Privacy Policy

1. Introduction

Pavone ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our video analysis and speech improvement platform.

This policy complies with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

2. Information We Collect

2.1 Personal Information

• Account Information: Name, email address, authentication credentials
• Payment Information: Processed securely through Stripe (we don't store payment details)
• Profile Data: Subscription plan, practice history, preferences

2.2 Video and Audio Data

• Video Recordings: Practice sessions you upload for analysis
• Transcriptions: Audio-to-text conversions of your recordings
• Analysis Results: AI-generated feedback, scores, and recommendations

2.3 Technical Information

• Usage Data: How you interact with our platform
• Device Information: Browser type, operating system, IP address
• Log Data: Error logs, performance metrics, security events

3. Legal Basis for Processing (GDPR)

• Contract Performance: Processing necessary to provide our services
• Legitimate Interest: Improving our platform, security, and user experience
• Consent: Where you've given explicit consent for specific processing
• Legal Obligation: Compliance with applicable laws and regulations

4. How We Use Your Information

• Provide video analysis and speech improvement services
• Generate personalized feedback and recommendations
• Process payments and manage subscriptions
• Communicate with you about your account and our services
• Improve our platform and develop new features
• Ensure security and prevent fraud
• Comply with legal obligations

5. Data Sharing and Disclosure

We do not sell your personal data. We may share information with:

• Service Providers: Clerk (authentication), Stripe (payments), AssemblyAI (transcription), Cloudflare R2 (storage)
• Legal Requirements: When required by law or legal process
• Business Transfers: In connection with mergers, acquisitions, or asset sales
• Consent: When you've given explicit consent

6. Data Retention

• Account Data: Retained while your account is active and for 30 days after deletion
• Video Recordings: Retained for 90 days or until you delete them
• Analysis Data: Retained for 1 year to improve our services
• Log Data: Retained for 30 days for security and debugging purposes
• Temporary Files: Automatically deleted within 24 hours

7. Your Rights (GDPR)

If you're in the EU, you have the following rights:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your personal data ("right to be forgotten")
• Portability: Receive your data in a machine-readable format
• Restriction: Limit how we process your data
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, contact us at privacy@speak.com or use the data management tools in your account settings.

8. Data Security

• All data encrypted in transit using TLS 1.3
• Data encrypted at rest in our storage systems
• Access controls and authentication for all systems
• Regular security audits and monitoring
• Incident response procedures for data breaches
• Employee training on data protection

9. International Data Transfers

Your data may be processed in countries outside your residence. We ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission.

10. Children's Privacy

Our service is not intended for children under 16. We do not knowingly collect personal information from children under 16. If we become aware of such collection, we will delete the information immediately.

11. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and inform affected users without undue delay.

12. Data Deletion & Contact

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. Continued use of our service after changes constitutes acceptance of the updated policy.

14. Supervisory Authority

If you're in the EU and have concerns about our data processing, you have the right to lodge a complaint with your local data protection authority.