Privacy Policy — uTalk (EuroTalk Ltd.)

Last updated: 22 September 2026

Plain English Summary

This summary is intended as an aid and does not constitute part of the Privacy Policy below, which you agree to by use of our website and app.

  1. We collect the information needed to create your account, run the app, and understand how our services are used, so that we can operate and improve them.
  2. Your personal data is kept confidential and only shared with the trusted service providers who help us run uTalk (for example, payment processors). We never sell it.
  3. Your voice recordings never leave your device. We don't record, store, or transmit your speech data anywhere.
  4. If uTalk is provided to you through a school, college, library, or other institution, your sign-in is handled by that institution. If it's a library, we don't ask you for your name or email — we only get one if the library itself chooses to give it to us. For some other institutions, you may register your own name and email directly with us.
  5. You can ask us to delete your data at any time, free of charge, by emailing support@utalk.com.
  6. We are a friendly, honest company, based in London, UK. We're happy to answer any questions on hello@utalk.com.

Privacy Policy

1. Introduction

1.1 This policy applies to utalk.com, the uTalk mobile and web applications ("uTalk" or the "Service"), and any institutional, school, college, or library portal through which uTalk is made available (together, our "Platform"). It also covers how we work with our advertising and analytics partners in connection with the Platform.

1.2 We are committed to safeguarding the privacy of everyone who visits our website, uses our app, or accesses uTalk through a partner institution. This policy explains how we collect, use, share, and protect your personal data, and what rights you have over it.

1.3 By using the Platform, you acknowledge this policy. Section 11 explains your choices regarding cookies specifically.

2. Who we are

2.1 uTalk is owned and operated by EuroTalk Ltd. ("uTalk", "we", "us"), a company registered in England and Wales under company number 2674118, with its registered office and principal place of business at 315-317 New Kings Rd, London, SW6 4RF, United Kingdom.

2.2 For any question about this policy or your personal data, contact us at hello@utalk.com or support@utalk.com.

3. The personal data we collect

3.1 In this Section 3 we set out the categories of personal data we process, where it comes from, and why. Where we say the legal basis is "consent", you may withdraw that consent at any time by contacting support@utalk.com or, where a control exists, through your account or device settings; this does not affect the lawfulness of processing before withdrawal.

3.2 Account data. When you create a uTalk account directly with us, we collect your first name, last name, email address, and a password (which we store in hashed form only). Source: you. Purpose: creating and operating your account, authenticating you, and communicating with you about your account. Legal basis: performance of a contract with you (necessary to provide the account you've asked for), and consent where required by local law.

3.3 Language and usage data. We collect the language you're learning, your in-app usage and progress data (such as which topics you've studied and your scores), your device type and operating system, and your IP address. We use IP address to derive an approximate location (country and city level) — we do not ask you for this directly. On our website, we also use Google Analytics, which provides us with aggregate, non-identified data such as age band and country for visitors who have consented to analytics cookies (see Section 10). Purpose: operating and improving the Service, understanding usage patterns, and (for website analytics) measuring the effectiveness of our marketing. Legal basis: consent (for analytics and non-essential tracking) and legitimate interests (for core usage data needed to run the app, namely providing a working, reliable product).

3.4 Voice and microphone data. Certain uTalk exercises use your device's microphone so you can practise pronunciation. This audio is processed entirely on your device. We do not record, store, transmit, or otherwise have access to your speech data — it never reaches our servers or any third party, and is not used to train any AI model. You can see the specific permissions the app requests in the iOS and Android app store listings.

3.5 Payment data. All payments are handled entirely by Stripe, the Apple App Store, or the Google Play Store, depending on how you subscribe. We never receive or store your card details; we only receive confirmation that a payment was made and basic transaction data (e.g. plan purchased, amount, date) needed to administer your subscription. Legal basis: performance of a contract.

3.6 Institutional, school, college, and library access. If you access uTalk through a school, college, library, or other institution, your sign-in is handled by that institution's own authentication system (for example, via SAML-based single sign-on, or library-specific access protocols such as patron barcode login or NCIP-based systems, depending on what your institution uses). In this case:

  1. Libraries. Where you access uTalk through a library, we do not ask you for your name or email address, and we do not collect them from you directly. We receive only an identifier assigned by the library to manage your access. If we do hold a name or email address in this context, it is because the library itself has chosen to provide it to us as part of managing its accounts with us — never because we requested it from you;
  2. Schools, colleges, and other institutions. Access is provided in one of two ways: either you register directly with us using your own name and email address (in which case we collect that data directly from you, in the same way as described in Section 3.2, and it is not provided to us by the institution), or an authorised person at your institution creates your account on your behalf using an administrative dashboard we provide. In the latter case, the institution — not you — provides us with your name and/or email address, and we never receive a bulk file, roster, or list of students; accounts are created individually, one at a time, by the institution's authorised user through that dashboard;
  3. Usage data, in all institutional contexts, is collected to operate the Service and is aggregated/anonymised at the institutional level for reporting to that institution, so that individual learners cannot be identified by us or the institution from that reporting;
  4. the institution is responsible for obtaining any consents (including parental consent, where relevant) required under its own policies before providing your details or access to us, or before creating an account on your behalf; where the institution provides us with any personal data about you (as opposed to you providing it directly), we act as a data processor for the institution in that respect, and the institution is the data controller for that data;
  5. Data Processing Agreements. Institutional customers (including libraries, schools, and colleges) may request a signed Data Processing Agreement governing our processing of personal data on their behalf. Contact hello@utalk.com to request one.

3.7 Children. Creating a direct consumer account with uTalk requires an email address, and we do not knowingly permit children under the age of 13 to create a direct consumer account. Where uTalk is provided through a school or other institution as described in Section 3.6, the institution is responsible for age-appropriate consent arrangements; we do not knowingly collect personal data directly from children in that context beyond the anonymised usage data described above.

3.8 Marketing referral partners. We work with a number of marketing and referral partners, who may direct their users to uTalk as part of a promotion. These partners send us referral traffic; if someone signs up as a result, they become a uTalk user under this policy in the ordinary way, and this policy governs our processing of their data from that point. We are not responsible for, and this policy does not cover, how a referral partner processes data on its own platform before that point — please see that partner's own privacy policy.

3.9 Correspondence data. If you contact us (for example via email or our support system), we process the content of your message and any related metadata to respond to you and keep records. Legal basis: our legitimate interests in running our business and communicating with users, and performance of a contract where your query relates to your account.

3.10 Marketing communications. We only send marketing or product emails (via Mailchimp or Brevo) to people who have registered an account with us and given us their email address in doing so — we do not email anyone who hasn't signed up. Every marketing email includes a clear unsubscribe link, and you can opt out at any time; see Section 9.5.

3.11 We may also process any of the personal data described in this Section 3 where necessary to establish, exercise, or defend legal claims, to comply with a legal obligation, or to protect someone's vital interests. Please do not supply another person's personal data to us unless we have asked you to.

4. How we use AI

4.1 In the product. uTalk does not currently use AI or machine learning within the app or website for speech recognition, pronunciation scoring, content personalisation or recommendation, or automated chat support. If this changes, we will update this policy before the change takes effect.

4.2 Your voice data and AI. As set out in Section 3.4, voice data processed for pronunciation practice stays on your device. It is never sent to us, and never sent to any third-party AI provider or used to train any AI model.

4.3 Advertising. uTalk does not display third-party advertisements within the app or website — there is no ad inventory in the product. We do advertise for uTalk on external platforms (such as Google and Meta/Facebook) to bring new users to the Service, and we use AI-assisted advertising tools, in addition to those standard platforms (see Section 5), to help target and optimise those external ad campaigns. This advertising activity, and the cookies used to measure and retarget it, are limited to our website (utalk.com); it does not run inside the uTalk app, and is not linked to your device once you have downloaded the app. See Section 10 for detail on the cookies and trackers involved.

4.4 Internal tools. Our team may use general-purpose AI tools (for example, for drafting or internal analysis) as part of our normal business operations. These tools are not given access to, and do not process, personal data belonging to our users.

4.5 Automated decision-making. We do not use automated decision-making that produces legal effects concerning you, or that similarly significantly affects you (for example, we do not use automated systems to block accounts, deny refunds, or make other significant decisions about you without human involvement).

5. Sharing your personal data with third parties

5.1 We disclose personal data to the following categories of recipient, only to the extent reasonably necessary for the purposes set out in this policy. Each of these providers is contractually required to protect your data and only process it on our instructions.

  1. Hosting and infrastructure: Amazon Web Services (AWS), which hosts our app and database infrastructure (United States); DigitalOcean, which hosts our website (United Kingdom).
  2. Analytics: Google Analytics (GA4) on our website, and Mixpanel and Smartlook within the app. None of these tools identify you individually to us — they operate on an aggregated or anonymised basis.
  3. Payments: Stripe, Apple (App Store), and Google (Play Store) — see Section 3.5.
  4. Email and marketing: Mailchimp and Brevo, used to send communications to users who have registered with us and, where required, consented to receive them.
  5. Customer support: Zendesk, used to manage support requests.
  6. Advertising (website only, to bring users to uTalk — not shown within the app or website itself, and not linked to your device after you download the app): Meta (Facebook) advertising tools, Google Ads, and AI-assisted advertising optimisation tools — see Sections 4.3 and 10.
  7. Institutional access systems: the authentication and access-management systems used by the school, college, or library through which you access uTalk, where applicable — see Section 3.6.

5.2 We may also disclose personal data to our suppliers or subcontractors where reasonably necessary to operate the Service, or where necessary to comply with a legal obligation or protect someone's vital interests.

5.3 We do not sell your personal data.

6. International transfers of your personal data

6.1 We are based in the United Kingdom. Personal data from users in the European Economic Area (EEA) that we receive is transferred to the UK on the basis of the European Commission's UK adequacy decisions (renewed on 19 December 2025 and valid until 27 December 2031), which recognise that the UK provides an equivalent standard of data protection.

6.2 Some of the service providers listed in Section 5 are based in, or transfer data to, the United States. Where this happens, we rely on the safeguards below, each maintained by the provider itself under its own standard, published terms:

  1. AWS (hosting) — certified under the EU-U.S. Data Privacy Framework, including the UK Extension;
  2. Google (Analytics, Ads) — certified under the EU-U.S. Data Privacy Framework, with Standard Contractual Clauses incorporated into its business contracts as a further safeguard;
  3. Meta/Facebook (advertising) — self-certified under the EU-U.S. Data Privacy Framework;
  4. Stripe (payments) — certified under the EU-U.S. Data Privacy Framework, with a separate Data Transfer Addendum in place;
  5. Zendesk (customer support) — certified under the EU-U.S. Data Privacy Framework and also uses Standard Contractual Clauses;
  6. Mailchimp (email) — certified under the EU-U.S. Data Privacy Framework, with Standard Contractual Clauses incorporated as a fallback;
  7. Mixpanel (in-app analytics) — relies on Standard Contractual Clauses; an EU data-residency option (hosted in the Netherlands) is also available.

Our other providers — DigitalOcean, Smartlook, and Brevo — do not transfer personal data to the United States as part of providing their service to us. DigitalOcean hosts our website using its United Kingdom data centre only; Smartlook and Brevo are EU-based (Smartlook uses Standard Contractual Clauses only for a small number of its own infrastructure sub-processors).

6.3 When you subscribe through the Apple App Store or Google Play Store, your purchase is contracted directly with Apple's or Google's own European entity, not with us. Apple and Google act as independent data controllers for that transaction, under their own privacy policies, so the international transfer safeguards in Section 6.2 do not apply to it in the same way as our other providers.

6.4 Personal data you submit for publication through the Platform (for example, in a public profile or community feature, if applicable) may be available worldwide via the internet; we cannot prevent its use, or misuse, by others once published.

7. Retaining and deleting personal data

7.1 We keep personal data only for as long as necessary for the purposes described in this policy, or as required by law.

7.2 You can ask us to delete your data at any time, free of charge, by emailing support@utalk.com. Once we have verified your request and processed it, we delete your identifiable personal data and anonymise any remaining account and usage records so that they can no longer identify you. We aim to complete verified deletion requests without undue delay, and in any event within one month.

7.3 We may retain data for longer where necessary to comply with a legal obligation, or to protect someone's vital interests.

7.4 We may anonymise, de-identify, or aggregate information we collect and use that anonymised data for commercial, statistical, and market research purposes, including sharing it with affiliates and business partners — this does not include any personal data that could be used to re-identify you.

8. Amendments

8.1 We may update this policy from time to time by publishing a new version on our website and in the app. Material changes will be highlighted.

8.2 Please check this page occasionally to stay informed. We may also notify you of significant changes by email or in-app message.

9. Your rights

Subject to applicable law, you have the right to:

9.1 request access to the personal data we hold about you, free of charge (we may ask you to verify your identity using your registered account details before providing this);

9.2 request that we correct inaccurate personal data (rectification);

9.3 request that we delete your personal data (erasure) — see Section 7.2;

9.4 request that we restrict our processing of your personal data in certain circumstances (restriction);

9.5 object to our processing of your personal data where we rely on legitimate interests, including for direct marketing (objection) — you may opt out of marketing at any time;

9.6 request a copy of the personal data you've provided to us in a structured, commonly used, machine-readable format (data portability), where technically feasible;

9.7 withdraw consent at any time, where our processing relies on consent, without affecting the lawfulness of processing carried out before withdrawal; and

9.8 lodge a complaint with a supervisory authority — in the UK, the Information Commissioner's Office (ico.org.uk); if you are in the EEA, your local data protection authority.

We do not charge a fee for exercising these rights, save in the rare case of manifestly unfounded or excessive requests, and we do not require notarised or solicitor-certified identity documents to process a request.

10. About cookies

10.1 A cookie is a small file containing an identifier that a website sends to your browser, which is then stored and sent back to us (or our partners) on later visits. This section covers cookies on utalk.com. The app uses separate technologies (analytics SDKs) rather than browser cookies; these are described in Section 10.2(b) and are not connected to, or shared with, the advertising tools described in Section 10.2(c).

10.2 We use cookies and similar technologies for:

  1. essential operation of the website (for example, remembering you're logged in);
  2. analytics — Google Analytics (cookies on the website) and Mixpanel and Smartlook (SDKs within the app, unrelated to website advertising cookies). None of these tools identify you individually to us — they operate on an aggregated or anonymised basis;
  3. advertising, on utalk.com only. We run advertising campaigns for uTalk on external platforms (Meta/Facebook, Google Ads, and AI-assisted advertising optimisation tools) to bring new visitors to our website. To measure and retarget those campaigns, these partners' cookies run on utalk.com. This advertising activity is limited to our website — it does not run inside the uTalk app, and once you have downloaded the app, this website advertising activity is not linked to your device or your use of the app.

10.3 When you first visit utalk.com, we show a cookie banner. We are currently updating how this banner works. At present, dismissing or acknowledging the banner is treated as acceptance, and using the site is not blocked if you do not interact with it. We recognise that, for non-essential cookies such as analytics and advertising, applicable law requires a genuine opt-in choice made before those cookies are set, with an equally easy way to refuse. We are implementing a consent-management solution to bring this in line with that requirement; until it is live, this section describes our current practice rather than a fully compliant consent mechanism.

10.4 Most browsers let you refuse or delete cookies yourself; see your browser's help pages for how. Blocking all cookies may affect how well the website and app work for you.

10.5 Our analytics provider's own privacy policy is available at their website (for Google Analytics: https://www.google.com/policies/privacy/).

11. Our details

11.1 This Platform is owned and operated by EuroTalk Ltd., registered in England and Wales under company number 2674118. Our registered office and principal place of business is 315-317 New Kings Rd, London, SW6 4RF, United Kingdom.

11.2 You can contact us:

  1. by post, at the address above;
  2. using our website contact form;
  3. by telephone, on the number published on our website from time to time; or
  4. by email, at hello@utalk.com or support@utalk.com.