Privacy Notice

Who we are

Habla is operated by Nikolay Vasilyev, a sole trader based in Spain, who acts as the data controller for the personal data described here. Contact: nick.vasiliev@gmail.com.

Who Habla is for

Habla is intended for adults. You must be at least 18 years old to create an account. We do not knowingly collect data from anyone under 18; if you believe a minor has created an account, contact us and we will delete it.

What we collect and why

Account data — email address, display name, sign-in identifiers (including Google sign-in). Used to create and secure your account. Legal basis: performance of our contract with you.
Voice recordings and transcripts — audio from your speaking turns is sent to our speech provider (ElevenLabs) to be transcribed, and the tutor's written replies are sent to the same provider to be turned into speech. Habla does not intentionally store raw audio in its own application database after processing — we keep the transcript, not the recording. ElevenLabs retains API request history by default and may hold request inputs and outputs, together with debugging and moderation logs, under its own documented retention windows (see "Who we share it with"). Audio and transcripts are sent to AI and speech services only after you allow it (see "AI and speech services" below). Legal basis for sending them to those services: your explicit consent.
Learning data — level estimates, grammar and vocabulary targets, mastery scores, streaks, XP, and personal details you volunteer in conversation (for example your job or interests) so the tutor can refer back to them. Sending it to AI services happens only with your permission (see below). Legal basis: performance of our contract.
Inferred learning-style signals — coarse indicators such as how much correction you seem to want or how formal you speak, used only to tune the tutor's behaviour. Legal basis: consent, which you can withdraw in Settings.
Support and feedback — messages, ratings and testimonials you send us. Legal basis: legitimate interests in improving the product.
Technical and usage data — device and browser information, IP address, error diagnostics, session timing and reliability logs, used for security, fraud prevention, debugging and product improvement. Our hosting provider (Lovable Cloud) also collects first-party, hosting-level operational and product analytics for us: page views and interactions, traffic source, device category (desktop, mobile or tablet), session and reliability metrics such as visit duration and bounce rate, and approximate country derived from the incoming traffic (IP address). We receive these only as aggregate statistics and use them to understand product usage, keep the service reliable, and for security and debugging. Legal basis: legitimate interests; legal obligation where applicable.
Email and notification preferences — reminder settings, push subscriptions, delivery and unsubscribe records. Legal basis: consent.
Referral data — if you join through another learner's invite link, we store that learner's invite code against your account so both rewards can be granted. From the invite link we capture only the invite code — no campaign or traffic-source metadata from the link. Legal basis: performance of the promotion you both joined.

AI and speech services (only with your permission)

Before your first lesson — and again whenever this list changes — the app asks for your explicit permission. Until you choose Allow, Habla sends nothing to these services: no microphone audio, no lesson text, no learner memory. If you choose Not now, you can still use Home, Progress, Settings, purchases, this notice and account deletion.

Lovable AI Gateway (Lovable) — Passes Habla's text requests on to Google and OpenAI. Receives: The same text that goes to Google and OpenAI.
Google (Gemini models) — Writes the tutor's replies, warm-ups and in-lesson summaries, keeps what the tutor remembers about you up to date, drafts the optional weekly coaching email, and is the backup for lesson analysis. Receives: Lesson transcripts, details you mention, what Habla remembers about you, your profile, progress and communication preferences.
OpenAI — Analyses finished lessons and writes your lesson report, helps the tutor find related things it remembers, and supports our team's lesson-quality review. Receives: Lesson transcripts, details you mention, what Habla remembers about you, your profile and progress.
ElevenLabs — Turns your voice into text and speaks the tutor's replies. Receives: Your voice recordings and the tutor's reply text. No separate learner-memory or profile record is sent to it, but the tutor's replies can mention things from your lesson or that Habla remembers about you (for example your job or plans), so that text reaches ElevenLabs too.

What is sent:

Voice recordings of what you say in lessons — sent only to ElevenLabs.
Transcripts of your lessons (your words and the tutor's).
Personal details you mention while talking (for example your job, family, plans), including when the tutor repeats them in a spoken reply.
What Habla remembers from past lessons: facts about you, topics and summaries.
Profile and progress: your level, goals, focus skills, mistakes and vocabulary.
Communication preferences, such as topics to avoid and how you like to be corrected.

Why:

Live tutoring: understanding you and replying by voice.
Lesson reports and personalisation: your progress and what the tutor remembers next time.
The optional weekly coaching email, if you receive it.
Internal lesson-quality review by our team to fix tutor problems.

Protection:

We only use providers whose published terms commit them to protect this data at least to the level in our privacy notice: confidentiality, secure handling, use limited to providing the service, and help with your privacy rights.
Lovable's privacy policy says it processes app users' data only on our behalf and does not use it to train AI models. ElevenLabs processes it under its business data processing agreement.
We have switched off ElevenLabs' option to use our data to improve its models. This applies to new data from 21 October 2026; it does not delete data sent earlier.
Providers may keep request history and logs for a limited time under their own terms. We never send your payment details or password.

These protections rely on each provider's published terms and privacy commitments — including ElevenLabs' business data processing agreement where it applies — not on a separately negotiated contract with Lovable. Sources:

You can withdraw at any time in Settings → Privacy. New requests stop straight away, but data already sent cannot be recalled from the providers. Without this permission you can still use Home, Progress, Settings, purchases, the privacy notice and account deletion — only lessons and warm-ups need it. Legal basis: your consent.

Who we share it with

We use a small number of service providers (processors). Most handle data strictly on our instructions; where a provider also applies its own retention or model-improvement settings, we say so explicitly below:

Lovable Cloud — application hosting, database, authentication and infrastructure, acting on our instructions. It also processes the hosting-level usage analytics described above (page views, traffic source, device category, approximate country) on our behalf.
ElevenLabs — converts your speech to text and generates the tutor's spoken voice. ElevenLabs keeps API request history and related debugging and moderation logs under its own documented retention windows, and copies in its backups may persist for up to its documented window after deletion. On 21 October 2026 we switched off its account-level "Improve the models for everyone" setting, so data sent from then on is not used to train its models. This is not retroactive: it does not delete or recall data sent before that date, and it is not a zero-retention arrangement.
AI and speech services — Lovable AI Gateway (intermediary), Google (Gemini models), OpenAI and ElevenLabs, used only with your permission. Exactly what each receives, and why, is listed under "AI and speech services" below.
Email delivery provider — sends reminders, digests and account emails.
Google (Google Analytics 4, and Google Ads for conversion measurement) — receives the optional, consent-based product-analytics events described below, plus Google Analytics' own standard technical measurement. Two of those milestones are imported into our Google Ads account to measure which campaigns bring learners who sign up and qualify. The account-created milestone is the primary conversion of our Habla campaign's Sign-ups goal and is used for bidding on that campaign; the A2+ qualification milestone is a secondary, observation-only conversion and is not used for bidding. Only sent if you allow analytics; never with your name, email, account identifier, transcripts or audio.
Stripe — processes card payments for subscriptions bought on the web, including tax calculation and invoicing. Card details never reach our servers.
Apple App Store / Google Play — handle billing for subscriptions bought inside the mobile apps under their own terms and privacy policies.
Professional advisers (legal, accounting) and authorities where required by law.

We do not sell your personal data. Habla embeds no advertising trackers and no cross-site tracking SDK, and ad personalisation signals are switched off. There is one narrow advertising-related use, only if you allow analytics: two consented milestones (account created, and A2+ qualification) are imported from Google Analytics into our Google Ads account for conversion measurement. The account-created milestone is the primary conversion of our campaign's Sign-ups goal and is used for bidding on that campaign; the A2+ qualification milestone is secondary and observation-only, as described below. Two kinds of usage analytics exist: the first-party, hosting-level aggregate measurement supplied by Lovable Cloud described above (always on, we cannot disable it), and — only if you choose it — optional product analytics through Google Analytics 4, described next.

Optional product analytics (Google Analytics 4)

With your consent we measure product usage through Google Analytics 4 (measurement ID G-84TG52BWZ3, operated by Google) to understand how many learners finish onboarding and complete real conversations, to spot where the product fails them, and to see which acquisition channels bring learners who qualify. Legal basis: your consent, which you can give, refuse or withdraw at any time.

Nothing is measured before you agree. Analytics is off by default; the Google Analytics script is not even loaded until you press “Allow”. Choosing “No thanks” is equally easy and is remembered. While your choice is unset or negative we also set Google's own opt-out flag and delete any Google Analytics cookies left on this device by an earlier version of the site.
You can change your mind. Settings → Privacy has an analytics toggle. Turning it off stops collection immediately and clears Google's measurement cookies; turning it back on resumes measurement of future activity only.
Five Habla milestones. Habla itself sends exactly five custom events, each with a short fixed list of non-identifying values: that a new account was created (whether you used email or Google, nothing more), that a genuine level check finished (your CEFR level such as A1 or B1, and whether it was A2 or above), that you qualified at A2 or above, that a conversation was completed (a coarse duration band such as “3–5 minutes”, and how many times you spoke), and — once per account — that you completed your second lesson (a fixed value only; it is not imported into Google Ads). Skipping the level check by self-reporting at onboarding is not measured as a level check.
Plus Google Analytics' standard technical measurement. Those five custom milestones are not the whole picture: with consent, Google Analytics 4 also collects its own automatic events, currently including page_view, session_start, first_visit and user_engagement, along with the technical parameters Google attaches to them (page URL and title, referrer, screen size, language, device/browser and derived approximate location). We deliberately keep this standard page and session measurement enabled, because visitor, session and new-versus-returning reporting is what our weekly acquisition review uses.
What we never send. No name, email address, account or user identifier, transcript or free text you wrote, no audio, and no learning-style or interest details. Google signals and Google Ads personalisation are switched off. Google Analytics 4 does not log or store IP addresses; your IP is used transiently by Google, for example to derive approximate location.
This is pseudonymous, not anonymous. Habla does not pass your account or user ID to Google. Google Analytics nevertheless generates and processes its own browser/device identifiers (a client ID held in a first-party cookie) together with network information such as your IP address and user agent under the Google Analytics service, which can amount to pseudonymous personal data. That is why it is optional and consent-based.
Minimal local records. On this device we keep your analytics choice and a tiny “already counted” marker per milestone, stored under a one-way local digest of your account/session reference rather than the reference itself. The digest is never sent to Google; the markers exist only so a milestone is not counted twice if you withdraw and later re-grant consent. Clearing your browser data resets them.
Purposes. Product usage measurement, onboarding and reliability improvement; visitor and session reporting for our acquisition review; and — for the two milestones imported into our linked Google Ads account (account created, and A2+ qualification) — conversion measurement for our own Habla campaigns. The account-created import is the primary conversion of our campaign's Sign-ups goal and is used for bidding on that campaign: Google's automated bidding may optimise delivery of that campaign toward visits whose consented measurement recorded a sign-up. The A2+ qualification import remains a secondary, observation-only conversion and is not used for bidding. Neither import carries your name, email, account identifier or any transcript, and bidding happens only at campaign level. That is the full extent of the advertising-related use: no ad personalisation, no Google signals, no audience or profile building about you, no cross-site tracking, no selling or sharing of your data, and no automated decisions about you.
Retention. Google Analytics data is held for Google's configured retention schedule for this property; we do not operate a separate period for it.

International transfers

Some providers process data outside the UK/EEA. Where that happens we rely on adequacy decisions or Standard Contractual Clauses, together with encryption in transit.

How long we keep it

Learning data, transcripts and summaries are kept for as long as your account is active, because they are what makes progress tracking work. Habla does not intentionally store raw audio in its own application database after a session is processed; our speech provider (ElevenLabs) may retain request history, outputs and related logs under its own documented windows, as described above. Reliability and email delivery logs are kept up to 12 months. Aggregate hosting analytics follows our hosting provider's documented retention schedule; we do not operate a separate retention period for it. If you delete your account, your account and personal data in Habla's application database are erased immediately as part of the self-serve deletion flow (or within 30 days if you ask by email). Short-lived infrastructure and security logs held by our hosting provider expire on that provider's own schedule. Data already processed by ElevenLabs is not automatically purged by our deletion flow and remains subject to ElevenLabs' retention until a supported erasure request with that provider is completed. Records our payment processors must keep for tax or legal reasons are held by them, not by us.

Deleting your account or parts of your data

You can delete your account yourself at any time at habla-app.com/delete-account (also linked from Settings). Deletion is permanent: your profile, sessions, transcripts, vocabulary, progress, referral records, email delivery and do-not-email records, and the billing records Habla holds are all erased from Habla's application database immediately once the flow completes. Any active card subscription is cancelled first — if that cancellation fails, nothing is deleted and you can retry, so you are never charged for an account that no longer exists. Audio and text already processed by ElevenLabs is not automatically purged by this flow and remains subject to ElevenLabs' retention until a supported erasure request with that provider is completed. Subscriptions bought through the App Store or Google Play must be cancelled in your store account. If you can no longer sign in, email nick.vasiliev@gmail.com from the address you registered with and we will delete the account within 30 days.

If you only want to delete some of your data — your language history, or the communication-style profile — you can do that from inside the app without closing your account. What each option deletes and keeps is documented at habla-app.com/delete-data.

Your rights

You have the right to access, correct, delete, restrict or port your data, to object to processing based on legitimate interests, and to withdraw consent at any time. Email nick.vasiliev@gmail.com and we will respond within one month. You can also complain to your local supervisory authority — in Spain, the Agencia Española de Protección de Datos (AEPD).

Security

We use encryption in transit, row-level access controls so learners can only read their own data, hashed credentials handled by our authentication provider, and least-privilege access for administrative operations.

Cookies and local storage

Habla itself sets only essential, first-party cookies and browser storage: keeping you signed in, remembering your preferences on this device, making the mobile app shell work, and — if you arrive through an invite link — a cookie holding just the invite code (kept up to 90 days) so the reward can be credited. Our hosting provider's edge additionally sets a small number of essential, short-lived first-party cookies that we cannot disable: currently a bot-protection cookie (expires after roughly 30 minutes) and a deployment-routing cookie (expires after roughly 24 hours). In our most recent audit the routing cookie identified the deployed version of the site rather than the visitor — its value was identical across unrelated browsers — and the hosting analytics described above reaches us only as aggregate statistics. If — and only if — you allow optional product analytics, Google Analytics additionally sets its own first-party measurement cookies (typically _ga and _ga_<property>, up to about two years) plus a stored record of your choice; declining or later switching the toggle off means those cookies are not set, and any existing ones are cleared — including ones left by an earlier version of the site, cleared for both habla-app.com and www.habla-app.com. If you arrive from a Google ad and have not yet made a choice, this browser tab briefly keeps the landing page address with only the ad click identifier and campaign tags, in tab-only storage. Nothing is sent to Google unless you allow analytics; it is then used once to credit the visit to the ad and cleared, and it is discarded straight away if you decline or close the tab. It is never sent to our servers. We set no advertising cookies and no cross-site tracking cookies. You can clear cookies in your browser at any time, which will sign you out.

See also our Terms & Conditions and Refund Policy.