Privacy Policy
Watch Your Tones ("the Service," "we," "us," "our"), operated by Watch Your Tones (operated by Everitt Gill), helps people practice Mandarin pronunciation by processing voice recordings for transcription and tone scoring. This Privacy Policy explains what data we collect, why we collect it, how long we keep it, who we share it with, and the rights you have over it.
We try to write in plain language. Where a legal term matters (like "lawful basis" under GDPR), we use it and explain it.
1. Who this policy applies to
This policy covers:
- Visitors to our marketing website at
watchyourtones.com - Registered users of the web application at
watchyourtones.com/app - Anyone who contacts us directly
It does not cover the practices of third-party services we integrate with. Where we send data to a third-party processor (Section 4), you should also consult that provider's own privacy policy.
2. What we collect
2.1 Information you give us directly
| Category | Examples |
|---|---|
| Account information | Email address, password (stored as a secure hash by our auth provider, never in plaintext), optional display name |
| Payment information | Subscription status, trial status, billing events, last 4 digits of card and card brand. We never see or store full card numbers, CVVs, or bank credentials. |
| Support correspondence | Emails or messages you send us, including any information you choose to include |
2.2 Information generated when you use the Service
| Category | Examples | Retention |
|---|---|---|
| Voice recordings (raw) | Audio clips captured when you press Record | Streamed to speech pipeline. Pseudonymized audio may be retained for up to 30 days for diagnostic, service-quality monitoring, model calibration, and abuse-detection purposes, then deleted. |
| Transcriptions | Text transcribed from your voice recordings | While your account is active |
| Pronunciation scores | Per-word and per-syllable tone scores, accuracy, fluency | While your account is active |
| Conversation history | Your messages and the AI tutor's responses | While your account is active |
| Learning data | Vocabulary list, flashcard review history, FSRS parameters, progress metrics | While your account is active |
2.3 Information we collect automatically
| Category | Examples |
|---|---|
| Device / technical data | IP address, browser type and version, operating system, device type, screen size, timezone, language preference |
| Usage data | Pages viewed, features used, session duration, crash reports (via Sentry — no voice audio is included) |
| Cookies and similar technologies | See our Cookie Policy for details |
2.4 Voice data — we do not process it biometrically
Your voice recordings are processed solely to produce transcriptions, pronunciation scores, and AI tutor responses. We do not:
- Create voiceprints or voice-identity templates
- Conduct speaker recognition, speaker verification, or any identity authentication using your voice
- Use your voice to uniquely identify you, re-identify you, or compare you to other users outside of service delivery
- Sell or license your voice recordings to third parties
To the extent any state or national law — including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), Washington's biometric privacy law, or the California Consumer Privacy Act's "sensitive personal information" category — applies to voice data processed by the Service, we process such data solely to provide the Service and for the limited internal service-improvement purposes described in Section 3. Your voice is not used for identification, authentication, or marketing profiling.
3. Why we collect it, and the legal basis (GDPR)
Under the GDPR, we need a lawful basis to process personal data. The basis depends on what we're doing with it.
| What we do | Why | GDPR lawful basis |
|---|---|---|
| Run your account and deliver the Service | You signed up for it | Contract (Art. 6(1)(b)) |
| Transcribe voice, score pronunciation, generate AI responses | Core feature of the Service | Contract (Art. 6(1)(b)) |
| Bill you, process refunds, resolve payment disputes | You subscribed to a paid plan | Contract + legal obligation (Art. 6(1)(b), (c)) |
| Keep logs for security, debugging, fraud prevention, abuse detection | Protect the Service and other users | Legitimate interests (Art. 6(1)(f)) |
| Calibrate and improve our own speech-recognition, tone-scoring, and AI-conversation models using pseudonymized data (30-day window) and de-identified data (indefinitely) | Maintain and improve a core Service capability | Legitimate interests, balanced against your rights |
| Analytics and product improvement (aggregate usage metrics) | Understand how the Service is used | Legitimate interests |
| Marketing cookies (Google Analytics, Meta Pixel) | Measure ad performance and retargeting | Consent (Art. 6(1)(a)) — withdraw at any time |
| Respond to legal process, comply with subpoenas, enforce our Terms | Comply with the law and protect our rights | Legal obligation / legitimate interests |
We rely on legitimate interests only after a balancing test. Where our interests do not override your rights and freedoms, we either seek consent or stop the processing. You have the right to object to legitimate-interests processing — see Section 7.
We do not sell your personal data. We do not use your voice recordings to train generative AI models operated by third parties. We may use de-identified, anonymized, or aggregated data derived from your voice recordings and other Service data to improve our own models and features — this is described in Section 6.3 of the Terms of Service.
4. Who we share data with
4.1 Subprocessors
We share data with the service providers needed to operate the Service. Each provider is bound by a data-processing agreement (or equivalent contractual terms) and may only use your data to provide services to us.
| Subprocessor | Purpose | Country / Region | Data categories |
|---|---|---|---|
| Supabase | Database, authentication | United States (AWS us-east) | Account info, learning data, billing metadata |
| Fly.io | Application hosting | United States (LAX) | All in-transit request data |
| Anthropic (Claude API) | AI conversation and teaching responses | United States | Conversation transcripts, learning-context prompts |
| Groq | Speech-to-text transcription | United States | Voice audio (transient), transcription output |
| iFlytek | Pronunciation tone scoring, text-to-speech | People's Republic of China (routed via Singapore endpoints) | Voice audio, reference text, transcription |
| Paddle | Subscription billing, payment processing, tax | United Kingdom + United States | Email, billing info, subscription state |
| Sentry | Error and performance monitoring | United States | Stack traces, request metadata, user ID. No voice audio. |
| Google Analytics 4 | Website analytics on marketing site | United States | Truncated IP, device info, page views |
| Meta Pixel | Ad attribution and retargeting | United States | Page views, conversion events |
For material changes to our subprocessor list, we will provide at least 15 days' advance notice.
4.2 Business transfers
If we undergo a merger, acquisition, financing, reorganization, asset sale, bankruptcy, or similar transaction, your data may be transferred to the successor entity. The successor will be bound by privacy terms no less protective than this Policy, or we will notify you and provide an opportunity to delete your account before the transfer closes.
4.3 Legal compliance and protection
We may disclose data where required by law, valid legal process (including subpoena or court order), or where we in good faith believe disclosure is necessary to:
- Comply with a legal obligation
- Investigate, prevent, or take action against fraud, abuse, or violations of these Terms
- Protect the safety, rights, or property of us, our users, or the public
- Defend, establish, or exercise our legal rights
Where permitted by law, we will notify you of a legal-process demand that affects your account before complying, so you may seek to challenge it.
5. Data retention
We retain personal data only for as long as necessary for the purposes described in this policy, or as required by law.
| Data | Retention period |
|---|---|
| Voice audio (raw) | Streamed and discarded after processing. Pseudonymized audio retained for up to 30 days for diagnostic / service-quality / model-calibration purposes, then deleted |
| Transcriptions, conversation history, scores, vocabulary | Retained while your account is active |
| Account information | Deleted within 30 days of an account-deletion request |
| Billing records | 7 years after account closure (U.S. and EU tax/accounting law) |
| Server logs (access, security) | 90 days |
| De-identified or aggregated data | Retained indefinitely — once data is de-identified, it is no longer personal data and is not subject to deletion rights |
When an account is deleted, we remove personal data from our active systems. Encrypted backups containing your data are rotated on a rolling basis and are fully purged within 90 days.
"De-identified" or "anonymized" means data from which reasonable measures have been taken so that it cannot be reasonably linked back to an identifiable individual. Anonymized data is no longer personal data under GDPR or CCPA/CPRA and may be used, retained, and shared indefinitely for any lawful purpose.
6. International data transfers
Because our service providers are located in multiple countries, your personal data may be transferred to and processed outside your country of residence, including in the United States and, for iFlytek services, through Singapore endpoints operated by a Chinese company.
Where such transfers are subject to GDPR, we rely on one or more of the following legal mechanisms:
- Adequacy decisions of the European Commission, where applicable
- The EU-U.S. Data Privacy Framework for participating U.S. providers
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Binding Corporate Rules, where adopted
- Derogations under Article 49 GDPR, including your explicit consent to a specific transfer or necessity for the performance of a contract
- Any other lawful transfer mechanism recognized under applicable data-protection law
You can request a copy of the safeguards we rely on by contacting us.
7. Your rights
You have rights over your personal data. The specific rights depend on where you live.
7.1 Everyone
- Access — request a copy of your personal data
- Correction — correct inaccurate data
- Deletion — request deletion of your account and associated data
- Opt-out of marketing cookies — via the cookie banner or your browser settings (see Cookie Policy)
7.2 If you live in the EU / UK / EEA (GDPR)
- Portability — receive your data in a machine-readable format and transmit it to another controller
- Restriction — ask us to limit how we use your data in certain circumstances
- Object — object to processing based on legitimate interests, including profiling
- Withdraw consent — where processing is based on consent, withdraw it at any time
- Lodge a complaint with your local data protection authority (EU: edpb.europa.eu / UK: ico.org.uk)
7.3 If you live in California (CCPA / CPRA)
- Right to know what personal information is collected, used, shared, or sold
- Right to delete personal information we collect from you
- Right to correct inaccurate personal information
- Right to opt out of the sale or sharing — we do not sell personal information and do not "share" it for cross-context behavioral advertising other than as described under "Marketing cookies" in Section 3, which you can disable via our cookie banner
- Right to limit the use of sensitive personal information — voice recordings may be considered sensitive under CPRA; we use them only for providing the Service
- Right to non-discrimination — we will not discriminate against you for exercising any right
To exercise a California right, email sellitwitheveritt@gmail.com with the subject line "CCPA Request."
7.4 Nevada residents
Nevada law allows residents to opt out of the sale of certain categories of personal information. We do not sell personal information. To submit a verified request regardless, email sellitwitheveritt@gmail.com with subject "Nevada Opt-Out."
7.5 How to exercise any right
Email sellitwitheveritt@gmail.com with your request. We will respond within 30 days (or 45 days for California requests). For complex or voluminous requests, we may extend the response window by up to 45 additional days with notice to you.
Identity verification. For security, we verify your identity before acting on any request. Typically, this means confirming control of the account email. For sensitive requests (such as bulk data export or deletion of records tied to billing), we may require additional verification, including a government-issued ID. We will not process requests we cannot reasonably verify.
Authorized agents may submit requests on your behalf with written authorization signed by you; we may verify with you directly.
Fees. Requests are free. We may charge a reasonable fee for, or decline, requests that are manifestly unfounded, excessive, or repetitive.
8. Security
We use the following measures to protect your data:
- TLS 1.2+ encryption for all data in transit
- Encrypted storage at rest through Supabase / AWS
- Passwords are handled as bcrypt hashes by Supabase Auth; we never see or store plaintext passwords
- Row-level security (RLS) on all user-scoped database tables
- Restricted access to production systems, with access logs
- Routine dependency updates and security monitoring
No system is perfectly secure. If we become aware of a breach that affects your personal data, we will notify you and the relevant supervisory authority as required by law. Breach notifications are sent to the email address associated with your account; you are responsible for keeping this address current. Our notification obligation is the minimum required by applicable law. Our liability for breach-related damages is limited as described in the Terms of Service.
You agree to cooperate with our investigation of any security incident involving your account or credentials.
9. Children's privacy
The Service is not directed at children under the age of 13, and we do not knowingly collect personal information from children under 13 (COPPA). If we learn an account is operated by a user under 13, we will terminate the account and delete associated data; refunds (if any) are governed by the Terms of Service. If you are a parent or guardian and believe a child under 13 has provided personal information to us, email sellitwitheveritt@gmail.com and we will delete it.
For users aged 13–17, we recommend a parent or guardian review this policy and the Terms of Service.
10. Cookies and tracking
We use cookies and similar technologies to keep you logged in, remember your preferences, understand how the Service is used, and measure advertising performance. For the full breakdown — including how to opt out of non-essential cookies — see our Cookie Policy.
11. Do Not Track
Some browsers send a "Do Not Track" (DNT) signal. There is currently no industry-standard way to respond to DNT signals, so we do not respond to them. You can control tracking through our cookie banner and your browser settings. We honor Global Privacy Control (GPC) signals as an opt-out of the "sale" or "sharing" of personal information under CCPA/CPRA.
12. Third-party links
The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. Please review their privacy policies before providing them with personal data.
13. Changes to this policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top of the policy reflects the most recent revision.
- For material changes that expand our use of your data or reduce your rights, we will provide at least 30 days' notice by email or in-app notice before the change takes effect.
- Non-material changes — including clarifications, typographical fixes, subprocessor additions within the same category, and reorganization — may take effect immediately upon posting.
Your continued use of the Service after the effective date constitutes acceptance of the updated Policy.
14. Contact us
For privacy questions, data requests, or to exercise any right under this policy:
- Email: sellitwitheveritt@gmail.com
- Operator: Watch Your Tones (operated by Everitt Gill)
For California residents exercising CCPA rights, please use the subject line "CCPA Request" in your email so we can route the request correctly.
For EU/UK residents: if we become required to appoint an EU or UK representative under Article 27 of the GDPR, we will publish their contact details here.