Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

Birdierun Technologies and Media GmbH
Switzerland

Accént ("we", "our", "us") is a language learning application operated by Birdierun Technologies and Media GmbH that helps English speakers learn French, German, Spanish, and Italian pronunciation using accent-based phoneme mapping. This policy explains how we collect, use, and protect your personal data in accordance with the Swiss Federal Act on Data Protection (nDSG/revFADP) and the EU General Data Protection Regulation (GDPR).

2. Data We Collect

3. How We Use Your Data

• To provide and personalise your learning experience
• To track your progress and suggest relevant lessons
• To authenticate your identity and maintain your session
• To process your voice recordings for accent detection and pronunciation feedback using AI
• To generate text-to-speech audio for language learning exercises using AI
• To send login codes via email
• To send push notifications (only if you opt in)
• To improve our service based on aggregate usage patterns

4. AI and Voice Data Processing

Accént uses artificial intelligence (AI) to power several core features of the Service:

• Accent Detection — When you record your voice during onboarding, your audio is sent to OpenAI's API for analysis to identify your English accent. The audio is processed in real time and is not permanently stored by us or by OpenAI.
• Pronunciation Scoring — When you practise pronunciation, your voice recordings are processed locally using an on-device AI model (wav2vec2) to score your pronunciation accuracy. These recordings are not sent to external servers.
• Text-to-Speech (TTS) — The Service generates spoken audio for words and phrases in your target language and English accent using OpenAI's audio generation API. The text you are learning is sent to OpenAI to generate the audio; no personal data beyond the learning content is transmitted.
• AI-Powered Coaching — Learning tips, pronunciation guidance, and accent-specific coaching content may be generated or enhanced using AI language models.

By using the Service, you consent to the processing of your voice data as described above. You may choose not to use voice-based features, in which case no voice data will be collected or processed.

5. Legal Basis for Processing

We process your personal data on the following legal bases:

• Contract performance (Art. 6(1)(b) GDPR / Art. 31(1) nDSG) — processing necessary to provide the learning service you signed up for
• Consent (Art. 6(1)(a) GDPR / Art. 31(1) nDSG) — for voice data processing, push notifications, and optional features
• Legitimate interest (Art. 6(1)(f) GDPR / Art. 31(1) nDSG) — for improving the service, security measures, and fraud prevention

6. Data Sharing and Processors

We do not sell your personal data. We share data with the following service providers (processors) who help us operate the Service:

• OpenAI, Inc. (USA) — AI processing for accent detection, text-to-speech generation, and coaching content
• Resend, Inc. (USA) — email delivery for sending login codes
• Replit, Inc. (USA) — application hosting, database storage, and infrastructure

These providers process data only on our behalf and under appropriate data processing agreements. We have verified that each provider maintains adequate data protection measures.

7. International Data Transfers

Your personal data is stored and processed in the United States of America. This includes:

• Application hosting and database storage (via Replit, USA)
• Voice and text data sent to OpenAI for AI processing (USA)
• Email delivery via Resend (USA)

The USA does not have an adequacy decision from the Swiss Federal Council or the European Commission that covers all data transfers. To ensure adequate protection of your data, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data processing agreements with each provider that include appropriate safeguards
• Provider certifications and compliance programmes (e.g., SOC 2)

By using the Service, you acknowledge that your data will be transferred to and processed in the USA under the safeguards described above.

8. Data Retention

We retain your account and learning data for as long as your account is active. Login codes expire after 10 minutes. Session tokens expire after 30 days. Voice recordings for accent detection are processed in real time and are not stored. If you delete your account, all associated data is permanently removed immediately.

9. Cookies and Local Storage

We use essential cookies and local storage:

• accent_session — keeps you logged in (httpOnly, secure, 30-day expiry)
• cookie_consent — stores your cookie consent preferences (localStorage)
• Functional storage — language preferences, accent selection, and learning settings (localStorage, optional)

We do not use analytics, advertising, or third-party tracking cookies. You can manage your cookie preferences at any time using the Cookie Settings.

10. Your Rights

Under the Swiss nDSG and the EU GDPR, you have the following rights regarding your personal data:

• Right of access — Request a copy of all your personal data (available via Account Settings)
• Right to rectification — Update or correct your account details through the app
• Right to erasure — Delete your account and all associated data via Account Settings
• Right to data portability — Export your data in machine-readable JSON format
• Right to restrict processing — Request that we limit how we use your data
• Right to object — Object to processing based on legitimate interest
• Right to withdraw consent — Withdraw your consent at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at the address provided in Section 14. We will respond within 30 days.

11. Data Security

We protect your data through: encrypted connections (HTTPS/TLS), bcrypt-hashed passwords (12 rounds), httpOnly secure session cookies, rate-limited authentication endpoints, and regular session cleanup. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in accordance with Art. 8 nDSG and Art. 32 GDPR.

12. Children's Privacy

Accént is not intended for children under 16. We do not knowingly collect personal data from children under 16 years of age. If you believe we have inadvertently collected such data, please contact us and we will promptly delete it.

13. Changes to This Policy

We may update this privacy policy from time to time. We will notify registered users of significant changes via email. The "Last updated" date at the top of this page will be revised accordingly.

14. Contact and Supervisory Authority

For privacy-related questions or to exercise your data rights, please contact:

Birdierun Technologies and Media GmbH
Switzerland
Email: privacy@birdierun.ch

If you believe that our processing of your personal data violates data protection law, you have the right to lodge a complaint with the competent supervisory authority:

• Switzerland: Federal Data Protection and Information Commissioner (FDPIC) — edoeb.admin.ch
• EU/EEA: Your local data protection authority in your country of residence