Privacy Policy

Last updated: 2026-05-20

At Tinly, we are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, mobile applications, and services (collectively, the “Service”).

By using Tinly, you agree to this Privacy Policy.

1. Information We Collect

1.1 Information You Provide

We may collect:

  • Account information (name, email address, password)
  • Profile information (native language, target language, learning goals)
  • User-generated content (text inputs, answers, messages, uploaded content)
  • Voice recordings and speech inputs (when using speaking features)
  • Learning progress and performance data
  • Subscription and transaction records
  • Support communications

1.2 Information Collected Automatically

  • Device information (IP address, browser type, OS)
  • Usage data (pages viewed, features used, timestamps)
  • Interaction data with AI features
  • Cookies and similar tracking technologies

1.3 Information from Third Parties

If you sign in via third-party providers (e.g., Apple or Google login), we may receive basic profile information from those providers.

2. How We Use Your Information

We use personal information to:

  • Provide, operate, and improve the Service
  • Deliver AI-generated language lessons
  • Personalize learning experiences
  • Process subscriptions and payments
  • Provide customer support
  • Monitor security and prevent fraud
  • Comply with legal obligations

3. AI Services and Automated Processing

Tinly integrates artificial intelligence services provided by: Microsoft Azure OpenAI Service.

AI-powered features include:

  • Course generation
  • Conversation simulation
  • Pronunciation analysis
  • Adaptive lesson difficulty adjustment

3.1 Data Shared with Microsoft Azure OpenAI Service

When you use AI-powered features, we may transmit:

  • Text inputs and responses
  • Voice recordings or transcriptions
  • Learning context (language, level, exercise type)
  • Session-based interaction history
  • Technical metadata required for processing

We do NOT share:

  • Passwords
  • Full payment details
  • Government identification numbers
  • Sensitive financial data

Data is transmitted using encrypted connections.

3.2 Purpose of AI Data Processing

AI processing is used solely to:

  • Generate personalized lessons
  • Simulate interactive conversations
  • Improve response relevance within the Service
  • Adapt course difficulty

We do not sell AI interaction data.

3.3 AI Content Disclaimer

AI-generated content is automatically produced and may contain inaccuracies. AI responses are for educational purposes only and should not be relied upon for legal, financial, medical, or professional advice.

4. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access your personal data
  • Correct inaccurate data
  • Delete your data
  • Withdraw consent for AI processing

To exercise these rights, contact support@tinly.ai.

5. AI Consent and Control

Use of AI-powered features is voluntary. By using AI features, you consent to the processing of your inputs by Microsoft Azure OpenAI Service for content generation.

You may:

  • Avoid using AI features
  • Request deletion of AI interaction history
  • Withdraw consent at any time

Withdrawal may limit certain Service functionality.

6. Data Retention

We retain personal data only as long as necessary for:

  • Providing the Service
  • Maintaining learning history
  • Legal compliance
  • Resolving disputes

Users may request earlier deletion.

7. International Data Transfers

Your information may be transferred to and processed in countries outside your residence, including the United States. This includes transfers to Microsoft Azure OpenAI Service.

Where required, we implement:

  • Standard Contractual Clauses (SCCs)
  • Contractual safeguards
  • Appropriate technical protections

8. Security Measures

We implement:

  • Encryption in transit
  • Access controls
  • Secure cloud infrastructure
  • Monitoring for unauthorized access

However, no system is 100% secure.

9. Children’s Privacy (COPPA-Aligned)

Tinly is not directed to children under 13. We do not knowingly collect personal data from children under 13 without verified parental consent where legally required. If such data is discovered, it will be deleted promptly.

10. Acceptable Use of AI Features

Users may not use AI features to:

  • Generate unlawful content
  • Produce harmful or abusive material
  • Attempt to reverse engineer the AI system
  • Violate intellectual property rights

Accounts violating these rules may be suspended.

11. Cookies and Tracking

We use cookies for:

  • Essential functionality
  • Performance analytics
  • Personalization

Users may control cookies via browser settings. Where required by law (e.g., EU), consent will be requested.

12. Changes to This Policy

We may update this Privacy Policy periodically. Continued use of the Service constitutes acceptance of updates.