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Privacy Policy

Last updated: May 3, 2026

1. Who We Are

LiveLingo is a product of Lunana Global Inc. ("we", "us", "our"), a Delaware corporation. We act as the data controller for the personal information described in this Privacy Policy. LiveLingo is a real-time translation app that provides live recording and transcription, photo translation, sign-mode translated displays, and translated phone calls (PSTN). This Privacy Policy explains how we collect, use, store, and protect your information when you use our website at livelingo.io and our mobile applications (collectively, the "Service").

2. Information We Collect

We collect the following categories of information:

  • Account information: When you sign up, we collect your email address, phone number, or Google account information used for authentication, an optional display name, and an optional profile photo.
  • Phone verification data: Before placing a translated phone call, you must verify your phone number by SMS one-time passcode (delivered via Twilio Verify). We store the verified E.164 phone number, the destination country, the first and most recent verification timestamps, the originating device identifier, and your subscription identifier. This data is used to gate outbound calling, deter fraud and abuse, enforce sanctions and quota, and skip re-verification on devices you have previously used.
  • Microphone audio: When you use live translation, sign mode (voice path), or translated phone calls, your microphone audio is streamed to our servers and to our speech-recognition provider for real-time processing. For translated phone calls, audio is also routed by Twilio (Programmable Voice and Media Streams). Audio is processed transiently and is not retained after the call or session ends. We do not store raw audio recordings.
  • Image data: When you use photo translation, the captured or selected JPEG is uploaded to our servers and processed by Google Gemini (and, if Gemini is unavailable, by Google Vision for optical character recognition combined with a fallback translation engine). Images are not retained server-side. Detected text and translations are stored only on your device.
  • Session data: We store transcripts and translations from your sessions so you can review them later. These include source text, translated text, speaker labels, and timestamps, and are associated with your account.
  • Call participant data: For translated phone calls, we store the recipient's phone number (E.164), the recipient name as you entered it, and the transcript of the recipient's translated speech generated during the call. These records are stored in your account, not the recipient's. See Section 9 for the recipient's rights as a data subject.
  • AI-generated content: Meeting memos, session summaries, and session titles generated by the Service are stored in your account.
  • Usage data: We collect session duration, language pairs used, subscription tier, and feature usage to operate and improve the Service. This includes any optional context you provide before a translation session (e.g. "doctor visit") and a small excerpt of the first few utterances, used to study how the context feature is used and how to improve translation quality. Excerpts are stored under the same protections as session data. For translated phone calls we also retain call metadata: source and destination country, duration, zone multiplier, success/failure status, and minute-credit consumption.
  • Analytics and advertising data: We use Google Analytics and Google Ads conversion tracking on our website, Firebase Analytics (Google Analytics for Firebase) in our iOS app, the Meta Pixel on our website, and the Facebook SDK in our iOS app. These tools may collect anonymized browsing data, page views, referral sources, device identifiers, app events (such as sign-up, start recording, and subscription purchase), and device information through cookies, SDKs, and similar technologies. The categories of data declared on the iOS App Store are listed in our app's Privacy Manifest (PrivacyInfo.xcprivacy) and on the App Store privacy label.
  • Payment information: Payment processing is handled by Stripe (web), RevenueCat with Apple App Store and Google Play (mobile). We do not store your credit card details. See Stripe's Privacy Policy.

3. Legal Basis for Processing (GDPR / UK GDPR)

If you are in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal data under the following legal bases:

  • Contract performance (Art. 6(1)(b)): processing your audio, storing transcripts, gating phone-verified calling, and managing your account are necessary to provide the Service you signed up for.
  • Consent (Art. 6(1)(a) and Art. 9(2)(a)): we process your microphone audio, your photos, and any health-related, legal, or other special-category content you choose to translate based on your explicit consent when you start a session, capture a photo, or place a call. You can withdraw consent at any time by stopping the session, deleting the photo, or ending the call.
  • Legitimate interest (Art. 6(1)(f)): we use analytics and abuse-prevention data to improve the Service, detect abuse, prevent toll fraud, and ensure security. We balance our interests against your rights and use anonymized data where possible.
  • Vital interests (Art. 6(1)(d)): in the event of suspected illegal activity threatening life or safety (e.g. fraudulent emergency reporting), we may retain and disclose data necessary to protect those interests.
  • Legal obligation (Art. 6(1)(c)): we retain certain payment, tax, and abuse records as required by applicable law.

4. How We Use Your Information

  • To provide, maintain, and improve our translation service
  • To authenticate your identity and manage your account
  • To gate outbound translated calling, prevent toll fraud and abuse, and enforce sanctions and quota
  • To store your session history, transcripts, photo translations, and meeting memos
  • To process payments and manage your subscription
  • To monitor usage for tier-based billing and abuse prevention
  • To generate session titles and meeting summaries using AI
  • To communicate with you about your account, service updates, or security alerts
  • To analyze aggregate usage patterns and improve service quality

We do not use your audio, transcripts, translations, or photos to train AI models. Your content is processed solely to deliver the Service and is not licensed, sold, or used for model training by us or our subprocessors under our agreements with them.

5. Data Storage and Security

Your account data, sessions, transcripts, memos, and verified-phone records are stored in Supabase (hosted on Amazon Web Services in the United States) with row-level security policies ensuring you can only access your own data. All data is transmitted over encrypted connections (TLS 1.2+ for HTTPS and WSS). Data at rest is encrypted with AES-256.

For translated phone calls, audio transits Twilio's carrier infrastructure in transit between your device, our server, and the called party's carrier. Twilio retains call signaling logs as required by carrier and regulatory rules; we coordinate deletion requests with Twilio under our data processing agreement.

We take reasonable technical and organizational measures to protect your information, including encryption at rest and in transit, role-based access controls, multi-factor authentication on administrative access, and regular security reviews. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

6. Third-Party Services and Subprocessors

We use the following third-party service providers (subprocessors) to operate the Service. Your data may be shared with these providers as necessary for service delivery. The current canonical list is published at livelingo.io/subprocessors.

  • Twilio (United States): PSTN call routing (Programmable Voice + Media Streams) and SMS one-time-passcode delivery (Twilio Verify) for phone verification. Receives outbound call audio in transit and the dialed phone number. See Twilio's Privacy Notice.
  • Speech-recognition and synthesis provider (United States): real-time speech-to-text and text-to-speech. Receives streamed audio for transcription and receives translated text for synthesis. Audio is processed transiently.
  • Google Gemini (United States): Translation, summarization, and image OCR. Receives transcribed text and uploaded photos for processing per Google's API Terms. We use Google's zero-data-retention configuration where available.
  • Google Vision (United States): Fallback OCR for photo translation when Gemini is unavailable.
  • LLM translation provider (United States): additional LLM-based translation, context expansion, and batch image translation. Receives transcribed or recognized text for translation.
  • LiveKit (United States): WebRTC infrastructure for live shared translation sessions, where two devices may join the same room by code to translate an in-person or remote conversation. LiveKit is not used for the PSTN translated-call feature, which routes through Twilio.
  • Supabase (United States, on AWS): Authentication, database, and storage hosting.
  • Stripe (United States): Payment processing for web subscriptions.
  • RevenueCat (United States): Subscription management for mobile in-app purchases (Apple App Store and Google Play).
  • Vercel (United States): Website hosting.
  • Google Analytics, Firebase Analytics, and Google Ads (United States): Web and mobile analytics and conversion tracking.
  • Meta Platforms (United States): Meta Pixel on our website and the Facebook SDK in our iOS app, used for ad measurement and audience analytics.

Each subprocessor operates under its own privacy policy and a data processing agreement with us. We will provide at least 30 days' advance notice before adding a new subprocessor that materially changes the nature of processing; for business customers under our DPA, we provide an objection mechanism.

7. Cookies and Tracking Technologies

We use essential cookies (for authentication and session management), analytics cookies (Google Analytics / Firebase Analytics), and advertising cookies (Google Ads conversion tracking and Meta Pixel). For the full list with retention, purposes, and opt-out instructions, see our Cookie Policy.

Global Privacy Control (GPC): we honor GPC browser signals as an opt-out request for the "sale" or "sharing" of personal information under the California Privacy Rights Act (CPRA) and analogous U.S. state laws.

8. Data Retention

  • Audio data: processed in real time; not retained after the session or call ends.
  • Image data: not retained server-side; detected text and translations are stored only on your device.
  • Transcripts and memos: retained as long as your account is active. You can delete individual sessions from within the app at any time.
  • Verified phone records: retained until you delete your account, revoke verification, or request deletion. Used to skip re-verification on a previously used device and to deter fraud.
  • Twilio call signaling logs: retained by Twilio per its standard retention schedule (typically up to thirteen months); we coordinate deletion requests with Twilio under our data processing agreement.
  • Account data: retained until you delete your account. Upon account deletion, all associated data (sessions, transcripts, memos, verified-phone records, and related subprocessor records) is permanently removed within 30 days, subject to legal-retention obligations.
  • Payment records: retained as required by applicable tax and financial regulations (typically 7 years).
  • Analytics data: Google Analytics data is retained for 26 months by default; Meta Pixel retention follows Meta's defaults.

9. Your Rights

Depending on your location, you may have the following rights:

  • Access: request a copy of the personal data we hold about you
  • Correction: request correction of inaccurate data
  • Deletion: request deletion of your personal data
  • Portability: request your data in a machine-readable format (JSON)
  • Restriction: request that we limit processing of your data
  • Objection: object to processing based on legitimate interest
  • Withdraw consent: withdraw consent at any time (without affecting lawfulness of prior processing)
  • Lodge a complaint: if you are in the EEA or UK, you have the right to lodge a complaint with your local data protection supervisory authority

To exercise any of these rights, contact us at hello@livelingo.io. We will respond within 30 days (or as required by applicable law). You may designate an authorized agent to submit requests on your behalf; the agent must provide written authorization signed by you.

Recipients of translated phone calls: if you are not a LiveLingo user but believe a transcript or translation involving your voice has been processed by the Service in connection with a call placed by one of our users, you may request access or deletion by contacting hello@livelingo.io with the subject line "Recipient Data Request." Because we do not have an account relationship with non-user participants, we will work with the originating user to fulfill verifiable requests where required by applicable law.

10. California Residents (CCPA / CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

  • Right to Know: request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and any third parties to whom we disclose it.
  • Right to Delete: request deletion of your personal information, subject to certain exceptions.
  • Right to Correct: request correction of inaccurate personal information.
  • Right to Opt-Out of Sale or Sharing: we do not sell your personal information for monetary consideration. To the extent that our use of advertising cookies (Google Ads conversion, Meta Pixel) constitutes "sharing" for cross-context behavioral advertising under the CPRA, you may opt out by enabling Global Privacy Control in your browser or by emailing hello@livelingo.io with the subject line "Do Not Sell or Share."
  • Right to Limit Use of Sensitive Personal Information: voice recordings and transcripts qualify as Sensitive Personal Information under California Civil Code §1798.140(ae)(2)(B). We use Sensitive Personal Information only as necessary to provide the Service you requested and for short-term, transient processing. To request that we further limit our use of your Sensitive Personal Information, email hello@livelingo.io with the subject line "Limit Sensitive PI."
  • Non-Discrimination: we will not discriminate against you for exercising your privacy rights.

Categories collected (CPRA): identifiers (email, phone, device ID, account ID); customer-records information (name, payment information held by our payment processors); commercial information (subscription tier, purchase history); internet/electronic activity (app and web usage); audio (microphone input, processed transiently); geolocation (coarse, country-level, derived from phone number for translated calls); inferences (none). See Section 6 for the categories of third parties to whom we disclose information.

11. Other U.S. State Privacy Rights

Depending on your state of residence, you may have additional privacy rights under state law. We extend the rights described in Section 9 to residents of states that have enacted comprehensive privacy laws, including Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), Iowa (ICDPA), Tennessee (TIPA), Indiana (ICDPA), Delaware (DPDPA), New Hampshire (NHDPA), New Jersey (NJDPA), Maryland (MODPA), Minnesota (MCDPA), and Rhode Island (RIDTPPA), and to Nevada residents under SB 220.

To exercise these rights, contact us at hello@livelingo.io with your state of residence and the right you wish to exercise.

Washington My Health My Data Act (and analogous laws in Nevada and Connecticut): if you use the Service to translate health-related conversations or documents, the audio, transcripts, and translations we process may constitute "consumer health data." We obtain your separate, distinct consent for this processing through the in-app context picker and consent screens, do not sell consumer health data, and do not geofence healthcare facilities. To withdraw consent, end the session and delete the associated transcript from your account.

12. Children's Privacy

Our Service is not directed to children under 13 (or under 16 in the EEA, or such other minimum age established by your jurisdiction). We do not knowingly collect personal information from children under these ages. If we become aware that we have collected personal information from a child without verifiable parental consent, we will take steps to delete it promptly. Parents or guardians who believe their child has provided personal information to us may contact hello@livelingo.io.

13. Biometric Identifier Disclaimer

LiveLingo does not generate, store, or possess "biometric identifiers" or "biometric information" as those terms are defined under the Illinois Biometric Information Privacy Act (740 ILCS 14), the California Consumer Privacy Act's definition of biometric information, the Texas Capture or Use of Biometric Identifier Act, or the European Union's GDPR Art. 9. Our speech-recognition provider processes raw audio for the limited purpose of transcription and synthesis, and does not retain voiceprints, voice embeddings, or other unique mathematical models of an individual's voice tied to identity.

14. AI Transparency

LiveLingo uses artificial intelligence and machine learning to perform speech recognition, machine translation, optical character recognition, and synthesized speech generation. Our use of AI complies with the transparency obligations of the European Union Artificial Intelligence Act (Regulation (EU) 2024/1689), California's AI Transparency Act (SB 942), California's Generative AI Training Data Transparency Act (AB 2013), Utah's AI Policy Act, and analogous disclosure laws.

Synthetic audio in translated phone calls: during a translated phone call, the recipient hears a synthesized translation voice (text-to-speech output) speaking the translation, not the caller's own voice rendered in the target language. The call follows a consecutive- interpretation pattern: each speaker's words are translated and spoken aloud in turn, with pauses between turns. At the start of every outbound translated call, the recipient hears a brief automated announcement in their language identifying the caller by name and informing them that the call is being translated. The announcement is informational only; it does not by itself collect or document the recipient's consent. The user who initiates the call is solely responsible for obtaining any further consent required by applicable law from each participant. See Sections 5 and 9 of our Terms of Service for the user's consent obligations.

Limits of AI: AI-generated translations, transcripts, and summaries may be inaccurate, incomplete, biased, or otherwise wrong. Do not rely on the Service for medical, legal, financial, immigration, or other consequential decisions. See our Terms of Service for the full disclaimer.

15. International Data Transfers

If you are located outside the United States, your data is transferred to and processed in the United States and other countries where our subprocessors operate. We rely on the following lawful transfer mechanisms:

  • EU-U.S. Data Privacy Framework (DPF), and the UK and Swiss extensions: for transfers to subprocessors that are certified under the framework (including Google Cloud, Stripe, and Meta Platforms).
  • Standard Contractual Clauses (SCCs): executed with subprocessors that are not DPF-certified, supplemented by the UK International Data Transfer Addendum (IDTA) for UK transfers.
  • Your explicit consent: where SCCs or DPF do not apply, we rely on your explicit consent to transfer data to the United States, with full awareness of the differences between U.S. and EEA/UK/Swiss data-protection regimes.

16. Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users without undue delay (and within 72 hours where required by GDPR Art. 33–34) and the relevant supervisory authority as required by applicable law (including U.S. state breach-notification statutes such as California SB 1386 and equivalents).

17. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice within the Service at least 30 days before they take effect. The "Last updated" date at the top indicates when the policy was last revised. Your continued use of the Service after the effective date of a change constitutes acceptance of the revised policy.

18. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, contact us at hello@livelingo.io.

Lunana Global Inc.
d/b/a LiveLingo
555 Burrard St
Vancouver, BC V7X 1M5
Canada
Data Protection Contact: hello@livelingo.io

EU/EEA Representative (GDPR Art. 27): We are in the process of appointing an authorized representative within the European Union as required by Article 27 of the GDPR. Until that appointment is complete, EU/EEA residents with data-protection inquiries may contact eu@livelingo.io and we will route your request appropriately.

UK Representative (UK GDPR Art. 27): We are in the process of appointing an authorized representative within the United Kingdom. Until that appointment is complete, UK residents with data-protection inquiries may contact eu@livelingo.io.

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