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Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data. With this Privacy Policy (“Policy”), we explain how HubX Yazılım Hizmetleri Anonim Şirketi (“HubX”) collects and processes your information and personal data, the protection and privacy, and data security measures implemented, including your rights.

This Policy is applicable on BetterSpeak's app, website and social media platforms owned by BetterSpeak (collectively “BetterSpeak / Services / Website”).

Collection of Information and Processing Purposes

We may collect the following information and personal data when you access BetterSpeak, or otherwise utilize (“use”) the Website, and/or the Services:

  • 1. Personal Information and Contact Information
  • Name, Google Account or Apple ID (whichever you preferred to log in), Language and proficiency level, E-mail address

This information is used to create BetterSpeak subscription, to form a history of your exercise and language practice history and communicate with you through or about BetterSpeak, updates or your requests.

  • 2. Technical Data
  • IP address, logs, device type and name, operating system, type and date of subscription.

These data are processed for the purpose of ensuring the functionality of the app, crash and error detection, conducting technical analysis, carrying out the activity in accordance with the legislation and technical data security.

  • 3. Customer Transaction
  • Subscription plan, billing cycle.

This data is processed for the purpose of determining the customer's subscription plan, providing and improving the services and membership plans, to follow and provide coin purchases. No credit card information is collected by us.

  • 4. Marketing and Analytics Data

Analytics data (session duration, feature interaction), user preferences (language, theme), identifiers, interaction within the app, marketing emails or ads.

These data are processed to deliver and personalize advertising and in-app content, run promotional campaigns, measure marketing performance, and gather insights to improve our products and features. We may send push notifications for marketing purposes and use identifiers for advertising (IDFA on iOS, GAID on Android, Firebase, Appsflyer) analytics upon your permission. These data are processed for marketing purposes, personalized advertising and contents, and providing insights for product development. Please note that you can withdraw your consent any time.

  • 5. The Information Disclosed by Users

Within the scope of the data minimization principle adopted in accordance with the GDPR, BetterSpeak takes care not to process any data other than the above and is unnecessary for the application. Data that is not included in the app but shared through contact, upload or other means is deemed to be disclosed by users. These are also protected within the scope of relevant legislation and adequate data protection measures.

Speaking Practices: For speaking practice features, users may interact with the tutor through voice. Voice input is processed in real time to enable conversational functionality with prior consent to microphone access. Please note that recordings are stored only on the user’s own device for personal playback or learning purposes. We do not access, transmit, or retain voice data beyond the real-time processing needed to provide the service. You may disable microphone access anytime by your device settings.

Age Restriction: BetterSpeak has an age restriction as it is not intended for Users under the age of 13. If you are under 13 years of age, please do not use or access the App and Website at any time or in any manner. By using the App and Website, you affirm that you are over the age of 13.

Parent/Guardian Use: Parents and guardians are strongly encouraged to notify BetterSpeak if their children under the age of 13 are using the app. Please note that BetterSpeak does not collect information from children under the age of 13 in accordance with the Children's Online Privacy Protection Act ("COPPA") as indicated in this Privacy Policy and the Terms.

Parents and legal guardians are welcome to use the app together with their children to support and improve their language skills. However, we strongly recommend that parents actively supervise their children's use of the app at all times to ensure appropriate usage and to guide their learning experience.

Sharing of Information

Your personal data will not be sold, traded, or otherwise transferred to third parties for commercial purposes. Your data may be transferred for the reasons explained below:

  • (a) Service Providers: We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and cloud services. This includes cloud providers (Google, CloudFlare), data analytics providers (Google, Appsflyer, Firebase). Please note that payments are processed through Google and Apple, and we do not access, store or share any credit card information.
  • (b) Business and Communication Partners: We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services. This includes service providers (Intercom, Firebase).
  • (c) Law Enforcement and Public Authorities: We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Anonymized Data: We may use anonymized data for analytical purposes. Anonymized data is processed in such a way that it can no longer be attributed to a specific individual, ensuring your privacy is maintained. Please review the Data Destruction and Anonymization heading for the process.

AI Technologies: This app uses artificial intelligence technologies for AI tutor features and practices. By using the app, you acknowledge and agree that certain outputs and interactions are generated or assisted by AI systems, which may not always be error-free or reflect human judgment. We continuously work to improve AI performance, but users are encouraged to apply their own discretion when relying on AI-generated responses. This app is created for educational purposes and personal use only.

Storage of Information

We are committed to ensuring that your personal data is stored securely and in compliance with applicable laws and regulations.

Retention of Personal Information

We may store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Data Destruction and Anonymization: When personal data is no longer necessary or the retention period has expired, we will either securely delete or destroy the data to prevent unauthorized access or retrieval, or we will anonymize the data. Anonymization involves processing the data in such a way that it can no longer be attributed to you, ensuring that it can be used for analytical or research purposes without compromising your privacy. Once data is anonymized, it is irreversibly altered and cannot be traced back to any individual.

Security Measures

We take the security of your personal data very seriously and implement measures to ensure protection as of the General Data Protection Regulation (GDPR). Our key principles include:

  • Safety Measures: Personal data is processed within the company only by authorized personnel, in a way that is not publicly accessible, and verification or additional confidentiality declarations required in processing special data categories if available.
  • Access Controls: Access to personal data is restricted to authorized personnel only, ensuring that only those who need to access your information can do so.
  • Regular Security Audits: We conduct regular audits and assessments of our security practices to identify and address potential vulnerabilities.
  • Data Minimization: We only collect and retain personal data that is necessary for the purposes specified.
  • Incident Response Plan: We have established an incident response plan to quickly address any potential data breaches or security incidents.

While we strive to maintain a secure digital environment, yet no digital environment can be fully secure, we encourage users to take their own precautions when accessing and using the app, including utilizing relevant antivirus software, implementing a secure firewall, accessing the website over a safe Wi-Fi connection, and ensuring that the device used to access the app is secure and up to date.

In the event of any potential data breach or security incident, users are encouraged to inform HubX immediately. We will analyze the situation to determine if there is a security problem and take necessary measures to mitigate any risks. Your security and privacy are our top priorities, and we are committed to maintaining adequate standards of data protection as required by relevant legislation.

Corporate Affiliates and Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of BetterSpeak or any of its Corporate Affiliates. Please note that Corporate Affiliate means any person or entity which directly or indirectly controls, is controlled by or is under common control with BetterSpeak, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Delete Account Policy

Users can delete their account at any time by logging in, navigating to Account Settings, selecting “Delete Account,” and confirming the action using a system-generated code. Once confirmed, the account and all associated personal data will be permanently deleted and cannot be recovered, except when we are legally required to retain under applicable laws. Anonymized data that does not personally identify the user may be retained for analytical purposes. Account deletion results in the immediate loss of access to all services and subscriptions, which will be terminated without refunds. This action is irreversible. In cases where legal obligations or unresolved transactions exist, deletion may be delayed until those matters are resolved.

Users may request the erasure of their personal data in line with GDPR requirements. Requests must be submitted to our support team via support@betterspeak.com along with the User ID for verification. Verified requests will be fulfilled within the legal period. Please note that this method is manuel, so we recommend using “Delete Account” through settings for easier and quicker processing, as explained above.

Rights Under GDPR

The General Data Protection Regulation No. 2016/679 (GDPR) establishes a comprehensive framework for the protection of personal data within the European Union and the European Economic Area. Under GDPR, users have the following rights regarding their personal data as data subjects:

  • Right to Access: Obtain confirmation and access to personal data being processed.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure: Request deletion of personal data under certain conditions.
  • Right to Restrict Processing: Request limitation of data processing in specific situations.
  • Right to Data Portability: Receive personal data in a machine-readable format and transfer it to another controller.
  • Right to Object: Object to the processing of personal data, especially for direct marketing.
  • Rights Related to Automated Decision-Making: Not to be subject to decisions based solely on automated processing, unless certain conditions apply.

To exercise these rights, users must send an email or petition clearly stating the right they wish to enforce, along with their name and accurate contact details. A response will be provided within the legal time period.

California Residents

The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.

We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:

  • Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
  • Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
  • Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
  • Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. Please note that we do not sell the personal information of our users. For more information about these rights, please contact us.

Updates to Privacy Policy

We reserve the right to update this privacy policy at any time to reflect changes in our practices, legal obligations, or operational needs. Users are encouraged to review this policy regularly to stay informed about how we protect their personal data and to understand their rights and responsibilities. The revision date is stated in the introduction of the policy. Any updates will take effect immediately upon posting. If users do not agree with the amendments, they should discontinue using the app. Continued use of the website after such updates constitutes acceptance of the revised policy.

Contact

This privacy policy constitutes the entire understanding between you and us regarding the collection, use, and protection of your personal data. If you have any questions or concerns regarding this policy or our data practices,
please contact us via support@betterspeak.com

  • HubX Yazılım Hizmetleri Anonim Şirketi
  • Çınarlı Mah. Ankara Cad. No:15 D:411 35170 Konak/İzmir

Last Update: August 2025