Privacy Policy

1. General Provisions

This Privacy Policy ("Policy") describes what personal data the Spiks application ("App", "we", "us") collects and processes, how it is used, stored, and protected.

By using the App, you agree to the terms of this Policy. If you do not agree, please do not use the App.

This Policy is developed in accordance with:

• Law of the Republic of Moldova No. 195/2024 on Personal Data Protection (effective August 23, 2026)
• Law of the Republic of Moldova No. 133/2011 on Personal Data Protection (currently in force)
• General Data Protection Regulation (GDPR, Regulation 2016/679) — applicable to users from EU countries

2. Data Controller

The data controller is the individual or legal entity that registered and published the Spiks application on the App Store and Google Play.

For all questions related to the processing of personal data, please contact us at: privacy@spiks.io

3. What Data We Collect

3.1 Account Data

When registering via Google or Apple Sign In, we receive:

• Display name
• Email address
• Unique Google or Apple account identifier

We do not receive or store your Google or Apple password. Authentication is handled via OAuth 2.0.

3.2 Voice Data

To power pronunciation exercises, the App uses your device's microphone. When you perform a speech exercise:

• Your audio is temporarily transmitted to OpenAI (Whisper API) for speech-to-text conversion
• The audio recording is not stored on our servers and is deleted immediately after processing
• The recognized text is used solely to evaluate your pronunciation within the App

3.3 Learning Progress Data

• Completed lessons and exercise results
• User settings and preferences
• Aggregated usage statistics (used to improve the App)

3.4 Technical Data

• Device type and model
• Operating system version
• Device identifier
• Crash and error logs (for technical support)

3.5 Payment Data

We do not collect or process bank card details. All subscription payments are processed directly through the App Store (Apple) or Google Play (Google) in accordance with their respective privacy policies.

4. Purposes of Processing

We process your data solely for the following purposes:

• App functionality — authentication, saving progress, personalizing learning
• Speech recognition — converting voice exercises to text for pronunciation evaluation
• Subscription management — activating and verifying subscription status
• Technical support — diagnosing and resolving errors
• App improvement — analyzing aggregated usage statistics

5. Third-Party Data Transfers

Your data may be transferred to the following third parties:

OpenAI, LLC

• What is transferred: audio recordings from voice exercises
• Purpose: speech recognition (Speech-to-Text via Whisper API)
• Storage: recordings are not retained after processing
• Legal basis: a Data Processing Agreement (DPA) is in place with OpenAI
• OpenAI Privacy Policy: openai.com/privacy

Apple / Google

• What is transferred: authentication data (Apple/Google Sign In), payment data (subscription)
• Legal basis: governed by Apple's and Google's privacy policies

We do not sell, rent, or share your personal data with third parties for marketing purposes.

6. Data Retention

After account deletion, all personal data is removed within 30 days.

7. Your Rights

Under applicable law, you have the right to:

• Access — obtain information about what data of yours is being processed
• Rectification — request correction of inaccurate data
• Erasure — request deletion of your data ("right to be forgotten")
• Restriction — restrict the processing of your data
• Portability — receive your data in a machine-readable format
• Objection — object to the processing of your data

To exercise any of these rights, contact us at: privacy@spiks.io

We will respond to your request within 30 days.

8. Data Security

We apply the following technical and organizational measures to protect your data:

• All data transfers use HTTPS/TLS encryption
• Access to data is restricted to authorized personnel only
• Voice data is not stored on our servers
• Regular security risk assessments

9. Children

Spiks is not intended for users under the age of 17. We do not knowingly collect personal data from children. If you believe a child is using the App, please contact us at: privacy@spiks.io

10. Changes to This Policy

We reserve the right to update this Policy. For significant changes, we will notify you via the App or by email. Continued use of the App after changes are published constitutes acceptance of the updated Policy.

11. Contact & Complaints

For any privacy-related questions: privacy@spiks.io

If you believe your data protection rights have been violated, you may contact the supervisory authority:

If you are an EU resident, you also have the right to lodge a complaint with the data protection authority of your country of residence.

© 2026 Spiks. All rights reserved.