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SWAI Privacy Policy
Last Updated: May 1st, 2025
At SWAI, we take your privacy seriously and are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR). This Privacy Policy outlines how we collect, use, and store your personal data when using SWAI, a language learning application.
When using SWAI you also consent to abstain from sharing any sensitive or personal information with our artificial language tutors.
For European users, your personal data, including conversations and voice data, is stored within the European Union at data centers operated by Microsoft, Hetzner, Stripe Payments Europe and Auth0. Furthermore, conversations are shared with the AI providers mentioned above. For non-European users, your voice data is processed on servers close to your location to ensure low latency, while other data is stored in the European Union.
By using SWAI, you acknowledge that you have read, understood, and agree to the terms outlined in this Privacy Policy.
At SWAI, we take your privacy seriously and are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR). This Privacy Policy outlines how we collect, use, and store your personal data when using SWAI, a language learning application.
Privacy Policy for Individual Users
Collection of Personal Data
When using SWAI, we collect the following personal data:- User conversations: We save your conversations with our artificial tutors to enhance your learning experience and to allow you to review past conversations.
- User settings: We save your settings in the Application to provide a personalized experience.
- Cookies: We use cookies for authentication and analytics purposes. Authentication cookies are used to identify you when you log in, while non-identifiable analytics cookies are used to analyze and optimize the Application's performance.
- Voice data: Your voice data is sent to third parties for processing to enable the voice-based features of SWAI (see sub-processor list below).
- Account email and password: We save your email address and password as part of the sign up process. This data is saved with identity provide Auth0 in the European Union.
- Payment data: if you signed up via our payment gateway, Stripe, then your payment data is handled and stored by Stripe Payments Europe
Individual User Consent
When using SWAI you consent to the collection and processing of your voice transcriptions and text input, and that we sent your data to Microsoft and the AI providers mentioned above for processing.When using SWAI you also consent to abstain from sharing any sensitive or personal information with our artificial language tutors.
Privacy Policy for Businesses and Schools
Organizational Data Collection
For business and school accounts, we collect additional organizational data including:- Organization name and contact information
- Administrator account details
- User license allocation and usage statistics
- Billing information for organizational accounts
Student/Employee Data
Organizations are responsible for obtaining appropriate consent from their users (students or employees) for the collection and processing of personal data in accordance with applicable laws. We process this data as described in the Individual Users section.Administrator Access
Administrators of business and school accounts have access to usage statistics and learning progress data for their users. This data is provided to help organizations monitor engagement and effectiveness. By default, administrators do not have access to the specific content of conversations between users and AI tutors unless explicitly permitted in your organization's settings.Data Export and Retention
Organizations may request exports of their users' learning progress data. When a user is removed from an organization, their data may be retained for a limited period before being permanently deleted unless the organization specifically requests immediate deletion.Organizational Responsibilities
Organizations using SWAI are responsible for:- Obtaining appropriate consent from users for data collection and processing
- Informing users about what data is collected and how it is used
- Ensuring compliance with applicable data protection laws
- Managing user access and permissions appropriately
General Privacy Information
Data Storage and Processing
Artificial Intelligence (AI) models are used to process your voice and text input. We use the following model providers for tasks such as response generation, language understanding, language generation, and voice recognition: OpenAI, Anthropic and Groq. Please refer to their privacy policies for more information.For European users, your personal data, including conversations and voice data, is stored within the European Union at data centers operated by Microsoft, Hetzner, Stripe Payments Europe and Auth0. Furthermore, conversations are shared with the AI providers mentioned above. For non-European users, your voice data is processed on servers close to your location to ensure low latency, while other data is stored in the European Union.
Sub-processors
We use the following sub-processors to store and process your personal data in accordance with the GDPR:- Microsoft Azure North Europe, Takeda Ireland Ltd (Grange Castle) New Nangor Road, Grange Dublin 22, Co. Dublin Ireland.
- Microsoft Azure, West Europe, Evert van de Beekstraat 354, 1118 CZ Luchthaven Schiphol, Noord-Holland, Netherlands.
- OpenAI Ireland Ltd. 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland.
- Anthropic Ireland Limited, 6th Floor South Bank House, Barrow Street, Dublin 4, Ireland.
- Groq, Inc. 301 Castro St., Suite 200 Mountain View, CA 94041, USA.
- Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, Web hosting.
- Auth0, Frankfurt, Germany, Authentication.
- Sentry, Frankfurt, Germany, Error logging.
- Mixpanel, Eemshaven, Netherlands, Usage tracking.
Right to Be Forgotten
You have the right to request the deletion of your personal data from our systems. To exercise this right, please send an email to contato@punkify.com with the subject "Right to Be Forgotten." Please settle any unpaid bills before submitting the request to ensure a seamless process. Upon receiving your request, we will delete your personal data from our systems within 30 days, as required by the GDPR.Data Protection
We implement appropriate technical and organizational measures to ensure the security of your personal data and protect it against unauthorized access, disclosure, alteration, or destruction.Changes to GDPR Information
We reserve the right, at our sole discretion, to modify or update this Privacy Policy at any time. By continuing to access or use SWAI after such modifications, you agree to be bound by the updated Privacy Policy.Contact Information
If you have any questions about this Privacy Policy or our data protection practices, please contact us at contato@punkify.com.By using SWAI, you acknowledge that you have read, understood, and agree to the terms outlined in this Privacy Policy.
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