Privacy Policy

1. Identity & Contact Information

Platform: Fluent Up

Fluent Up is currently operated as an individual initiative. We do not have a designated Data Protection Officer as we are not yet incorporated.

2. Types of Data Collected

Account Data:

Email address (required for account creation)
Language preferences (target language, learning preferences)
Learning progress data (vocabulary learned, exercises completed, progress tracking)

Contact Form Data:

Name, email address, message content, and any other information you voluntarily submit through our contact form
Contact form submissions are collected via Google Forms and may include category selection, subject, and message content

Usage Data:

Google Analytics data (anonymous usage statistics, page views, device information)
Session cookies (authentication and platform functionality)

3. Purpose of Processing

We collect and process your personal data solely for:

Service Provision: To create and maintain your account, track your learning progress, and provide personalized learning content
Communication: To respond to your inquiries submitted through our contact form and to send you essential service-related notifications
Platform Improvement: To analyze usage patterns and improve the user experience, content quality, and platform functionality

4. Legal Basis for Processing

We process your data based on:

Contract (GDPR Article 6(1)(b)): Processing necessary to provide the Fluent Up service you requested when creating an account
Consent (GDPR Article 6(1)(a)): Contact form submissions are processed based on your voluntary consent when you submit the form
Legitimate Interest (GDPR Article 6(1)(f)): Analytics and platform improvements to enhance user experience and service quality

5. Data Sharing & Third Parties

Your data is shared only with:

Hosting Provider: Amazon Web Services (AWS) data center located in Frankfurt, Germany (EU). Data remains within the EU.
Contact Form Provider: Google Forms (Google LLC) for collecting and processing contact form submissions. Google Forms may process data in the USA under Standard Contractual Clauses (SCCs) approved by the EU. By submitting the contact form, you acknowledge that your data will be processed by Google according to Google's Privacy Policy and Terms of Service.
Analytics: Google Analytics for anonymous usage statistics. Google Analytics may process data in the USA under Standard Contractual Clauses (SCCs) approved by the EU.

We do not sell, rent, or trade your personal data. Data is shared only as necessary for platform operation and is protected by data processing agreements with third parties.

6. Data Retention

We retain your data:

While your account is active and for 30 days after account deletion (to allow account recovery if requested)
Contact form submissions are retained for as long as necessary to respond to your inquiry and for a reasonable period thereafter (typically up to 2 years) unless you request earlier deletion
Google Forms data is stored according to Google's data retention policies. You can request deletion of your contact form submission at any time by contacting us
Google Analytics data is retained according to Google's retention policies (typically 26 months for standard properties)
After the retention period, all personal data is permanently deleted from our systems

7. Your Rights (GDPR Articles 12–23)

You have the right to:

Access: Request a copy of your personal data we hold
Rectify: Correct inaccurate or incomplete data
Erasure: Request deletion of your account and personal data
Restrict: Limit how we process your data
Portability: Receive your data in a structured, machine-readable format
Object: Object to processing based on legitimate interests
Withdraw Consent: Where processing is based on consent, you may withdraw it at any time

To exercise these rights, contact us at hey@fluent-up.com. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection supervisory authority.

8. Security Measures

We implement industry-standard security measures:

Data encryption in transit (TLS/SSL) and at rest
Access controls and authentication mechanisms
Security practices following OWASP guidelines
Regular security audits of our platform
Secure hosting infrastructure (AWS Frankfurt, EU)

9. Cookies & Tracking

We use:

Essential Cookies: Session cookies required for platform authentication and functionality
Analytics Cookies: Google Analytics cookies to understand how users interact with our platform (anonymous data)

You can control cookies through your browser settings. Note that disabling essential cookies may affect platform functionality.

To opt out of Google Analytics tracking, you can install the Google Analytics Opt-out Browser Add-on.