
If you connect the FluenTea Room add-on for Google Calendar, FluenTea requests access to your Google account to attach and manage language-practice rooms on your calendar events. The Google user data we access is limited to:
We do not read or store attendee lists, guest email addresses, event descriptions, attachments, or the contents of any event for which you have not created a FluenTea Room. This Google data is transmitted only to FluenTea's own backend to operate the room, and is deleted or deactivated when you remove the room, delete the event, or disconnect the add-on. It is never shared with any advertiser or data broker, and it is never transferred to any third-party AI/ML service.
Limited Use. FluenTea's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In particular, we do not use, transfer, or sell Google Workspace API data (raw, aggregated, or derived) to develop, improve, or train generalized or foundational AI/ML models.
An Institutional Account engaging FluenTea at scale may execute a separate Data Processing Addendum or other written agreement governing data handling. In the event of conflict, that agreement supplements and, where inconsistent, supersedes this Privacy Policy for that Institutional Account, consistent with our Terms of Service, Section 5.8.
If you have any questions about this Privacy Policy, please contact us:
Email: privacy@fluentea.com
Address: FluenTea Inc., Cincinnati, OH, USA