Privacy Policy

This Privacy Policy describes how SonLerni, LLC (“SonLerni,” “we,” “us,” “our”) collects, uses, discloses, and otherwise processes personal information in connection with our websites, applications, and related services (the “Service”). Controller: SonLerni, LLC, [company address]. For certain activities we act as a “controller/business”; for others we may act as a “processor/service provider.”

We collect information from you, automatically, and from service providers/partners:

• Identifiers & contact: email; account identifiers; support communications.
• Account & learning activity: listening progress, AI tutor interactions, flashcards, streaks, preferences, session metadata.
• Device/technical: device type, OS, app version, language, crash logs, diagnostics, approximate region from IP.
• Usage & analytics: feature usage, timestamps, referring URLs, in-app events.
• Marketing & attribution: campaign identifiers, conversion events, audience segments (e.g., Meta/Instagram).

We do not intentionally collect sensitive personal information. Purchases are handled by app stores/payment providers under their policies.

• Service delivery: operate features (AI tutor, transcripts, flashcards, progress, reminders).
• Communications: transactional emails/push; respond to inquiries.
• Improvement & safety: monitor performance, debug, prevent abuse, enhance the Service.
• Marketing & growth: measure campaigns, build audiences, run targeted ads (incl. lookalikes) as permitted by law.
• Legal & compliance: meet legal obligations; enforce terms; protect rights and users.

• Contract: provide requested Service (account, core features).
• Legitimate interests: secure/improve Service; prevent abuse; understand usage (balanced against your rights).
• Consent: certain marketing/analytics and push notifications where required.
• Legal obligation: recordkeeping, tax, regulatory compliance.

• Service providers/processors: hosting, analytics, email/push (e.g., Customer.io), crash reporting under restricted-use contracts.
• Advertising partners: platforms (e.g., Meta/Instagram) to deliver/measure ads; we may disclose identifiers, usage, conversion data as allowed.
• Corporate transactions: transfers in a merger, acquisition, financing, or sale of assets.
• Legal & safety: to comply with law or protect rights, property, or safety.

We do not sell personal information for money. Some laws treat certain ad disclosures as a “sale” or “sharing.” See Sections 6 and 8 for opt-out rights.

We use cookies/SDKs and similar tools for analytics and targeted ads. Where required, we seek consent. You can opt out as follows:

• Web: Use our Do Not Sell or Share My Personal Information link and adjust cookie preferences.
• Apps: Use device settings (e.g., Limit Ad Tracking) or reset advertising IDs.
• GPC: We treat a valid Global Privacy Control signal as a sale/sharing opt-out for that browser where required.

• Exercise rights by emailing privacy@sonlerni.com. We will verify your request. Timelines: generally 30 days (GDPR/UK) or 45 days (CA/CO), extendable as allowed.
• Opt out of marketing emails via unsubscribe; transactional messages may still be sent.
• Opt out of targeted ads/sale-sharing via Do Not Sell or Share My Personal Information and/or GPC.

Authorized agents (CA): we may require proof of authorization and identity verification.

California (CPRA)

We collect identifiers (e.g., email, device IDs); internet/network activity; inferences about preferences; and approximate geolocation (from IP). We may “share” these categories for cross-context behavioral advertising. We do not knowingly collect sensitive personal information.

• Know/Delete/Correct. Request access, deletion, or correction.
• Opt Out of Sale/Sharing. Use Do Not Sell or Share My Personal Information or send a valid GPC signal.
• Non-discrimination. We won’t discriminate for exercising rights.

Colorado (CPA)

You may access, correct, delete, and opt out of targeted advertising or certain profiling (we do not conduct profiling with legal/similarly significant effects). If we deny a request, you may appeal by emailing privacy@sonlerni.com with subject “Appeal.” We honor recognized Universal Opt-Out Mechanisms.

We retain personal information as needed to provide the Service, meet legal obligations, resolve disputes, and enforce agreements. When no longer needed, we delete or anonymize information.

We use administrative, technical, and organizational measures designed to protect personal information. No method is completely secure; we cannot guarantee absolute security.

We are based in the United States and may transfer personal information to countries that may not offer the same level of protection as your jurisdiction. Where required, we use appropriate safeguards, such as Standard Contractual Clauses.

The Service is not directed to children under 13 (or 16 in the EU/UK). We do not knowingly collect children’s data. If you believe a child has provided personal information, contact us to request deletion.

We and our partners use cookies, SDKs, and similar tech to operate the Service, remember preferences, analyze usage, and advertise. Where required, we request consent. You can update preferences via our cookie banner or browser/app settings. See our Cookie Notice (if provided).

We may not respond to “Do Not Track” signals due to lack of standardization. We treat a valid Global Privacy Control (GPC) signal as an opt-out of sale/sharing for that browser where required.

We may update this Policy. Material changes will be reflected by the “Effective Date” and, where required, by additional notice (e.g., email or in-app). Continued use after the effective date constitutes acceptance.

• Email: privacy@sonlerni.com

If you are in the EEA/UK, you may also lodge a complaint with your local data protection authority.