Privacy
Privacy notice
Fluency EI assesses a student's spoken and written language performance. That means we handle personal data, including voice recordings. This page explains exactly what we hold, why, for how long, and who else is involved.
Last updated September 2026
Who is responsible
Where a school uses Fluency EI with its own students, the school is the data controller and Fluency EI acts as processor on the school's instructions. Where an individual runs the public demo on their own response, Fluency EI is the controller for that submission.
What we collect and why
- Student name, class, school and optional external ID — So a level can be attached to a real learner and progress tracked over time.
- The prompt, the written response and the transcript — Evidence a teacher can review behind every proposed level.
- Scores, CEFR proposal and rationale — The assessment result itself.
- The audio recording — Re-scoring and dispute resolution. Deleted automatically after 20 days.
- Technical usage records (duration, tokens, cost) — Cost control and service monitoring. Contains no response content.
Lawful basis
- For schools: the school's legitimate interest in measuring and supporting language progress, or consent where the school's own policy requires it. The school remains responsible for informing students and parents.
- For the public demo: your consent, given by confirming the consent statement before you submit a response. You can withdraw it at any time by asking us to delete the submission.
How long we keep it
- Audio recordings: 20 days. Recordings are stored in a private, access-controlled location and are deleted automatically once 20 days have passed. The assessment record then shows that the recording was deleted.
- Transcripts, scores and CEFR proposals: kept for as long as the school needs the progress history, and deleted on request.
- Technical usage records (duration, tokens, cost): kept for cost control. They contain no response content.
Who processes the data
We use the following sub-processors, and no others:
| Provider | Purpose | Location |
|---|---|---|
| Lovable (hosting, database, storage, AI gateway) | Runs the platform, stores the roster, assessments and recordings, and routes AI requests. | European Union / United States |
| OpenAI | Speech-to-text transcription of oral responses (via the AI gateway). | United States |
| Language evaluation and CEFR scoring of the response (via the AI gateway). | United States |
Transfers outside the European Economic Area rely on the providers' standard contractual clauses. Student responses are never used to train Fluency EI's or any provider's models.
Your rights
- Access and portability — we can export everything held about a student as a machine-readable file.
- Erasure — we can permanently delete a student and every assessment, recording, transcript and derived insight linked to them.
- Correction, restriction and objection — contact us and we will act without undue delay.
- Complaint — you may complain to your national data protection authority.
To exercise any of these, email valeriabm68@gmail.com. Schools can also ask their Fluency EI contact to run an export or erasure directly.
Automated assessment
Fluency EI proposes a CEFR level; it does not decide one. Every result is an indicative estimate for a qualified teacher to confirm or override. No decision with a legal or similarly significant effect on a student is made by the system alone.
Demonstrations and conferences
The public demo is a demonstration environment. Please do not upload identifiable recordings of real students until a service agreement and a data-processing agreement are in place. See our data-processing agreement and terms of use.
For online, traditional schools and language educators