# Privacy Policy

Last updated: 27 October 2026

This policy explains how **Heartongue** ("Heartongue", "we", "us") handles personal data when you visit heartongue.com, use the app at app.heartongue.com, or listen to a Heartongue broadcast. Contact: team@heartongue.com.

## 1. Our role

- We are the **controller** for account, organization, billing-contact, support and website data.
- For the content an organization broadcasts (live audio, transcripts, translations and glossary), the **organization is the controller** and we act as its **processor**: we process it only to provide the Service on its instructions. Organizations that need a data processing agreement can request one at team@heartongue.com.

## 2. What we collect

**Website visitors**
- Standard server and CDN logs (IP address, browser, pages requested, time) used for security and to keep the site running. We use no advertising or analytics cookies on heartongue.com.

**Account users** (people who sign up to run broadcasts)
- Name, email address, password (stored only as a secure hash), language preference, and the organizations and roles you belong to.
- If you **sign in with Google**, we receive your name, email address, profile picture and Google account ID. See section 4.
- Invitations: the email address of the person invited and who invited them.
- Session records (IP address, browser, sign-in time) to keep your account secure.

**Organizations**
- Organization name, rooms (names, languages, optional PIN, settings), glossary entries, members, broadcast history (start and end time, languages, listener counts), and usage and balance records.

**Billing**
- Payments are processed by **Paddle**, our merchant of record. Paddle collects your payment details, billing address and tax information as an independent controller under its own privacy policy (https://www.paddle.com/legal/privacy). We receive from Paddle the customer and subscription identifiers, plan, amounts and transaction status, never your card number.

**Broadcast content**
- **Live audio** from the Broadcast page is processed in real time to produce captions and translated voice. **Audio is never stored.**
- **Text** (the transcript and translations) is kept only while it is delivered, unless the organization turns on **saved transcripts**, in which case it is stored for **90 days** and then deleted automatically. Organizations can download or delete saved transcripts at any time.

**Listeners**
- Listeners need no account. We do not ask for their name, email or age and set no tracking cookies. To deliver audio and captions we process their IP address and connection details, and limited security data to protect PIN-protected rooms. The app may store the listener's chosen language and theme in their own browser.

## 3. Why we use it (purposes and legal bases)

| Purpose                                                                                   | Legal basis (GDPR / UK GDPR)                       |
| ----------------------------------------------------------------------------------------- | -------------------------------------------------- |
| Creating and running your account and organization, delivering broadcasts, metering usage | Performance of our contract with you               |
| Billing and tax records (with Paddle)                                                     | Contract; legal obligation                         |
| Security, fraud and abuse prevention, preventing repeated free trials, logs               | Our legitimate interest in a safe, working service |
| Service emails (verification, password reset, invitations, important changes)             | Contract; legitimate interest                      |
| Answering support requests                                                                | Contract; legitimate interest                      |
| Product news by email (only if you opt in)                                                | Consent, which you can withdraw at any time        |

We do not sell personal data, do not use it for advertising, and do not use broadcast content or personal data to train machine-learning models.

## 4. Google user data

If you choose to sign in with Google, we request only the basic scopes `openid`, `email` and `profile`. We use the name, email address, profile picture and account ID we receive **only to create and secure your Heartongue account and to show your name to the organizations you belong to**. We do not use Google user data for advertising, do not sell it, and do not share it except with the infrastructure providers listed below that we need to run the Service. You can disconnect Heartongue from your Google account at https://myaccount.google.com/permissions. Heartongue's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

## 5. Who we share data with

We share personal data only with service providers that help us run Heartongue, under contracts that limit their use of the data to providing their service to us:

- **Infrastructure and hosting** providers that run our servers, database, website and email forwarding.
- **AI service** providers that turn speech into text, translate it and produce synthesized voice, in real time.
- **Paddle**, our merchant of record, for payments, invoices and sales tax (see section 2).
- An **email delivery** provider for account, password and invitation emails.
- **Google**, only if you choose to sign in with Google (see section 4).

Neither we nor our AI service providers use your content to train AI models. Providers may keep limited data briefly where their terms require it to prevent abuse. A current list of our service providers is available on request at team@heartongue.com.

We may also disclose data if required by law, to protect rights and safety, or as part of a sale or reorganization of the business (in which case this policy continues to apply).

## 6. International transfers

Our service providers may process data in countries other than your own, including the United Kingdom, the European Union and the United States. When personal data from the EU, EEA or UK is transferred to countries without an adequacy decision, we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or the provider's certification under the EU-U.S. Data Privacy Framework, as applicable.

## 7. How long we keep data

| Data                                | Kept for                                                                      |
| ----------------------------------- | ----------------------------------------------------------------------------- |
| Live audio                          | Not stored                                                                    |
| Saved transcripts                   | 90 days, or until the organization deletes them                               |
| Account and organization data       | While the account exists; deleted within 30 days after you ask us to close it |
| Broadcast history and usage records | While the organization exists                                                 |
| Billing records                     | As long as tax law requires (Paddle keeps its own records)                    |
| Server and security logs            | Up to 30 days                                                                 |

## 8. Cookies

The app uses only cookies that are strictly necessary to keep you signed in and secure. The website uses no tracking or advertising cookies. Your language and theme choices may be saved in your browser's local storage.

## 9. Your rights

Depending on where you live, you may have the right to access, correct, delete, restrict or object to the processing of your personal data, to receive a copy in a portable format, and to withdraw consent. To use these rights, email team@heartongue.com; we reply within one month. If your data is part of an organization's content (for example a transcript), we will pass your request to that organization.

- **EU/EEA and UK:** you can also complain to your local data protection authority (in the UK, the Information Commissioner's Office).
- **California and other US states:** we do not sell or share personal information for cross-context behavioral advertising, and we do not use sensitive personal information to infer characteristics. We give the same rights to all users regardless of location.
- **Vietnam:** we process personal data in line with Vietnam's Personal Data Protection Law, and you may exercise the rights it grants by contacting us.

## 10. Children

Heartongue accounts are only for people aged 18 and over, and the Service is not directed at children. Listeners do not create accounts and we do not knowingly collect personal information from children under 13. Organizations decide who attends their broadcasts and must not broadcast children's speech where the law requires parental consent unless they have it. If you believe a child has given us personal data, contact us and we will delete it.

## 11. Security

We protect data with encryption in transit, secure password storage, access controls by organization and role, and protection against unauthorized access to rooms. No system is perfectly secure; if a breach affects your personal data we will notify you and the relevant authorities as the law requires.

## 12. Changes

We may update this policy. We will post the new version here with a new date and notify account owners by email of material changes.

## 13. Contact

Heartongue — team@heartongue.com
