Privacy Policy

What data we use and what for

Before you start studying, we record your confirmation that you are 18 or older, the versions of the Terms of Service and the Privacy Policy shown to you, and the date you accepted them. We do not collect your date of birth in that confirmation.

• Founder price: at launch, we keep a fingerprint of the email of each person entitled to the founder price (a code calculated from it, not the address), to apply that price to the account created with the same email. It is deleted if you delete your account or ask through the contact details in this policy; in the backups, it disappears when they expire.
• App statistics: in the installed app, after you create the account or sign in, these statistics are on, based on legitimate interest and not on consent, with the same pseudonymous account code, without recording sessions and without ads. You can turn them off at any time under Profile › Preferences › Usage statistics. Before the account, the app only counts, by step and by day, how many people go through the introduction, like the anonymous count below: with no identifier, no device data, and no IP. Legitimate interest test, in short: the purpose is to know where the app helps and where people stop, to improve it; it is necessary because without those numbers we would not know what to fix, and we use only usage events, never what you write; in the balance, the data is pseudonymous, does not serve ads and is not sold, and turning it off is simple and takes effect at once. The full record of the test is available on request through the contact details in this policy.
• Nekomachi visits: with the app’s usage statistics on, we keep, with your account, each day you opened Nekomachi and where you came in from, to measure the use of Nekomachi and improve the product. This record stays only at Fluentei and does not go to the statistics service. It is deleted when you turn the statistics off or delete the account, and each day is deleted after 12 months.
• Voluntary feedback: you can give feedback on readings, music, and games even without authorizing statistics. By clicking “Send feedback”, you authorize the use of the rating, the choice, and an optional comment of up to 500 characters to improve that experience. We keep the answer and the receipt of that authorization linked to your account. New answers are analyzed by Fluentei, without being sent to the statistics service and without any link to statistics or error reports. We do not send views, dismissals, reading history or playback history. We filter known patterns of contacts, links, and credentials; this does not make a text anonymous or remove every sensitive piece of data. Do not include personal data or excerpts of your material.
• Anonymous usage count: with the app’s statistics off, and before you have an account, we count in an anonymous and aggregated way completed sign-ups, steps and answers of the introduction to the product, trials started, subscription and payment events (purchase completed or abandoned, conversion, renewal, cancellation and the reason chosen, and the category of a declined payment, never amounts or card data) and usage events, using only data from the event itself (for example, step, plan, billing period, trial length and device type), with no identifier of you or of the account, no profile, no origin data, no IP or location and no cookie, with a random code per event, based on legitimate interest in measuring how many people use and complete each step of the product. You can object by writing to suporte@fluentei.com.br.
• Campaign measurement: when you arrive through a Fluentei campaign link, we keep with the account only the source, the medium and the campaign name, never a click identifier, to add up sign-ups, trial starts and first subscriptions by campaign and by day. These totals contain no account, email, identifier or IP. The campaign kept with the account is deleted at the first subscription, within 90 days or when the account is deleted, whichever comes first. Basis: legitimate interest in knowing which campaigns work.
• Operation and security: connection and device data and privacy preferences, to make the site and the app available and to prevent abuse, based on the legitimate interest in protecting the service and its users. While a session is open, we keep with it the IP address and the type of device and browser, deleted when the session expires. Sign-in security events, such as access attempts, are kept for 30 days, without the IP, only with a code that does not reveal it.
• Device country: when you create the account, we keep with it the country of the region set on the device, never inferred from the IP address, to adapt the study content to your country, based on performance of the contract. If the device does not report a region, no country is kept.
• Error monitoring: we use a monitoring service to find and fix failures and keep the service running safely, based on legitimate interest. We send the type and message of the error, the screen, the system and the version of the app, after removing unnecessary personal content. We do not send your email, account identifier, study content, or credentials. When you are signed in, errors carry the pseudonymous code of your account, the same on all your devices, to give support and fix failures, based on legitimate interest, even without consent for statistics. This code does not reveal your email or the account identifier. Reports from visitors who are not signed in are anonymous, with no link between them. You can object to this processing by writing to suporte@fluentei.com.br.
• Study features: account data, content you send and study activity, to provide the features you ask for, including the artificial intelligence ones, based on performing the service at your request. To track the cost and quality of the AI features, we record in the statistics service metrics of each use (cost, response time, type of request, and errors), never the content sent or the answers. With your consent for statistics, these metrics are linked to the pseudonymous account code described above; without it, they are counted anonymously, with a random code per event, with no profile, IP or location, based on legitimate interest in keeping these features running at a controlled cost.
• Onboarding answers: your reasons for learning Japanese, your level, what tends to get in the way of your studies, how much time you have a day and, if you write one, your idea for a song theme, as free and optional text, to build your plan and your study suggestions, based on performance of the contract. These answers stay with your account and are deleted when it is deleted; in the backups, they disappear when the backups expire. We do not sell these answers or share them for advertising.
• Chat with Ginga: the messages you write, the Notebook passage used in the question, Ginga’s answers and your ratings of them, to answer and keep the chat history, based on performance of the contract. An automatic safety check analyzes each message before the answer. Ginga’s memory keeps your interests, declared level, and practice pace; you can edit or clear it at any time.
• Notifications: notices about credits, refunds, creations, and Fluentei news are kept with your account, along with when you read them, to show you your notifications, based on performance of the contract. They are deleted when the account is deleted; in the backups, they disappear when the backups expire. In the app, if you turn on the Review reminder, we keep the device’s notification code to send the reminder through the service that delivers the app’s notifications. That code is deleted when you delete the account, and when you sign out on the device, as soon as the device is online.
• Error reports in readings: when you use “Report an error” on a catalog reading, Fluentei keeps the reading, the version, the page, the selected passage, when there is one, and your message, along with a reference to your account, without using your email to identify it. Our team uses these records to analyze the report and fix the content, based on legitimate interest in keeping the catalog correct. Do not write personal data in the message.
• Reports in the Notebooks you create: when you use “Report a problem” on a song or reading you created, Fluentei keeps the Notebook, the page, the selected passage, and your message, along with a reference to your account, to analyze the report and keep the generated content safe, based on legitimate interest. The report is deleted with the Notebook or with the account; in the backups, it disappears when the backups expire. Do not write personal data in the message.
• Purchases in the app: in the app, the subscription is made through the store (Google Play or the App Store), which processes the payment and the card data. To confirm those purchases and activate your plan, we use a service that confirms purchases made in the store, which receives an identifier of your account, the history of purchases made in the store and technical data about the device and the app, based on performance of the contract. We do not receive or store your card data.
• Sign in with Google: when you choose this method, we receive the Google account identifier, verified email, name, and profile photo, when available, to create or access your Fluentei account. We keep the link and the technical credentials needed, in a protected way. We do not ask for access to Drive, Gmail, or other data in your Google account.
• Sign in with Apple: in the iPhone app, when you choose this method, we receive from Apple the identifier of your Apple ID for Fluentei and the email Apple provides, which may be a relay address created by Apple if you choose to hide yours, to create or access your Fluentei account. We do not ask for your name or other data from your Apple ID. We keep the link and the technical credentials needed, in a protected way.

Your choices

The English site does not use analytics cookies. In the app, once you have an account, the usage statistics are on, based on legitimate interest, and the “Usage statistics” switch, under Profile › Preferences, turns them off at any time. Turning them off does not stop you from using the study features, also deletes the Nekomachi visits kept on the account, and does not undo data already sent. The error monitoring described above stays on to keep the service running. When you are signed in, we record on the account each choice made there, with date and version of this Policy, as proof of your choice, without IP or browser data; this record stays only at Fluentei and is kept even after the account is deleted, without email or name. You can also object, or deal with data already shared, through the contact details in this policy.

Feedback has a separate authorization. Under “Give feedback” in the Notebook, see the receipt and use “Withdraw my response”; for other answers, use the contact details in this policy, and to delete the account, see Account deletion. Withdrawing deletes the rating, the choice, the comment, and the link to the Notebook. We keep only a minimal receipt to confirm the withdrawal and to prevent a second answer to the same question. To withdraw survey answers sent earlier to the statistics service, use the contact details in this policy. Declining statistics does not withdraw an answer already authorized. “Don’t ask again” stops the questions without deleting answers; “Turn automatic questions back on” undoes that preference. We keep only the account’s last prompt, postponement, and preference to respect these choices and avoid repeated questions, without creating a behavior history or sending those preferences.

If we learn that a person under 18 created an account, we may assess the case individually, decide the appropriate measures and handle the data under the rights and legal grounds described below. You can tell us through the contact details on this page. We do not ask for a document or date of birth by default.

You can unlink Google under Profile › Account. This removes that way of signing in; it does not delete your history or sessions already open. To delete the account, see Account deletion.

Support by email

For support or complaints, write to suporte@fluentei.com.br. We use your name, email, message, any attachments you choose to send, and the dates of the conversation to handle the request and follow up on your reply. Depending on the subject, this processing serves performance of the contract, compliance with legal obligations or the exercise of rights. It does not depend on the optional consent for statistics or advertising.

Our email service acts as a processor to receive, organize, and store these conversations. The history is restricted to the people authorized to give support. Sending a message does not make you a participant in our internal inbox or let other learners read your request.

We keep support conversations for up to 180 days after they close. We keep for longer only the records needed for a legal obligation or the exercise of rights. Our support backups are restricted and deleted within 56 days; when a backup is restored, we reapply deletion requests. The email provider can take up to 180 days after the final deletion to delete data from its systems, under the contract and legal exceptions. Do not send a password, a sign-in code, or full card details.

Sharing and protection

To provide the service, we rely on providers that handle data on our behalf (processors), under contract and only for these purposes:

• hosting, database, security, backups, and sending emails;
• artificial intelligence features (translations, explanations, Chat with Ginga, safety checks of messages, songs, narration, and recognition of sung lyrics), which receive only the content needed for each request;
• support by email.

These providers follow our instructions and the security measures of the contract, and Fluentei remains responsible to you. The provider of Chat with Ginga’s answers may keep records of those requests for up to 30 days to monitor abuse.

Only in these cases does data go to third parties that make their own decisions about it: Google or Apple, when you sign in with their account or subscribe through their store; and authorities, when the law requires. You can ask for the list of providers through the contact details in this policy (LGPD, Brazil’s data protection law, art. 18, VII). We use protected connections and access controls to restrict the use of data.

YouTube videos: in the video Notebooks, we use the YouTube API Services to play the video in the official YouTube player. When a YouTube video appears, YouTube and Google may store or read cookies and similar data on your device, as described in the Google Privacy Policy. Fluentei does not ask for access to your YouTube account; if you connected your Google account to a service, you can revoke that access in your Google account security settings.

International transfer

• Where to: some of the providers described above handle data outside Brazil, in the United States.
• What for: hosting the service, storing data, processing requests to the artificial intelligence features, measuring authorized use, monitoring errors, and giving support.
• How and for how long: data is sent over protected connections and handled only for the time described in How long.
• On what basis: the standard contractual clauses approved by the ANPD (Brazil’s data protection authority; Resolution CD/ANPD no. 19/2024) or, when the transfer is necessary to perform the contract with you or to meet a request of yours, art. 33, IX, of the LGPD.
• Who is responsible: the controller and the data protection officer described in Who looks after your data. The providers follow the security measures of the contract, and Fluentei remains responsible to you.
• Your rights: you can exercise the rights described below through suporte@fluentei.com.br, ask for a copy of the clauses free of charge, which we send within 15 days, and file a complaint with the ANPD.

How long

Nekomachi visits are deleted automatically after 12 months. In the statistics service, the statistics, the survey answers sent earlier and the error records linked to your account are deleted when you delete the account. You can ask for information or request deletion earlier through the contact details in this policy. These periods do not apply to the content of your conversations with Ginga or of your Notebooks.

The local feedback answer remains while needed to improve the experience and can be withdrawn at any time. We do not keep drafts or earlier versions of the answer. Fluentei will review the need for this retention when the beta evaluation ends.

We keep the founder code until the account is deleted or you ask. Account and study data remain while needed to provide the service; you can request their deletion. The records of confirmed charges are kept while needed for that purpose and for the legal grounds for retention. Other records are kept only while needed for their purpose or for the grounds for retention provided by law.

Conversations with Ginga are kept for 90 days and then deleted. You can delete them sooner, at any time, under Profile › Account.

Your progress in Ginga’s Journey (completed stages, seals, and unit tests) is kept with the account until it is deleted.

Backups are kept for up to 35 days and then deleted; when a backup is restored, we repeat the account deletions.

Account deletion

You can delete your account in the Fluentei app under Profile › Account › Delete account. If you signed in more than 15 minutes ago, we ask you to sign in again. Deletion is immediate and can’t be undone: access ends at once. If you can’t sign in, write to suporte@fluentei.com.br from the account’s email; our team deletes the account and replies when it is done.

If there is a subscription, what happens depends on where it was made:

• Google Play: we cancel the subscription on Google Play before deleting the account. If the cancellation fails, the account is not deleted, and you can try again.
• App Store: Apple does not let Fluentei cancel for you. The charge continues until you cancel in your Apple settings; you can delete the account anyway.

We delete the email, the name, the photo, the sign-in methods, and the sessions, as well as the content of the account, such as Notebooks, songs, conversations with Ginga, onboarding answers, notes, feedback, playlists, notifications, and Nekomachi visits. If you sign in with Apple, we revoke Fluentei’s access to your Apple ID. We ask the statistics service to delete the data linked to the account; it deletes the events in batches, usually within a week.

What stays, without your email, name, or texts, is the record of confirmed charges and credits, the acceptances of the Terms and the Privacy Policy, the record of choices on statistics and ads (as proof of consent), the record of the age restriction in Ginga and the study history without text, such as reviews and games. Backups are deleted within 35 days; when a backup is restored, we repeat the account deletions.

After the deletion, you can create a new account with the same email. It starts from scratch, without access to what was deleted.

Your rights

Under the LGPD, you can request confirmation and access to your data, correction, anonymization, blocking or deletion of unnecessary or unlawfully handled data, portability when applicable, and information about sharing, including the list of entities we share data with. You can also refuse or revoke consent, be informed of the consequences of not consenting and ask for the deletion of data handled on that basis, subject to legal exceptions.

Send your request free of charge to suporte@fluentei.com.br. We may confirm your identity to protect your data. You can also file a complaint with the ANPD. Changes to this notice will be published on this page; new purposes that depend on consent will require a new choice.

Who looks after your data

The controller of the personal data handled on this site, in the app and in the study features is HENRIQUE DAL MORA ROSENDO DA SILVA CONSULTORIA EM TECNOLOGIA DA INFORMACAO, CNPJ 46.692.459/0001-02, at Av. Paulista, 777, 15º andar, conj. 15, sala 1526, Bela Vista, São Paulo/SP, CEP 01311-914, which operates Fluentei.

The data protection officer (LGPD, art. 41) is Henrique Dal Mora. For privacy matters, write to suporte@fluentei.com.br.

See also the Terms of Service.

Changes

• November 4, 2026: our contact address is now suporte@fluentei.com.br. No new purpose.
• November 1, 2026: we name YouTube where its player appears, and what it may store on your device. No new purpose.
• November 1, 2026: we describe the app’s statistics for the app on every device, iPhone included, and error monitoring for the app only, since the English site runs no script. No new purpose.
• October 31, 2026, English edition: this is the English edition of the Privacy Policy, for the English app, based on the Portuguese version of October 31, 2026. No new purpose.
• October 31, 2026: we make clear that the account of someone who says they are under 18 may be assessed case by case, with no automatic measure. No new purpose.
• October 30, 2026: we describe the country of the device’s region, kept with the account when it is created, to adapt the study content to your country.
• October 29, 2026: we name the data protection officer; we bring the international transfer together in one section, with the country, the purpose and the legal basis; we describe sign-in with Apple; analytics data kept at Fluentei is now deleted after 12 months (before, 400 days for Nekomachi visits); and we describe providers by category. You can ask for the list through the contact details in this policy. No new purpose.
• October 25, 2026, Android app: once you have an account, the app’s statistics use legitimate interest, are on by default, and can be turned off under Profile › Preferences; before you have an account, the app counts, by step and by day, how many people go through the introduction, with no identifier.
• October 24, 2026, reports in the Notebooks you create: we describe “Report a problem” on the songs and readings you create, deleted with the Notebook or with the account. No new purpose.
• October 24, 2026, app: we describe purchases in the app through the store, confirmed by a purchase-confirmation service with an identifier of your account, and the device’s notification code for the Review reminder. No new purpose.
• October 23, 2026, Notebook narration: we changed the provider that narrates the sentences you hear and lights up the words along with the narration. Narrations already made stay as they are. No new purpose.
• October 21, 2026, backups: backups are kept for up to 35 days and then deleted; when a backup is restored, we repeat the account deletions. No new purpose.
• October 17, 2026, campaign measurement: we count sign-ups, trial starts and first subscriptions by campaign (the source, the medium and the campaign name) in daily totals with no data about people; the campaign stays with the account only until the first subscription, for up to 90 days.
• October 17, 2026, Nekomachi: with consent for statistics, we keep on the account the days you opened Nekomachi, for up to 400 days, deleted when you withdraw consent or delete the account. No new purpose, and what you accepted still applies.
• October 11, 2026, record of choices: people who haven’t yet chosen about statistics and ads now also see the question when signing in, in the app, and in the game, and we record on the account each choice made while you are signed in, as proof of consent, kept even after the account is deleted. No new purpose, and what you accepted still applies.
• October 11, 2026, AI features: we explain the usage metrics of the AI features (cost, response time, type of request and errors, never the content): with consent for statistics, they are linked to the account’s pseudonymous code; without it, they are counted anonymously. No new purpose, and what you accepted still applies.
• October 11, 2026, subscriptions: we include in the anonymous count the subscription and payment events (purchase, conversion, renewal, cancellation and the reason chosen, declined payment by category), with the same safeguards and without amounts or card data. No new purpose, and what you accepted still applies.
• October 11, 2026, anonymous count: we widened the anonymous and aggregated count without consent, previously limited to trials started, to sign-ups, steps of the introduction and use of the product, with the same safeguards, and we stopped keeping city and CEP in the authorized statistics. No new purpose, and what you accepted still applies.
• October 9, 2026: we include the Account deletion section and Ginga’s memory, which you can clear whenever you like. No purpose changed, and what you accepted still applies.
• October 4, 2026: earlier version.