Privacy Policy

Last Updated: June 5, 2026

Your Privacy Matters to Us

At Stella AI, we are committed to protecting your privacy and handling your data responsibly. This Privacy Policy explains what data we collect, how we collect it, how we use it, who we share it with (including third-party AI services), and how we protect it. By using Stella AI, you agree to the practices described here.

We take your trust seriously. We only collect and share the minimum data necessary for the app to function, and we always ask for your explicit permission before sending any personal data to third-party services.

1. Data We Collect

We collect the following types of data to provide language learning features:

• Personal Information and Contact Information
  Email Account or Apple ID, Language and proficiency level, E-mail address.
  How collected: Voluntarily provided by users for self-reported language proficiency information.
  Purpose: Create Stella AI subscription, form a history of your exercise and language practice history and communicate with you through or about Stella AI, updates or your requests.
• In-app learning progress
  Completed lessons, exercises, scores, and performance metrics.
  How collected: Automatically within the app.
  Purpose: Personalize your learning path, track improvement, and improve app features.
• Voice/audio input
  When you speak into the microphone for speaking practice, pronunciation exercises, or conversation mode.
  How collected: Via device microphone (with your permission via iOS microphone prompt).
  Purpose: To enable speech recognition, pronunciation scoring, and interactive AI conversation. For speaking practice features, voice input is processed in real time to enable conversational functionality with prior consent to microphone access. Recordings are stored only on the user’s own device for personal playback or learning purposes; we do not access, transmit, or retain voice data beyond the real-time processing needed to provide the service. You may disable microphone access anytime by your device settings.
• Text input
  Messages or text you type when chatting with AI or using translation features.
  How collected: Directly from your input in the app.
  Purpose: To power AI conversation, translation, and text-to-speech playback.
• Technical Data
  IP address, logs, device type and name, operating system, type and date of subscription.
  How collected: Automatically when you access and use the app and related services.
  Purpose: Ensure the functionality of the app, crash and error detection, conduct technical analysis, carry out the activity in accordance with the legislation and technical data security.
• Customer Transaction Data
  Subscription plan, billing cycle.
  How collected: Automatically when you purchase a subscription plan for the app.
  Purpose: Determine the customer's subscription plan, provide and improve the services and membership plans, to follow and provide purchases. Note: No credit card information is collected by us; payments are processed through official third-party payment channels.
  Apple In-App Purchase (iOS): If you subscribe on an Apple device, payment and billing are handled entirely by Apple. We receive subscription status and related transaction metadata from Apple to provide your membership. We do not receive your credit card or Apple Pay details. Refund requests must be submitted to Apple. By subscribing via the App Store, you agree that consumption and subscription-related data may be reported to Apple as described in Section 3 of this Policy.
• Marketing and Analytics Data
  Analytics data (session duration, feature interaction), user preferences (language, theme), identifiers, interaction within the app, marketing emails or ads.
  How collected: Automatically through app usage behavior and with your explicit permission for relevant data collection.
  Purpose: Deliver and personalize advertising and in-app content, run promotional campaigns, measure marketing performance, and gather insights to improve our products and features. We may send push notifications for marketing purposes and use identifiers for advertising (IDFA on iOS, Firebase, Appsflyer) analytics upon your permission. You can withdraw your consent for such data collection and use at any time.
• The Information Disclosed by Users
  Within the scope of the data minimization principle adopted in accordance with the GDPR, Stella AI takes care not to process any data other than the above and is unnecessary for the application. Data that is not included in the app but shared through contact, upload or other means is deemed to be disclosed by users. These are also protected within the scope of relevant legislation and adequate data protection measures.

We do not collect your phone number, location, photos, contacts, or any other sensitive personal identifiers unless you voluntarily provide them (e.g. in a support message).

Age Restriction

Stella AI has an age restriction as it is not intended for Users under the age of 13. If you are under 13 years of age, please do not use or access the App at any time or in any manner. By using the App, you affirm that you are over the age of 13.

Parent/Guardian Use

Parents and guardians are strongly encouraged to notify Stella AI if their children under the age of 13 are using the app. Please note that Stella AI does not collect information from children under the age of 13 in accordance with the Children's Online Privacy Protection Act ("COPPA") as indicated in this Privacy Policy and the Terms.

Parents and legal guardians are welcome to use the app together with their children to support and improve their language skills. However, we strongly recommend that parents actively supervise their children's use of the app at all times to ensure appropriate usage and to guide their learning experience.

2. Third-Party AI and Service Providers – What Data Is Shared and Why

Stella AI uses third-party AI and speech services to deliver core functionality. We never send data to these services without your explicit consent.

Before any data is shared with a third-party AI service, the app will show a clear in-app consent screen explaining:

• Exactly what data will be sent (e.g. your voice recording or typed text)
• Who it is sent to (specific provider name)
• Why it is needed (e.g. to transcribe speech, generate responses, score pronunciation, or convert text to voice)

You must actively agree (e.g. tap “Allow” or “Continue”) before any data is transmitted. You can withdraw consent at any time by disabling the relevant feature in Settings.

Third-Party AI Services for Core Language Learning Functions

a) OpenAI (openai.com)

• Data sent: Audio recordings (for speech-to-text), text messages/prompts (for AI chat responses), text outputs (for text-to-text translation and text-to-speech input).
• Purposes:
  • Speech-to-text (ASR): Convert your spoken words to text.
  • AI conversation: Generate natural language responses for interactive language practice.
  • Text translation: Translate English to your local language (and vice versa).
  • Text-to-speech input: Prepare text to be converted to spoken audio.
• OpenAI’s privacy practices: https://openai.com/policies/privacy-policy
• OpenAI does not use your data to train models without explicit permission (we use their API in a mode that prevents training on user data). We apply appropriate technical and organizational safeguards to protect data during this process.

b) Microsoft Azure Cognitive Services (Speech and Translator APIs)

• Data sent: Text strings.
• Purposes: Text translation (English ↔ local language).
• Microsoft’s privacy practices: https://privacy.microsoft.com/en-us/privacystatement
• Microsoft provides enterprise-level data protection and does not use your data for training their models. We apply appropriate technical and organizational safeguards to protect data during this process.

c) SpeechSuper (speechsuper.com)

• Data sent: Audio recordings of your spoken pronunciation.
• Purposes: Analyze and score your pronunciation accuracy during speaking exercises.
• SpeechSuper’s privacy practices: Refer to their official privacy policy on their website.
• Data is processed only for scoring and not stored long-term by us. We apply appropriate technical and organizational safeguards to protect data during this process.

Other Third-Party Service Providers

Your personal data will not be sold, traded, or otherwise transferred to third parties for commercial purposes. Your data may be transferred to the following third-party service providers only for the purpose of providing and improving our services, and we ensure that these providers adopt adequate data protection measures:

(a) Service Providers: We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and cloud services. This includes cloud providers (Google, CloudFlare), data analytics providers (Google, Appsflyer, Firebase). Please note that payments are processed through Google and Apple, and we do not access, store or share any credit card information.

(b) Business and Communication Partners: We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services. This includes service providers (Intercom, Firebase).

(c) Law Enforcement and Public Authorities: We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

(d) Apple Inc. (App Store / In-App Purchase): We may share subscription status, transaction identifiers, product identifiers, purchase and renewal dates, and consumption or usage data related to in-app purchases with Apple as required by Apple for billing support, fraud prevention, subscription management, and refund evaluation. Payments and refunds for iOS subscriptions are governed by Apple’s terms. Apple’s privacy practices: https://www.apple.com/legal/privacy/

Anonymized Data Sharing and Use

We may use anonymized data for analytical purposes and share such data with third-party service providers if needed. Anonymized data is processed in such a way that it can no longer be attributed to a specific individual, ensuring your privacy is maintained.

3. Apple In-App Subscriptions, Refunds, and Consumption Data

If you subscribe to Stella AI on iOS, your subscription is processed entirely through Apple In-App Purchase. We do not collect, store, or process your payment card or Apple Pay credentials. Apple handles billing, renewal, cancellation, and payment receipts in accordance with Apple Media Services Terms and Conditions and Apple Privacy Policy.

Subscriptions and Billing

• Subscription plans, prices, billing cycles, free trials (if offered), and auto-renewal are displayed in the App Store and within the app before purchase.
• Your subscription renews automatically unless you cancel at least 24 hours before the end of the current period.
• You can manage or cancel your subscription at any time via Settings → [Your Name] → Subscriptions on your Apple device.
• We receive limited transaction information from Apple (such as subscription status, product identifier, purchase date, and renewal status) to activate and maintain your membership. We do not receive your full payment details.

Refunds

• Refund requests for Apple In-App Purchases must be submitted to Apple, not to Stella AI. Apple makes refund decisions at its sole discretion under its policies.
• You may request a refund through reportaproblem.apple.com or Apple Support.
• Stella AI cannot override Apple’s refund decisions or issue refunds for purchases made through the App Store.
• If you contact us about a refund, we may assist by explaining your subscription status, but the final determination rests with Apple.

Consumption Data Shared with Apple

To comply with Apple’s App Store requirements and to support subscription integrity, fraud prevention, and refund-related review, Stella AI may share certain consumption and usage data with Apple related to your in-app purchases and subscription, such as:

• Whether a subscription is active, expired, or in a trial period;
• Approximate usage of purchased features or content (e.g., whether digital services have been accessed or consumed);
• Information reasonably necessary for Apple to evaluate refund requests or subscription disputes under its policies.

By using Stella AI subscriptions on iOS, you acknowledge and agree that this consumption and transaction-related data may be reported to Apple as required or permitted by Apple’s platform rules and technical frameworks (including StoreKit and App Store Server APIs). This reporting is enabled by default for iOS subscribers as part of using Apple In-App Purchase. If you do not agree, you should not purchase or renew subscriptions through the App Store.

We share only the minimum data necessary for these purposes. Apple’s handling of such data is governed by Apple’s privacy policy and terms, not ours. For questions about how Apple uses this information, please refer to Apple’s documentation and privacy resources.

4. How We Protect Your Data

• All data transmission uses industry-standard encryption (HTTPS/TLS).
• We do not store raw audio files after processing unless necessary for your immediate session (and never permanently without consent).
• Third parties we share with are contractually bound to provide equivalent or better protection than required by applicable laws (including GDPR/CCPA where relevant).
• We do not sell your data or use it for advertising.
• Safety Measures: Personal data is processed within the company only by authorized personnel, in a way that is not publicly accessible, and verification or additional confidentiality declarations required in processing special data categories if available.
• Access Controls: Access to personal data is restricted to authorized personnel only, ensuring that only those who need to access your information can do so.
• Regular Security Audits: We conduct regular audits and assessments of our security practices to identify and address potential vulnerabilities.
• Data Minimization: We only collect and retain personal data that is necessary for the purposes specified in this Policy.
• Incident Response Plan: We have established an incident response plan to quickly address any potential data breaches or security incidents.

While we strive to maintain a secure digital environment, yet no digital environment can be fully secure, we encourage users to take their own precautions when accessing and using the app, including utilizing relevant antivirus software, implementing a secure firewall, accessing the service over a safe Wi-Fi connection, and ensuring that the device used to access the app is secure and up to date.

In the event of any potential data breach or security incident, users are encouraged to inform us immediately. We will analyze the situation to determine if there is a security problem and take necessary measures to mitigate any risks. Your security and privacy are our top priorities, and we are committed to maintaining adequate standards of data protection as required by relevant legislation.

5. Storage and Retention of Information

We are committed to ensuring that your personal data is stored securely and in compliance with applicable laws and regulations.

Retention of Personal Information

We may store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Data Destruction and Anonymization

When personal data is no longer necessary or the retention period has expired, we will either securely delete or destroy the data to prevent unauthorized access or retrieval, or we will anonymize the data. Anonymization involves processing the data in such a way that it can no longer be attributed to you, ensuring that it can be used for analytical or research purposes without compromising your privacy. Once data is anonymized, it is irreversibly altered and cannot be traced back to any individual.

6. Your Controls and Choices

• You can disable microphone access, AI chat, translation, or pronunciation scoring at any time in iOS Settings → Stella AI → Permissions.
• Deleting the app removes all local learning progress data.
• You may contact us to request deletion of any server-side data (if any exists).
• You can withdraw your consent for marketing and analytics data collection and push notifications for marketing purposes at any time through app settings or device settings.

Users may request the erasure of their personal data in line with GDPR requirements. Requests must be submitted to our support team via the official contact email along with the User ID for verification. Verified requests will be fulfilled within the legal period. Please note that this method is manual, so we recommend using “Delete Account” through settings for easier and quicker processing.

7. App Tracking Transparency (ATT) and IDFA

Our app does not use the Identifier for Advertisers (IDFA) for tracking or advertising purposes. If any future feature requires it, we will request permission via Apple’s ATT prompt and respect your choice.

8. Rights Under Applicable Privacy Laws

Rights Under GDPR

The General Data Protection Regulation No. 2016/679 (GDPR) establishes a comprehensive framework for the protection of personal data within the European Union and the European Economic Area. Under GDPR, users have the following rights regarding their personal data as data subjects:

1. Right to Access: Obtain confirmation and access to personal data being processed.

2. Right to Rectification: Request correction of inaccurate or incomplete data.

3. Right to Erasure: Request deletion of personal data under certain conditions.

4. Right to Restrict Processing: Request limitation of data processing in specific situations.

5. Right to Data Portability: Receive personal data in a machine-readable format and transfer it to another controller.

6. Right to Object: Object to the processing of personal data, especially for direct marketing.

7. Rights Related to Automated Decision-Making: Not to be subject to decisions based solely on automated processing, unless certain conditions apply.

To exercise these rights, users must send an email or petition clearly stating the right they wish to enforce, along with their name and accurate contact details. A response will be provided within the legal time period.

California Residents (CCPA Rights)

The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.

We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:

1. Right to Know and Access: You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.

2. Right to Equal Service: We will not discriminate against you if you exercise your privacy rights.

3. Right to Delete: You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.

4. Request that a business that sells a consumer's personal data, not sell the consumer's personal data (note: we do not sell the personal information of our users).

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us via the official contact email stated in this Policy.

9. Corporate Affiliates and Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Stella AI or any of its Corporate Affiliates. Please note that Corporate Affiliate means any person or entity which directly or indirectly controls, is controlled by or is under common control with Stella AI, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in features, services, or legal requirements. The updated version will be posted here with a new “Last Updated” date. Significant changes will be notified in-app. Users are encouraged to review this policy regularly to stay informed about how we protect their personal data and to understand their rights and responsibilities. Any updates will take effect immediately upon posting. If users do not agree with the amendments, they should discontinue using the app. Continued use of the app after such updates constitutes acceptance of the revised policy.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us at:

stellaai.support@hkbetensh.com

By using Stella AI, you acknowledge that you have read, understood, and agree to this Privacy Policy.

Thank you for choosing Stella AI as your language learning companion!