Draft for review. This policy is not ready for publication until the final public URL and applicable legal review are confirmed.

This Privacy Policy explains how Unity Bridge Solutions Ltd ("Cleverly Lingo," "we," "us," or "our") collects, uses, shares, retains, and deletes information when you use the Cleverly Lingo mobile app, companion app, keyboard extension, and related services (collectively, the "Service").

Privacy at a glance

Information we collect and process

The information involved depends on which features you use.

Account and authentication information

If you create or sign in to an account, we process an account identifier and your primary email address. If you choose Sign in with Apple or Google sign-in, the relevant provider and our authentication provider process the information needed to authenticate you. Apple may provide a private relay email address if you select that option.

We use this information to authenticate you, keep your synced content separated from other users' content, support account recovery, and process account deletion.

Text you deliberately submit for cloud features

When you tap a cloud action such as Translate, Enhance, change tone, or Summarize, the text selected for that action and the options you choose are sent to our backend and relevant AI or translation provider. We process that text to return the requested result.

We may temporarily cache the submitted text and generated result to provide the feature efficiently and prevent repeated processing. AI enhancement cache records are configured with a seven-day expiry and are deleted sooner when you delete your account.

Notes and translation history

Notes and translation history can be stored locally on your device. When you are signed in and synchronization is enabled, they are also stored in our cloud database so they can be restored and synchronized. These records may include note titles and bodies, source and translated text, source and target languages, feature type, timestamps, and a device-scoped identifier used for synchronization.

Camera and image translation

When you choose camera or photo translation, the selected image is sent for optical character recognition and translation. Our backend does not retain the original image. It may retain an image hash and the extracted and translated text, language information, and text-region metadata to return results and avoid duplicate processing. Non-favorite image-translation results are eligible for cleanup after 30 days; saved or favorite results remain until you remove them or delete your account.

Voice and live translation

When on-device dictation is available and selected, speech recognition is performed on your device using Apple's speech services. When you deliberately use cloud voice or live translation, audio is streamed to our speech relay and Google Cloud speech services to produce transcription and translation. We do not store the streamed audio in our application database. We retain limited usage records such as session duration, audio processed, character counts, languages, provider, and timestamps for reliability, abuse prevention, and cost control.

Subscription and purchase information

If you view, start, restore, or manage a subscription, Apple and RevenueCat process purchase information. We receive subscription and entitlement details such as an opaque billing identifier, product identifier, transaction identifier, subscription status, store environment, and purchase, renewal, or expiration dates. We do not receive or store your full payment-card details.

Usage, security, and diagnostic information

We process limited operational data needed to run and protect the Service. This may include feature type, request counts, text or audio length, token or character counts, timestamps, language choices, response status, error categories, app configuration, and pseudonymous account, session, or device identifiers. Our logs are designed to record metadata rather than the content you type, say, or translate.

Our infrastructure providers may process network information such as IP address and request headers as necessary to transmit requests, prevent abuse, and keep their services secure.

How we use information

We use information to:

We do not use your content for third-party advertising or sell it to data brokers.

When information is shared

We share information only as needed to operate the Service, complete actions you request, protect users and the Service, or comply with law. Our principal service providers are:

These providers process data under their own terms and privacy commitments and, where they act for us, under contractual data-protection obligations. They may use subprocessors to provide their services.

We may also disclose information when reasonably necessary to comply with law, respond to valid legal process, protect rights and safety, investigate fraud or security incidents, or complete a merger, financing, acquisition, or sale of assets. If ownership changes, personal information will remain subject to applicable law and any notice required for the transaction.

Retention and deletion

We retain information only for as long as reasonably necessary for the purposes described in this Policy:

When you delete your account, Cleverly Lingo deletes user-linked content and private billing mappings from its active systems and requests deletion from the relevant authentication and subscription systems. Some minimized, non-identifying, or one-way hashed records may remain where necessary to prevent a deleted identity from being silently recreated, record completed deletion work, maintain security, or comply with law. Deletion may take additional time to propagate through provider systems and limited backup-retention cycles, unless preservation is required by law.

Your choices and rights

Depending on where you live, you may have rights to request access to, correction of, deletion of, restriction of, or a portable copy of your personal information, and to object to or withdraw consent for certain processing.

You can:

Withdrawing permission may prevent the related feature from working. Account deletion does not cancel an Apple subscription. You can manage or cancel an Apple subscription in your Apple Account subscription settings.

Legal bases for processing in the UK and EEA

Where UK or EEA data-protection law applies, we rely on one or more of the following legal bases:

International data transfers

Our service providers may process information in the United Kingdom, European Economic Area, United States, or other countries where they or their subprocessors operate. Where required, we and our providers use recognized transfer mechanisms and safeguards for international transfers.

Security

We use technical and organizational measures designed to protect information, including encrypted network connections, access controls, row-level database authorization, platform data-protection features, restricted server credentials, content-minimized logging, and in-app account deletion. No system can guarantee absolute security.

Children's privacy

Cleverly Lingo is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, contact support@cleverlylingo.com so we can investigate and delete it as appropriate.

Changes to this Policy

We may update this Policy when the Service, our providers, or legal requirements change. We will change the "Last updated" date and provide additional notice when required. Material changes will apply prospectively unless the law permits or requires otherwise.

Contact us

The data controller responsible for Cleverly Lingo is:

Unity Bridge Solutions Ltd
Email: support@cleverlylingo.com

If you are in the UK or EEA, you may also complain to your local data-protection authority. We encourage you to contact us first so we can try to resolve your concern.

Service-provider privacy information