개인정보 처리방침

[Company legal name], [registered address], is the controller of your personal data for the Service ("Podling", "we", "us"). You can reach us about privacy at privacy@trypodling.com. Where required by law, we will appoint representatives in the EU and the UK: [EU/UK representative].

• Account data. Your email address and, if you sign in with Apple or Google, the basic profile details they share (such as a name and an identifier; Apple may provide a private relay email). Your native language, learning language, and level.
• Learning activity. Shows you follow, episodes you play and how far, words you look up, daily goals, streaks, study sheets you open, shadowing sessions, and transcript problem reports.
• Word bank. Words and phrases you save, with the sentence and episode they came from.
• Voice audio. When you use AI Talk or shadowing, the app records your voice through the microphone, only after you grant permission and only while you are using those features. AI Talk conversation history (text) is stored so you can review it.
• Comments and ratings. Episode comments and show ratings you post, which other users can see along with your display name.
• Device and diagnostic data. Device model, operating system, app version, language and time-zone settings, IP address, crash reports, and performance logs.
• Purchase status. Which plan you have, trial and renewal dates, and transaction identifiers we receive from Apple or Google. We never receive or store your card or bank details; the stores handle payment.
• Website data. Strictly necessary data to run the site and, only if you consent, analytics data collected with Google Analytics 4: pages viewed, referring site or campaign, approximate location, device and browser details, and interactions such as button clicks. See our Cookie Policy.
• Messages to us. What you send when you contact support, creators, or privacy.

Where the GDPR, UK GDPR, or similar laws apply, we rely on the following legal bases:

When you speak in AI Talk, your voice is transcribed by speech recognition so the AI partner can understand and respond. Shadowing audio is processed to support the practice session. We send the minimum needed (your audio or its transcript and the episode context) to our AI and speech service providers, who process it on our behalf under contracts that restrict them from using it for their own purposes, including training their models.

• Your voice is never used for advertising, and we do not build voiceprints to identify you.
• You can delete AI Talk conversation history in the app at any time. More detail: Your voice data.
• AI features do not make decisions that have legal or similarly significant effects on you.

We use service providers (sub-processors) in these categories: cloud hosting and storage; speech recognition and AI model providers; crash reporting and analytics (analytics only with consent); email delivery; and customer support tools. A current list is available on request at privacy@trypodling.com.

We share personal data only as described here:

• Service providers who process data for us under contract (see above).
• Apple and Google, to verify purchases and, if you choose, to sign you in.
• Google Analytics: if you allow analytics cookies on our website, Google processes website usage data as our analytics provider. Google signals and ad personalization are off. You can withdraw consent at any time with "Cookie settings" in the website footer.
• Other users, who can see your display name, comments, and ratings.
• Podcast publishers receive the standard information any podcast player sends when streaming audio from their server (such as your IP address and app name). We do not share your learning data with them.
• Legal and safety: when required by law, or to protect the rights, safety, or property of users, Podling, or others.
• Business transfers: as part of a merger, acquisition, or sale of assets, with notice to you.

We do not sell your personal data, and we do not "share" it for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA). We honor Global Privacy Control signals on our website.

Podling and our providers operate in several countries, so your data may be processed outside the country where you live, including in the United States. When we transfer personal data from the EEA, UK, or Switzerland, we use safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum) or rely on adequacy decisions. We apply equivalent safeguards for transfers required under other laws, such as Brazil's LGPD, Japan's APPI, and Korea's PIPA.

Encrypted backups are overwritten on a rolling basis within [35] days. We may keep data longer where needed to comply with law or resolve disputes.

Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal data; to restrict or object to processing; and to withdraw consent at any time. To make a request, email privacy@trypodling.com from your account email. We will respond within the time required by law (usually one month) and may need to verify your identity. You will not be treated differently for exercising your rights.

• EEA and UK (GDPR / UK GDPR): all of the rights above, including data portability and the right to object to processing based on legitimate interests. You may complain to your local data protection authority.
• California (CCPA/CPRA) and other US states: the right to know, delete, correct, and opt out of sale, sharing, or targeted advertising (we do none of these), and to limit use of sensitive personal information. An authorized agent may submit a request for you.
• Taiwan (Personal Data Protection Act): the rights to inquire, review, obtain copies, supplement or correct, request cessation of collection, processing, or use, and request deletion.
• Korea (PIPA): the rights to access, correct, delete, and suspend processing of your personal information.
• Japan (APPI): the rights to request disclosure, correction, suspension of use, and deletion of retained personal data, including records of third-party provision.
• Brazil (LGPD): the rights to confirmation, access, correction, anonymization, portability, deletion, information about sharing, and review of consent. You may contact the ANPD.

In the app, go to Profile > Settings > Account > Delete account. You can also email privacy@trypodling.com from your account email. We delete your account data within 30 days, except data we must keep by law (such as purchase records). Deleting your account does not cancel a store subscription, so please cancel it in the App Store or Google Play first. Step-by-step instructions: Delete your account.

Podling is not directed to children under 13, and you must be at least 13 (or 16 where local law requires) to create an account. We do not knowingly collect personal data from children below these ages. If you believe a child has given us personal data, contact privacy@trypodling.com and we will delete it.

We use administrative, technical, and physical safeguards appropriate to the risk, including encryption in transit (TLS) and at rest, access controls with least privilege, and monitoring. No system is perfectly secure. If a breach affects your personal data, we will notify you and the authorities as the law requires.

We may update this policy as Podling changes. If a change is material, we will notify you in the app or by email before it takes effect, and ask for consent again where required. The "Last updated" date shows the current version.

Privacy questions or requests: privacy@trypodling.com, or by post to [Company legal name], [registered address]. If you are not satisfied with our response, you can contact your local data protection authority.