Privacy Policy

1. Overview & Our Privacy Commitment

Intersolution Trade Ltd. ("we," "us," or "our") is the operator of Senthora, an AI-native language tutor. We utilize a "Privacy by Design" framework, ensuring that AI-driven learning never compromises your fundamental data rights. We adhere strictly to the GDPR (EU), the EU AI Act, and COPPA (USA).

2. Mandatory AI Disclosure & Data Processing

To provide real-time tutoring, Senthora transmits data to third-party Artificial Intelligence providers. In accordance with Apple App Store Guideline 5.1.2(i) and the EU AI Act, we explicitly identify our sub-processors:

• OpenAI, Inc. (GPT-4o mini & Realtime API): Processes text and audio for conversational intelligence and fluency scoring.
• ElevenLabs Inc.: Processes text to generate synthetic voice responses.
• Google Firebase: Managed infrastructure for data hosting and secure authentication.
• RevenueCat: Encrypted management of subscriptions and payment verification.

The "No-Training" Guarantee: We utilize Enterprise/API-tier agreements. Your private conversations, text prompts, and voice recordings are NOT used by OpenAI, ElevenLabs, or Intersolution Trade Ltd. to train foundation AI models.

3. Types of Data We Collect

A. Account & Identification Data
Name, email address, and account preferences collected via Firebase to maintain your learning progress across devices.

B. Voice & Audio (Biometric-Derived Data)
When using "Voice Mode," your audio is processed to analyze pronunciation, rhythm, and fluency.

• Usage: This data is used strictly for linguistic inference (scoring), not for unique biometric identification.
• Retention: Audio is temporarily cached for processing and deleted from sub-processor volatile memory immediately after the tutor's response is generated.

C. Learning History & Transcripts
We store transcripts of your AI interactions to provide grammar feedback, personalized lesson paths, and "Streak" tracking.

D. Technical & Advertising Identifiers
We collect Device IDs (IDFA/AAID) and IP addresses via Firebase Analytics for app optimization and marketing attribution. You can opt-out of "Tracking" in your device system settings.

4. EU AI Act: Transparency & Human Oversight

As a Bulgarian entity, we comply with the EU AI Act (2026 Standards):

• AI Identification: You are always notified that you are interacting with a synthetic AI system, not a human.
• Accuracy Disclaimer: AI systems may "hallucinate" or provide incorrect linguistic feedback. Senthora is an educational aid, not a certified legal or medical translation service.
• Right to Contest: You have the right to flag any AI output for manual review. Flagged responses are reviewed by our human linguists to ensure safety and quality.

5. Protection of Minors (13+ / UK Online Safety)

Senthora adheres to the UK Age Appropriate Design Code:

• Age Limit: Users must be 13 or older.
• Safety Default: For users under 18, high-privacy settings and "Strict Content Filters" are enabled by default to prevent exposure to harmful content.

6. Data Retention & Your Rights

Retention: We retain data only as long as your account is active.

• Right to Delete: You can use the "Delete Account" button in the App Settings. This triggers a "Hard Delete" across Firebase, OpenAI, and ElevenLabs within 30 days.
• Global Rights: Regardless of residency, you have the right to access, port, or rectify your data by contacting support@senthora.ai.

7. Data Security & Encryption

• In Transit: All data is encrypted using TLS 1.3.
• At Rest: Data is stored on AES-256 encrypted servers within the EEA (European Economic Area) where possible.

8. Contact Information

Intersolution Trade Ltd. · UIC: 208418306
Sofia, Bulgaria
Email: support@senthora.ai