LuraTalk – Privacy Policy

Last updated: November 27, 2025

This Privacy Policy explains how Mynalabs Inc. (“Mynalabs”, “we”, “us”, or “our”) collects, uses, and shares information about you when you use the LuraTalk mobile application and any related websites, services, or communications (collectively, the “Service”).

By using the Service, you agree that we may collect, use, and share your information as described in this Privacy Policy. If you do not agree, please do not use the Service.

1. Scope of this Privacy Policy

This Privacy Policy applies to:

• Your use of the LuraTalk mobile application and associated features (for example, AI language tutors, interactive lessons, voice practice, and progress tracking). Mynalabs Inc. is the owner and operator of the platform and all data collected through the Service.
  
• Your interactions with us through email, support requests, social media, or other channels related to the Service.
  

This Privacy Policy does not apply to third-party websites, apps, or services that we do not control, even if you access them through the Service.

2. Definitions

For this Privacy Policy:

• Account means a unique account created for you to access the Service.
  
• Application means the LuraTalk mobile application provided by Mynalabs.
  
• Service means the Application and any related services, websites, or communications operated by Mynalabs in connection with LuraTalk.
  
• Personal Data means any information that identifies or can reasonably be linked to an individual.
  
• Usage Data means data collected automatically in connection with your use of the Service (for example, device identifiers, IP address, and usage patterns).
  
• Device means any device that can access the Service, such as a smartphone or tablet.
  
• You means the individual accessing or using the Service.
  

Where applicable under the GDPR, you may also be referred to as the Data Subject.

3. Children’s privacy

The Service is not intended for children under the age of 18, and we do not knowingly collect Personal Data from anyone under 18.

If you are a parent or guardian and believe that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from someone under 18 without appropriate consent, we will delete that data.

If we rely on consent as a legal basis for processing and your country requires parental consent for minors, we may ask for your parent or guardian’s consent before collecting or using certain information.

4. Information we collect

We collect and process various categories of Personal Data depending on how you use the Service.

4.1 Personal Data you provide directly

a) Account and profile information

When you create or update an Account, you may provide:

• Name or display name
  
• Email address
  
• Age group (for example, “18–24”, “25–34”)
  
• Gender (if you choose to provide it)
  
• Hobbies, interests, and other profile details you choose to share
  
• The AI tutor/avatar you select within the Service
  

We use this information to create and maintain your Account and personalize your experience.

b) Language-learning information

To build and adapt your learning plan, you may provide:

• Native language
  
• Target language(s) you are learning
  
• Language-learning goals and priorities (for example, travel, work, exams)
  
• Your self-reported proficiency level
  
• Previous experience learning the target language
  

We use this information to personalize your curriculum, lessons, feedback, prompts, and hints.

c) Lesson content, audio, and transcripts

The Service includes interactive practice with AI tutors and other features that may involve voice input and conversational learning. When you use these features, we may process:

• Audio recordings of your conversations with AI tutors (where the feature is available and enabled)
  
• Transcripts of those conversations
  
• Corrections, feedback, and hints generated by the Service
  
• Your lesson history, including completed activities and performance metrics
  

We use this information to provide and improve the language-learning experience, including:

• Understanding your pronunciation and fluency
  
• Generating feedback and suggestions
  
• Tracking your progress over time
  

Depending on your settings and applicable law, we may also use this information to help improve and train our models and features (for example, to enhance speech recognition or responses).

d) Subscription and purchase information

If you subscribe to a paid plan or make in-app purchases, we may collect:

• Type of subscription or purchase (for example, monthly plan, trial, promotional offer)
  
• Subscription start date, renewal date, and duration
  
• Whether you are in a free trial period
  
• Confirmation from your app store (Apple App Store or Google Play) that a purchase has been made
  

We do not store full payment card numbers. Payments are processed by third-party providers (such as Apple or Google), and your card details are handled directly by them.

e) Communications and support

If you contact us (for example, via email or in-app support), we may collect:

• Your contact details (name, email address)
  
• The content of your messages and any attachments you send
  
• Information about the issue you are reporting or feedback you provide
  

We use this to respond to you, provide support, and improve the Service.

4.2 Information we collect automatically

When you use the Service, certain information is collected automatically:

a) Usage Data

This includes, for example:

• IP address
  
• Device identifiers (such as advertising identifiers and app-specific IDs)
  
• Device type, operating system, and version
  
• App version and settings
  
• Time and date of your interactions with the Service
  
• Pages, screens, or features used in the app
  
• Time spent in the app and on specific screens
  
• Crash logs and diagnostic data
  

We use Usage Data to:

• Operate and display the Service on your Device
  
• Monitor performance and stability
  
• Detect and fix errors and security issues
  
• Understand usage patterns and improve the Service
  
• Measure and optimize the effectiveness of our marketing and advertising campaigns (see Section 9).
  

b) Approximate location

We may infer an approximate location from:

• Your IP address
  
• Device settings or language preferences
  

We generally use approximate location for:

• Understanding where our users are located in aggregate
  
• Improving the Service (for example, localization and time zones)
  
• Complying with regional legal requirements
  
• Measuring and optimizing advertising and campaigns in different regions
  

We do not use precise GPS-level location unless clearly explained and requested in the app.

4.3 Information from your app store account

If you create or access an Account using your app store login (for example, Apple or Google), we may receive information such as:

• Name associated with your app store account
  
• Email address associated with your app store account
  
• App store user ID
  

We use this information to create and manage your Account and confirm purchases.

4.4 Information from social media and other channels

If you interact with us on social media (for example, following, mentioning, or messaging us), we may see and process:

• Your profile name and handle
  
• Profile picture
  
• Content of messages or public posts that reference us
  

We use this to respond to you and understand how people talk about and use our Service.

5. How we use your information

We use your Personal Data for the following purposes:

1. To provide and operate the Service
   

• Delivering lessons, practice sessions, and AI tutor conversations
  
• Tailoring the content, difficulty, and feedback to your profile and learning goals
  
• Managing your Account and user settings
  

2. To personalize your learning experience
   

• Adapting content to your proficiency, interests, and preferences
  
• Recommending lessons, exercises, or features based on your prior activity
  

3. To manage subscriptions and payments
   

• Enabling in-app purchases and subscriptions
  
• Verifying transactions with app store providers
  
• Providing access to paid features and handling renewals or cancellations
  

4. To communicate with you
   

• Sending service-related messages (for example, security alerts, changes to terms, support responses)
  
• Sending learning-related updates, progress summaries, reminders, or motivational nudges
  
• Sending marketing or promotional communications, where permitted by law and your preferences
  

5. To improve and develop the Service
   

• Monitoring performance and usage trends
  
• Debugging and enhancing app stability
  
• Analyzing aggregated usage and learning data to optimize features and content
  

6. For advertising and marketing measurement
   

• Evaluating the effectiveness of our online advertising (for example, whether an ad led to an app install or subscription)
  
• Building audiences of users and similar people who may be interested in LuraTalk (see Section 9)
  

7. For security, fraud prevention, and legal compliance
   

• Detecting and preventing fraudulent or abusive activity
  
• Protecting the rights, property, and safety of users, the public, and Mynalabs
  
• Complying with legal obligations, subpoenas, or government requests
  

8. For business operations and transfers
   

• Supporting internal business purposes such as accounting, audits, and planning
  
• Evaluating or carrying out corporate transactions (for example, merger, sale, restructuring) where user data may be part of the transferred assets
  

6. Legal bases for processing (EEA/UK users)

If you are in the European Economic Area (“EEA”) or the United Kingdom, we only process your Personal Data when we have a legal basis, including:

• Performance of a contract
   When processing is necessary to provide the Service and fulfill our contract with you (for example, managing your Account, delivering lessons, processing subscriptions).
  
• Legitimate interests
   When we have a legitimate business interest in processing your data that is not overridden by your rights and interests (for example, improving the Service, preventing fraud, measuring advertising performance and reach, responding to your enquiries).
  
• Consent
   When you have given your consent (for example, where required for certain analytics, cookies, or marketing communications). You can withdraw your consent at any time, but this will not affect processing that has already taken place.
  
• Legal obligations
   When processing is needed to comply with law (for example, tax or accounting rules, responding to lawful requests from authorities).
  

We will clearly indicate where providing Personal Data is required by law or contract, and what happens if you choose not to provide it (for example, you may not be able to use certain features).

7. Cookies, SDKs, and other tracking technologies

We and our partners use cookies, software development kits (“SDKs”), and similar technologies to:

• Remember your preferences and settings
  
• Understand how you use the Service
  
• Improve performance and features
  
• Measure and optimize marketing and advertising campaigns
  

On mobile devices, these technologies often take the form of SDKs integrated into the app. Your device or operating system may provide tools to control certain tracking technologies (for example, limiting ad tracking or resetting advertising IDs).

Where required by law, we will ask for your consent before using certain tracking technologies, especially for analytics or advertising purposes.

8. Advertising and measurement

We may work with advertising and measurement partners (for example, ad networks, analytics providers, and social platforms) to:

• Determine whether our ads lead to app installs, sign-ups, or subscriptions
  
• Show our ads to people who may be interested in LuraTalk based on general interest profiles
  
• Exclude existing subscribers from seeing certain ads
  

To do this, we or our partners may:

• Use cookies, SDKs, or similar technologies to recognize your Device
  
• Use identifiers such as advertising IDs, app install data, and hashed email addresses (if available)
  
• Combine information from our Service with information from other apps and websites for measurement and targeting purposes
  

Where required, we will obtain your consent before using your information for personalized advertising.

Your choices for ads

Depending on your location and device, you may be able to:

• Limit ad tracking on your Device
  

• On iOS devices, using privacy/ad tracking settings
  
• On Android devices, using “Opt out of Ads Personalization” or similar options
  

• Control cookies and trackers
   Use in-app or operating system settings, and browser settings where relevant, to manage cookies and tracking.
  

Even if you opt out of interest-based advertising, you may still see ads; they just may be less relevant to your interests.

9. Analytics

We may use third-party service providers to monitor and analyze how the Service is used.

9.1 Firebase

We use Firebase, an analytics service provided by Google, to help us understand how users interact with the app and to improve performance and features.

You may be able to disable certain Firebase features through your mobile device settings (for example, your device’s advertising settings) or by following instructions provided in Google’s privacy materials, such as:

• Google Privacy Policy:
  https://policies.google.com/privacy
  
• Information about how Google safeguards data:
  https://support.google.com/analytics/answer/6004245
  

For general information about how Google handles data from sites and apps that use its services, you can review:

• “How Google uses information from sites or apps that use our services”:
  https://policies.google.com/technologies/partner-sites
  

Firebase may collect information such as device identifiers, app usage data, and crash data as described in those materials.

9.2 Amplitude

We also use Amplitude, a third-party analytics provider, to better understand user behavior and improve the Service.

You can review Amplitude’s privacy practices at:

• Amplitude Privacy Policy:
  https://amplitude.com/privacy
  

10. Payments

We may offer paid products and services within the Service. When you make a purchase, all payments are processed exclusively through third-party payment processors (for example, Apple Store or Google Play). Mynalabs Inc. does not store or collect your payment card information, and such information is handled directly by the payment processors, whose use of your Personal Data is governed by their own privacy policies. These payment processors typically comply with standards such as PCI-DSS, managed by the PCI Security Standards Council.

The payment processors we commonly use include:

• Apple Store In-App Payments
   Privacy Policy:
  https://www.apple.com/legal/privacy/en-ww/
  
• Google Play In-App Payments
   Privacy Policy:
  https://www.google.com/policies/privacy/
  

We may update this list as our payment providers change.

11. How we share your information

We do not sell your Personal Data in the traditional sense (for example, selling lists of users to third-party marketers). We may, however, share information as follows:

1. Service providers
    We share Personal Data with third-party companies that help us operate the Service, such as:
   

• Cloud hosting providers
  
• Analytics providers (including those described in Section 9)
  
• Customer support tools
  
• Email and push notification providers
  

2. These service providers are only allowed to use your data on our behalf and in accordance with this Privacy Policy.
   
3. Analytics providers
    We may share certain Usage Data and identifiers with analytics services so they can help us understand how the Service is used and how to improve it.
   
4. Advertising and marketing partners
    As described in Section 8, we may share certain identifiers and usage data with advertising partners to measure and optimize campaigns and, where permitted, to support interest-based advertising.
   
5. Business transfers
    If we are involved in a merger, acquisition, financing, sale of assets, reorganization, or similar transaction, your Personal Data may be transferred as part of that transaction.
   
6. Legal and safety purposes
    We may disclose Personal Data if we believe in good faith that it is necessary to:
   

• Comply with a legal obligation or lawful request
  
• Protect the rights, property, or safety of Mynalabs, our users, or others
  
• Investigate and prevent fraud, security issues, or misuse of the Service
  

7. With your consent
    We may share your information for any other purpose disclosed to you at the time of collection, if you agree.
   

12. International data transfers

Mynalabs is based in the United States, and your Personal Data may be transferred to and processed in countries other than your own, including countries that may have different data protection laws.

Where required by law, we implement appropriate safeguards for international transfers. These may include:

• Standard contractual clauses approved by the European Commission or UK authorities
  
• Other mechanisms recognized under applicable data protection laws
  

By using the Service, you acknowledge that your data may be transferred to the United States and other countries where we and our service providers operate.

13. Data retention

We keep your Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

• Providing and maintaining the Service
  
• Complying with our legal obligations
  
• Resolving disputes and enforcing agreements
  
• Supporting business operations and accounting requirements
  

We typically retain:

• Account and profile information for the life of your Account and for a reasonable period after closure (for example, to resolve disputes or comply with law).
  
• Subscription and purchase data for as long as needed for tax, accounting, and audit purposes.
  
• Usage Data for a shorter period, unless it is needed for security, fraud prevention, legal obligations, or ongoing Service improvement.
  

When data is no longer needed, we will delete it or anonymize it so that it cannot reasonably be linked to you.

14. Security

We use reasonable technical and organizational measures to protect your Personal Data from unauthorized access, loss, misuse, or alteration.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your Personal Data, we cannot guarantee absolute security.

If you believe your Account or Personal Data may have been compromised, please contact us immediately.

15. Your rights

Your privacy rights depend on your location. In many regions, including the EEA, UK, and California, you have rights regarding your Personal Data. Subject to applicable law and certain exceptions, these may include the right to:

• Access your Personal Data and obtain a copy
  
• Correct inaccurate or incomplete Personal Data
  
• Delete your Personal Data (for example, where it is no longer needed for the purposes for which it was collected)
  
• Object to certain processing (for example, processing based on legitimate interests or for direct marketing)
  
• Restrict processing in certain circumstances
  
• Data portability, receiving certain Personal Data in a structured, commonly used, machine-readable format
  
• Withdraw consent where processing is based on consent
  

To exercise these rights, please contact us at support@luratalk.app. We may ask you to verify your identity before responding to your request.

You also have the right to lodge a complaint with a supervisory authority (for example, your local data protection authority in the EEA or UK) if you are concerned about how we handle your Personal Data.

16. Additional information for California residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”) and similar laws may provide you with specific rights, including:

• Right to know
   You can request that we disclose what categories and specific pieces of Personal Data we have collected, used, disclosed, or “sold” (as defined by CCPA) in the last 12 months.
  
• Right to delete
   You can request that we delete certain Personal Data we hold about you, subject to exceptions (for example, where the data is required to complete a transaction, comply with law, prevent fraud, or support internal operations consistent with your expectations).
  
• Right to opt out of “sale” or “sharing” of personal information
   To the extent our use of advertising and analytics cookies or identifiers is viewed as a “sale” or “sharing” under CCPA, you have the right to opt out. We honour such rights through our in-app settings (where available) and by using browser/device-level opt-out tools.
  
• Right to non-discrimination
   We will not discriminate against you for exercising your privacy rights.
  

To exercise your CCPA rights, you (or your authorized agent) can contact us at support@luratalk.app. We will need to reasonably verify your identity before fulfilling your request.

17. “Do Not Track” and similar signals

Some browsers offer a “Do Not Track” (“DNT”) setting that sends a signal to websites that you do not wish to be tracked. Our Service does not currently respond to DNT signals.

However, you can use other controls described in this Privacy Policy (for example, device settings, cookie controls, and in-app consent tools) to manage how we and our partners collect and use data about you.

18. Links to other websites and services

The Service may contain links to third-party websites, apps, or services that are not operated by us. If you click on a third-party link, you will be directed to that third party.

We are not responsible for the privacy practices of third-party websites or services. We encourage you to review the privacy policies of each site or service you visit.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will:

• Post the updated Privacy Policy within the Service and/or on our website
  
• Update the “Last updated” date at the top of this page
  
• Where required by law, notify you in advance and/or request your consent to material changes
  

Your continued use of the Service after any changes become effective means that you accept the updated Privacy Policy.

20. Contact us

If you have any questions, concerns, or requests relating to this Privacy Policy or your Personal Data, you can contact us at:

Mynalabs Inc.
 769 Monterey Blvd., Suite #5A
San Francisco, California, 94127
United States

Email: contact@luratalk.app

We will do our best to respond promptly and in accordance with applicable law.