Privacy Policy
We’re serious about your data. Here’s exactly what we collect, why, and what you can do about it.
Section 01
Who We Are
LayRuna (“we,” “our,” or “us”) is an AI-powered language learning application developed and operated by Necole Carpenter, based in Sitges, Catalonia, Spain. LayRuna is available on iOS and is distributed globally through the Apple App Store.
If you have any questions about this Privacy Policy or how we handle your data, please contact us at:
| Data Point | |
|---|---|
| info@layruna.com | |
| Website | https://layruna.com |
| Address | Sitges, Catalonia, Spain |
Section 02
Information We Collect
We collect only the information necessary to provide you with a personalised, functional language learning experience.
2.1 Information You Provide Directly
- Account information: email address and display name when you register, or your name and Apple ID token if you sign in with Apple.
- Language preferences: your chosen interface (base) language and the language you are learning (target language).
- Learning pace and goals: the study pace you select (Explorer, Committed, or Focused) and your weekly goals.
- Profile information: optional details such as interests, occupation, and language-learning goals that you share during onboarding or with a tutor.
2.2 Information Generated During App Use
- Flashcard and study progress: which cards you have studied, your accuracy scores, pronunciation scores, and mastery levels per layer.
- Voice and speech data: when you use the speech recognition features, your voice recording is sent to OpenAI’s Whisper API for real-time transcription. We do not store raw audio recordings on our servers.
- AI conversation content: messages exchanged with AI tutors in the Practice Café are processed by OpenAI’s GPT-4o API to generate tutor responses. Conversation histories are stored in our database to provide context continuity across sessions.
- Tutor memory: a structured summary of your learning preferences, weak and strong areas, and session history is stored to allow tutors to personalise future sessions.
- Game scores and activity logs: records of games played, words studied, café sessions, and lesson completions.
- CEFR placement results: your assessed language level (A1–C1) if you complete the placement assessment.
2.3 Automatically Collected Information
- Device and OS information: iOS version and device type, used solely for debugging and compatibility.
- Streak and daily usage data: stored locally on your device using Apple’s UserDefaults. Aggregate daily and weekly counts are used to calculate streaks and goal progress.
- App session data: basic usage metrics such as session start/end times, stored locally
2.4 Information We Do Not Collect
- We do not collect your precise location.
- We do not collect contacts, photos, or files from your device.
- We do not track you across other apps or websites.
- We do not use advertising identifiers (IDFA).
- We do not sell your data to third parties.
Section 03
How We Use Your Information
| Purpose | Data Used | Legal Basis (GDPR) | |
|---|---|---|---|
| Provide and personalise the learning experience | Account data, language preferences, study progress, tutor memory | Contract performance | |
| Deliver AI tutor conversations and speech recognition | Voice recordings (transient), conversation history, vocabulary progress | Contract performance | |
| Track and display your progress | Study scores, game results, streak data, CEFR level | Contract performance | |
| Sync your progress across devices and prevent data loss | All learning data stored in Supabase database | Contract performance / Legitimate interest | |
| Improve app stability and fix bugs | Device/OS type, anonymous error logs | Legitimate interest | |
| Send streak reminders (local notifications only) |
|
Consent | |
| Process subscription payments | Handled entirely by Apple — we receive only entitlement status | Contract performance | |
| Comply with legal obligations | Account data as required by applicable law | Legal obligation |
Section 04
Third-Party Services
LayRuna integrates with the following third-party services. Each processes data under their own privacy policies.
4.1 OpenAI (GPT-4o + Whisper)
We use OpenAI’s API for AI tutor conversations and voice transcription. When you speak or type in the Practice Café or during study, your input is sent to OpenAI’s servers for processing. OpenAI does not use API data to train its models by default under their API data usage policy. For more information, see: https://openai.com/policies/api-data-usage-policies
4.2 ElevenLabs
We use ElevenLabs to generate natural-sounding voice audio for your AI tutors. Text generated by the AI tutor is sent to ElevenLabs for audio synthesis. For more information, see: https://elevenlabs.io/privacy
4.3 Supabase
Your account data, learning progress, conversation history, and tutor memory are stored in a Supabase PostgreSQL database. Supabase is an EU-based (AWS eu-central-1) service with encryption at rest and in transit. All user data tables are protected by Row Level Security (RLS) — only you can access your data. For more information, see: https://supabase.com/privacy
4.4 Apple
Subscription payments are processed entirely by Apple through the App Store. We receive only a confirmation of your subscription status — never your payment details. Apple’s Privacy Policy applies to all purchase transactions: https://www.apple.com/legal/privacy/
4.5 Ready Player Me
3D tutor avatar models are provided by Ready Player Me. Avatar assets are loaded as static 3D model files (.glb) bundled within the app. No personal data is transmitted to Ready Player Me during normal app use.
Section 05
Data Retention
- Account data is retained for as long as your account is active.
- Learning progress, tutor memory, and conversation history are retained indefinitely while your account exists, as they are essential to the personalised learning experience.
- Local data stored on your device (streak counts, daily progress) is retained until you delete the app or clear app data.
- Upon account deletion, all personal data is permanently erased from our systems within 30 days, except where we are legally required to retain it.
- Transient voice recordings sent to OpenAI Whisper are not stored by us after transcription.
Section 06
Data Security
We take the security of your data seriously:
- All data in transit between the app and our servers is encrypted using TLS 1.2 or higher.
- Data at rest in our Supabase database is encrypted using AES-256.
- Row Level Security policies ensure each user can only access their own data.
- API keys and secrets are never stored in the app binary or Info.plist — they are injected at build time from a secrets configuration file that is never committed to version control.
- We do not have direct access to your Apple Sign-In identity — only the anonymised user identifier Apple provides.
Section 07
Children’s Privacy
LayRuna is designed for adult language learners aged 16 and over. We do not knowingly collect personal data from children under 16 years of age (or under 13 in the United States). If you believe a child has provided us with personal information, please contact us at info@layruna.com and we will delete the data promptly.
The app has an age rating of 4+ on the App Store, meaning it is technically accessible to all ages. However, our Terms of Service require users to be at least 16 years old to create an account.
Section 08
Your Rights
8.1 Rights Under GDPR (EU/EEA Users)
If you are located in the European Union or European Economic Area, you have the following rights:
- Right of access: request a copy of the personal data we hold about you.
- Right to rectification: request correction of inaccurate data.
- Right to erasure (“right to be forgotten”): request deletion of your data. You can do this directly within the app via Settings → Delete Account, or by emailing privacy@com.
- Right to restrict processing: request that we limit how we use your data.
- Right to data portability: request your data in a machine-readable format.
- Right to object: object to processing based on legitimate interests.
- Right to withdraw consent: withdraw consent at any time where processing is based on consent (e.g. notifications).
To exercise any of these rights, contact us at info@layruna.com. We will respond within 30 days.
You also have the right to lodge a complaint with your national data protection authority. In Spain, this is the Agencia Española de Protección de Datos (AEPD) at www.aepd.es.
8.2 Rights Under CCPA (California Users)
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):
- Right to know: request disclosure of the categories and specific pieces of personal information we have collected about you.
- Right to delete: request deletion of personal information we have collected from you (subject to certain exceptions).
- Right to opt out of sale: we do not sell your personal information. There is nothing to opt out of.
- Right to non-discrimination: we will not discriminate against you for exercising your privacy rights.
To submit a CCPA request, contact us at info@layruna.com with the subject line “CCPA Request.”
Section 09
Account Deletion
You can delete your LayRuna account at any time:
- In the app: Settings → Account → Delete Account.
- By email: send a deletion request to info@layruna.com.
Account deletion will permanently erase all of your personal data, including your study progress, tutor memory, conversation history, and account credentials. This action is irreversible. Any active subscription should be cancelled through the App Store separately before deleting your account (Settings → Apple ID → Subscriptions).
Section 10
Cookies and Tracking
The LayRuna app does not use cookies or browser-based tracking technologies. Local data is stored on your device using Apple’s UserDefaults and Keychain frameworks.
Our website (layruna.com) may use minimal analytics to understand traffic patterns. If so, a cookie notice will be displayed. No cross-site tracking is used.
Section 11
International Data Transfers
LayRuna is operated from Spain (EU). Your data is processed by third-party services that may be located outside the EU:
- OpenAI — United States (covered by Standard Contractual Clauses).
- ElevenLabs — United States (covered by Standard Contractual Clauses).
- Supabase — EU (AWS eu-central-1, Frankfurt, Germany) — no transfer required.
All international transfers are conducted with appropriate safeguards as required under GDPR Chapter V.
Section 12
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the “Last Updated” date at the top of this page and, where appropriate, by sending a notice within the app. Your continued use of LayRuna after any changes constitutes your acceptance of the updated policy.
Section 13
Contact Us
For any questions, requests, or concerns about this Privacy Policy or your personal data:
- Email: info@layruna.com
- Website: https://layruna.com/privacy
- Address: Necole Carpenter, Sitges, Catalonia, Spain

