Privacy Policy

Kanata Labs LLC, a Wyoming limited liability company (“Kanata Labs,” “we,” “us”), operates Dicavo, including its website and app (the “Service”), and is responsible for the personal information described here. This is a launch draft that requires qualified legal review before public release. Privacy contact: support@dicavo.com.

Information we collect

• Account information: email address, account identifier, password hash, birth year and age/guardian-related information you provide, preferences, and consent choices.
• Learning content: recordings, transcripts, scores, practice history, saved expressions, imported materials, and free-form inputs you actively submit, such as essays, sentences, ideas, answers, and messages. Depending on the feature, submitted text and feedback may be saved as learning history even when both optional consent settings are off. Some inputs are processed without saving their raw text in ordinary history. This is separate from copying content for product improvement.
• Technical and security information: IP address, device/browser information, request logs, and abuse-prevention signals. Necessary authentication, security and local preference storage operate independently of optional analytics.
• Purchase and support information: when applicable, purchase identifiers, payment status, entitlements and communications you send to support. Payment credentials are handled by the checkout provider; they are not part of the improvement dataset.
• Optional usage analytics: only after a separate opt-in, PostHog receives limited events such as registration completion, email verification, practice start, scoring outcome and feedback entry. Only signed-in accounts whose registered age establishes that they are at least 18 can enable this setting. We use an account-based pseudonymous identifier; no new visitor analytics is collected. These are not fully anonymous. We do not send email addresses, recordings, transcripts, free-form inputs, payment contents or authentication credentials through these analytics events. We do not enable automatic capture or session recording.

The exclusions in the analytics notice apply to PostHog usage analytics. They do not mean that Dicavo never processes or stores submitted learning content. Allowing analytics does not enable the separate “Use my data to improve the product” setting.

Purposes and legal bases

We process account and necessary learning information to provide the features you request, assess pronunciation, generate text feedback and speech, synchronize learning history and manage purchases and support. Where GDPR or UK GDPR applies, our basis is performance of our contract with you to the extent that processing is objectively necessary for those services. Accepting a privacy policy is not blanket consent to optional processing.

Optional usage analytics and the separate use of learning content for product improvement rely on your respective consent. Either can be refused without losing normal learning features. We use limited information for security, fraud prevention and protection of legal claims on the basis of our legitimate interests where applicable, subject to your rights and a balancing assessment; statutory reporting and retention rely on the relevant legal obligation. We do not retrospectively replace withdrawn improvement consent with a different basis to keep using that content.

We do not sell personal information or share it for cross-context behavioral advertising. Learning scores and AI feedback assist practice; they are not decisions about employment, credit or legal eligibility. Avoid including other people’s personal information, passwords or sensitive personal information in learning submissions.

Service providers and international processing

We use Cloudflare for hosting, security, databases and object storage; Microsoft Azure for speech assessment and synthesis; DeepSeek for AI-generated text feedback; Resend for transactional email; and PostHog for optional usage analytics. Input needed to produce your requested assessment or feedback is sent to the relevant provider even when the improvement setting is off. Checkout providers identified when you purchase may process purchase and payment information under their own notices, including Dodo Payments or an applicable app store when that channel is offered.

Processing can occur outside your country, including in the United States and other countries used by these providers. Our configured Azure speech region and PostHog endpoint are in the United States. DeepSeek’s published privacy notice describes processing and storage in China; the applicable API arrangement and safeguards require separate verification. A US company address does not mean all data is processed only in the United States.

Using the Service or accepting this policy does not waive transfer protections or automatically authorize an international transfer. Where applicable law requires a transfer mechanism, it must be supported by an applicable adequacy decision or appropriate safeguards, such as properly implemented standard contractual clauses and necessary supplementary measures. Contact support@dicavo.com for information about recipients, destinations and applicable safeguards. This notice does not certify that a provider has a particular contractual or transfer arrangement.

Retention and deletion

Ordinary submitted learning text, including saved essays, sentences and messages, and related feedback may remain in your learning history while your account is active, until you delete the relevant record or your account, unless a shorter period applies. Turning off analytics or product improvement does not delete that ordinary history. You can request deletion through available in-app controls or our privacy contact.

Ordinary recordings are uploaded for assessment and cleared after successful processing; server recording playback is not provided. Failed or unfinished recordings and temporary assessment data are usable for at most one hour from upload, and retries do not extend that period. Expired inputs cannot be read or resumed. Background cleanup retries physical deletion if storage failures delay it. Separately consented improvement copies follow the shorter-of-purpose/90-day/withdrawal rule below.

Limited purchase, security, rights-request and consent audit information may need separate retention to meet legal obligations, establish compliance or resolve claims. Its retention must be tied to those purposes and applicable deadlines, not unlimited reuse of learning content. Copies in backups and service-provider systems must be addressed through the applicable deletion process. Contact us for the retention criteria applicable to your request.

Optional use of learning data to improve the product

“Use my data to improve the product” is a separate account setting, off by default. You must read the disclosure and manually confirm before enabling it. Registration, policy acceptance and usage analytics consent do not enable it. Your choice does not affect normal access to learning features. Only registered accounts established as at least 18 may enable it. Under-18 and unknown-age accounts remain off. Eligibility is based on registered birth year and age declarations, not independent identity verification; becoming eligible does not automatically turn either optional setting on.

While enabled, new submitted recordings, transcripts, practice scores, free-form text (including essays, sentences, ideas and messages), saved expressions and imported materials may be copied into a private improvement dataset for improving Dicavo through research, development, debugging, evaluation and AI/model training. Authorized developers may read the content or listen to recordings. This is separate from the data sent to PostHog. We do not copy account-password fields or checkout payment credentials into this dataset. Free-form content itself may contain identifying or sensitive information; avoid submitting secrets or sensitive information.

Each identifiable improvement copy is retained for at most 90 days from collection, and must be removed earlier when no longer necessary for that purpose or when you withdraw consent or delete your account. This is a maximum, not a claim that every record is needed for 90 days. Re-enabling does not restore revoked submissions or authorize backfilling earlier opted-out content.

Turn the setting off in Settings → Privacy at any time. Withdrawal stops new collection and ongoing use of previously consented identifiable improvement copies. Stored improvement text is scrubbed and recording copies are queued for deletion; failures are retried and pending deletion copies are excluded from authorized improvement use. Account deletion also withdraws this consent and starts this cleanup. Deleting one ordinary history record does not automatically identify and delete all separate copies; turn the setting off or contact us to request broader deletion.

Withdrawal does not make processing lawfully completed before withdrawal unlawful. Some earlier analyses or training may already have occurred, but models and training outputs are not automatically anonymous or exempt from privacy rights. We assess requests involving identifiable information in those outputs under applicable law; we do not promise that all prior technical effects can be reversed or use that limitation to waive your rights.

An internal audit trail records enabling and disabling, the account identifier, server timestamp, disclosure version and source of the change. Minimal consent evidence and deletion/replay-prevention metadata are handled separately from learning content and are limited to compliance, security and deletion purposes. The app displays only the current state and, while enabled, the current enablement time. Current consent evidence is kept while that grant is relied upon. Superseded or withdrawn consent evidence is normally deleted 365 days after retirement, subject to necessary documented legal holds with recorded expiry, or an approved earlier erasure request. Minimal replay-prevention decisions are retained while an active account may retry the corresponding submission; after account closure they are normally removed after 365 days once deletion dependencies are cleared. Pending recording-deletion manifests remain until storage deletion is confirmed. Audit evidence is not permission to keep training on withdrawn content.

Your rights and how to exercise them

Contact support@dicavo.com or use the available account controls for access, correction, export, deletion and withdrawal. You do not need an active account to contact us. We may request proportionate verification, used only to handle your request. We respond within applicable legal deadlines and explain lawful exceptions and any permitted extension. We do not penalize you for exercising privacy rights.

• EEA and UK: where the respective law applies, rights can include access, rectification, erasure, restriction, objection to processing based on legitimate interests, portability of eligible data and withdrawal of consent. GDPR/UK GDPR requests generally receive a response within one month, with a permitted extension explained within that initial period. You may complain to the competent supervisory authority, including the UK ICO.
• California and other US states: where applicable, rights may include knowing categories, sources, purposes and recipients; access, correction, deletion and applicable opt-outs. Covered California requests generally require a response within 45 days, subject to a notified lawful extension. Authorized agents may submit requests subject to verification. We do not sell or share information for cross-context behavioral advertising, including learning content; applicable sensitive-information rights remain available.
• Other regions: local laws may provide access, correction, consent withdrawal, deletion, portability or regulatory complaint rights. Examples include Canada, Australia, Singapore, Japan, Brazil and the Philippines. The applicable law, not the language of the interface, determines your rights. Contact us if your jurisdiction or request is not listed.

You may withdraw analytics consent through Settings → Privacy; this stops future optional sends, including unsent queued events. Requests already in flight cannot be reversed. Tracking is off for signed-out, under-18 or unknown-age accounts. An existing historical visitor reference may be retained locally for up to 365 days solely to help you request rights over older provider data; it does not resume tracking and is included in an email draft only when you choose the privacy-request action. To request deletion or restriction of analytics data already held by PostHog, contact us. Stopping future events alone does not resolve a request concerning previously collected personal information.

Children

The Service is not directed to children under 13. Do not create or use an account for a child under 13. Some countries require a higher age or valid parental authorization for consent-based online services; the local rule applies even if a general age gate allows registration. A checkbox is not itself proof of valid parental authorization. Optional usage analytics and learning-data improvement are restricted to adults aged 18 or over; we do not currently accept guardian-checkbox authorization for these optional uses. Parents or guardians may contact support@dicavo.com about a child’s information. When legally required authorization is missing, the relevant processing must stop and the information must be deleted as required by law.

Changes and contact

We update this policy and its date when practices change and provide additional notice where required. New optional purposes or expanded collection require the applicable fresh consent, rather than assuming policy acceptance authorizes them. Privacy requests: support@dicavo.com. Controller: Kanata Labs LLC, Wyoming, United States. Corporate website: kanatalabs.com.