Privacy Policy & GDPR

Cogenti ("we", "us", "our") is the data controller for personal data processed through our website and language learning service. Contact: privacy@cogenti.eu. Postal address: [Company address — update before launch].

This Privacy Policy applies to visitors, registered users, and anyone who interacts with Cogenti online. It covers data collected through our website, conversational features, email communications, and support channels.

We may collect: account data (email address, onboarding preferences, proficiency level, learning goals); conversation data (text and voice transcripts, pronunciation feedback, lesson metadata); technical data (IP address, browser type, device identifiers, session cookies, anonymised usage analytics); and communications (support emails, feedback you send us). We do not intentionally collect special category data — please do not share health, biometric, or similarly sensitive information in conversations.

We use personal data to: provide and personalise the Service; authenticate you via magic links; track learning progress; generate AI tutor responses; improve safety and product quality; send service-related emails; comply with legal obligations; and defend legal claims.

We process data on the following bases: (a) Contract — to deliver the Service you sign up for; (b) Legitimate interests — to improve Cogenti, prevent abuse, and ensure security, balanced against your rights; (c) Consent — where required for optional analytics or marketing (you may withdraw at any time); (d) Legal obligation — where we must retain or disclose data by law.

Cogenti uses AI to generate tutor responses and adapt lessons. These outputs inform your learning experience but do not produce legal or similarly significant effects without human involvement. You may contact us to request human review of automated processing that affects you.

We use essential cookies for authentication, session management, and security (including anonymous visitor identifiers on the landing page). We may use analytics cookies to understand usage patterns. You can control non-essential cookies through your browser settings. See your browser documentation for cookie management.

We share data with trusted subprocessors who help us operate the Service — for example cloud hosting, email delivery, speech recognition, and AI inference providers. These processors act on our instructions under data processing agreements. We do not sell your personal data.

Some subprocessors may process data outside the European Economic Area. Where this occurs, we rely on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, or adequacy decisions where applicable.

We retain account and conversation data for as long as your account is active and for a reasonable period thereafter to allow reactivation and comply with legal obligations. Anonymised analytics may be kept longer. You may request deletion — see Your rights below.

We implement technical and organisational measures including encryption in transit, access controls, and regular review of our security practices. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security.

If you are in the EEA or UK, you have the right to: access your data; rectify inaccuracies; erase data ("right to be forgotten"); restrict processing; data portability; object to processing; withdraw consent; and not be subject to solely automated decisions with legal effect. To exercise these rights, email privacy@cogenti.eu. We respond within one month, extendable by two months for complex requests.

Cogenti is not directed at children under 13. We do not knowingly collect data from children under 13. If you believe we have, contact us and we will delete it promptly.

You have the right to lodge a complaint with the Data Protection Commission (DPC), Ireland: www.dataprotection.ie. We encourage you to contact us first so we can try to resolve your concern.

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated date. Continued use after changes constitutes acknowledgement.

Data protection enquiries: privacy@cogenti.eu. For account deletion or data subject access requests, include the email address associated with your account.