Privacy Policy
Last updated: 30 October 2026
In short
- We only keep what is needed to teach you: your profile name, age, level, progress, words and the mistakes to practise.
- Your voice is sent to be transcribed and scored, and is not stored by us.
- To answer you, conversations go through the AI and voice services listed below.
- No advertising, no selling of data, no tracking cookies and no usage analytics.
- You can export or delete your data at any time, inside the app.
1. Who is responsible
TalkTumble is developed by Farol Development in Portugal, the controller of the data described in this policy. Website: faroldevelopment.com. Contact: info@faroldevelopment.com.
2. What data we use and why
| Data | Purpose |
|---|---|
| Profile: name, age, adult or child, girl/boy or woman/man, chosen picture, language being learned | To fit lessons to your age and level, and to address you correctly (Portuguese words change with gender, e.g. ‘obrigada’ or ‘obrigado’). |
| Progress: level, lessons done, word notebook, mistakes to practise, stories heard, lesson summaries, study days, stickers | To carry on where you left off, review words and show your progress. |
| What you say and type in conversations, and short notes the teacher keeps (for example interests you mentioned) | To answer you, correct your mistakes and remember you in later lessons. |
| Voice recordings (only while you press ‘Speak’) | To transcribe what you said and score your pronunciation. We do not store them. |
| Questions asked in the ‘Life in Portugal’ and ‘Life in the UK’ sections | To answer from our guides. We do not store them; we only count how many questions are asked per day. |
| Answers you report: the text of the teacher's answer, where it appeared and the profile | To review what went wrong and improve the app. |
| Family code | To give access to the app and bring a family's profiles together on several devices. |
| Daily reminder (only if you turn it on): the device's notification address, chosen time and time zone | To send the reminder at the right time. |
| Technical logs (response times, errors, family name) and usage counts per profile and per day (number of requests, amount of text and seconds of speech processed) | To keep the service running and understand its costs. They do not include the content of conversations. |
We do not ask for your email, address, phone number or payment details.
3. Legal basis
We use this data to provide the service you asked for (performance of a contract, Article 6(1)(b) GDPR / UK GDPR) and, for technical logs, our legitimate interest in keeping the app secure and working (Article 6(1)(f)). The daily reminder and the microphone depend on your permission, which you can withdraw at any time in your phone's settings.
4. Where it is kept and who receives it
- On your device: all the app's data is kept on your own phone or computer.
- Netlify (website hosting): keeps a copy of the family's profiles and progress, to sync devices, the reminder settings and the answers you report.
- Google (Gemini API): receives the conversation, the voice recordings of your answers, questions from the ‘Life in Portugal’ and ‘Life in the UK’ sections and a short profile summary (name, age, level, interests and recent mistakes), to write the teacher's replies.
- Microsoft (Azure Speech, France region): receives the text to be read aloud and the recordings of pronunciation exercises, to create the teacher's voice and score your pronunciation.
- Your device's notification service (Apple or Google): delivers the daily reminder, if you turn it on.
These providers process data on our behalf and under their own terms. Some are outside the UK and the European Economic Area; such transfers rely on the safeguards provided for by data protection law, such as the European Commission's standard contractual clauses and the UK addendum.
5. How long we keep it
- Profiles and progress: for as long as the profile exists. Deleting a profile deletes it from the website and from every device in the family.
- Voice recordings: not stored by us; the providers process them to answer and under their own terms.
- Daily reminder: until you turn it off or remove the app.
- Technical logs: for the period set by the hosting provider, usually a few days. Usage counts and reports: up to 12 months.
6. Children
TalkTumble has a children's mode. Children's profiles must be created and supervised by a parent or legal guardian, who accepts this policy on the child's behalf. For children we ask for the minimum: a name (a first name or a nickname is enough) and the age, to fit the lessons. There is no advertising, no in-app purchases, no chat with other people and no public profiles. The parent can see, export or delete the child's data at any time.
7. Your rights
You have the right to access your data, correct it, delete it, take it with you (portability), restrict or object to its use, and withdraw permissions. In the app:
- Settings → Advanced → Backup → Export downloads all your data in a file;
- Manage profiles lets you correct or delete a profile;
- Settings → Advanced → Delete progress for… also deletes it from the website.
For anything else, write to info@faroldevelopment.com; we reply within one month. You can also complain to the Information Commissioner's Office in the UK (ico.org.uk) or to Portugal's data protection authority, the CNPD (cnpd.pt).
8. Artificial intelligence
Mr Oliver and Mrs Inês are virtual teachers: their replies are written by artificial intelligence and may contain mistakes. The app makes no automated decisions with legal or similarly significant effects on you; the level it suggests is only used to choose lessons, and you can change it.
Before you use the teachers, the app asks you to accept a notice about this and about what is sent to Google and Microsoft. Answers go through Google's safety filter. If an answer seems offensive, harmful or wrong, tap the flag next to ‘Listen again’ (or ‘Report this answer’ in the help section) to send us its text.
9. Security
Connections are encrypted (HTTPS), the service keys stay on the server rather than on devices, and each family's data can only be reached with its own code. Keep your family code safe, like a password.
10. Changes
If this policy changes, we update the date at the top and, for important changes, let you know in the app.