Fluo Privacy Policy

Last Updated: October 16, 2026

1. Introduction

Welcome to Fluo, a product of Project Quik Private Limited (“Project Quik,”, "we," "us," or "our"). Fluo is an adaptive, AI-powered language learning platform that provides personalized curricula, text and voice conversation practice with an AI tutor, spaced-repetition review, and progress tracking (the "Service"). This Privacy Policy explains what information we collect, how we use and share it, and the choices available to you.

By using Fluo, you agree to the collection and use of information as described in this policy. If you do not agree, please do not use the Service.

2. Information We Collect

2.1 Basic Information You Provide to Us

Account Information: Name, email address, date of birth and social sign-in details. Date of birth is processed ephemerally for compliance with applicable local laws and only your birth year is stored in our servers.
Payment and Billing Information: Billing name, address, and payment details, processed through third-party payment processors and app-store billing systems (e.g., Apple App Store, Google Play). We do not store full payment card numbers on our own servers.
Learning Goals & Preferences: The goals, scenarios, or contexts you provide to generate a personalized curriculum (e.g., "business negotiations in Tokyo," "everyday conversation for travel").
Referral Information: Email addresses or contact details you submit to invite friends through our referral program.
Communications: Information you provide when contacting support or responding to surveys.

2.2 Learning Content and Interaction Data

Because Fluo's core functionality is built around an AI tutor and a persistent learning profile, we collect and generate the following as you use the Service:

Chat Transcripts: Text conversations between you and the AI tutor during text-based lessons.
Voice Recordings and Audio Data: Audio captured during voice sessions and real-time persona calls, used to provide pronunciation feedback, transcription, and conversational responses. Audio is processed to generate a response and is not used for any purpose other than providing and improving the Service, as described in Section 5.
Text-to-Speech (TTS) Data: Generated audio responses from the AI tutor, cached to improve performance.
Friction Log / Error Data: Records of recurring mistakes, grammar patterns, and areas of difficulty, used to personalize future lessons and reviews.
Memory Profile: A cumulative, long-term learning profile summarizing your progress, vocabulary history, and interaction patterns across sessions.
Notebook Content: Notes, phrases, and edits you or the AI generate and save within your personal lesson notebook.
Progress & Gamification Data: XP, streaks, levels, completed lessons, and quiz/recap results.
Shared & Social Data: If you use curriculum-sharing or collaborative features, the curricula, progress, or activity you choose to share with friends, and information about friends who join through your referral.

2.3 Information Collected Automatically

Usage Data: Features used, session frequency and duration, lesson completion, and navigation within the app.
Device Information: Device type, operating system, browser type, unique device identifiers, and mobile network information.
Log Data: IP address, access times, crash reports, and diagnostic data.
Cookies, SDKs, and Similar Technologies: Used to recognize you, remember preferences, measure usage, and — for users on the ad-supported Free Plan — to serve and measure advertising (see Section 8).

2.4 Information from Third Parties

We may receive information from payment processors, analytics providers, advertising partners, sign-in providers (e.g., Google or Apple sign-in), and, where applicable, partner organizations (e.g., a university or travel partner through which you obtained a promotional subscription).

3. How We Use Your Information

We use the information we collect to:

Provide and operate core Service features, including generating personalized curricula, conducting text and voice tutoring sessions, and managing your learning profile
Personalize lesson content, pacing, and review scheduling based on your goals and recorded friction points
Process transactions, subscriptions, and one-time purchases (e.g., session boosters)
Operate gamification features (XP, streaks, levels) and, where applicable, social and referral features
Serve advertising to users on the Free Plan and measure ad performance
Communicate with you, including support, service updates, and (where permitted) marketing
Monitor, secure, and improve the Service, including troubleshooting and fraud prevention
Comply with legal obligations and enforce our terms

4. Legal Bases for Processing (EEA/UK Users)

Where the GDPR applies, we rely on the following legal bases:

Contractual necessity — to deliver the tutoring, curriculum, and account features you've signed up for
Legitimate interests — for analytics, service security, and improving the AI tutor's personalization
Consent — for voice recording processing where required, optional marketing communications, and non-essential/advertising cookies
Legal obligation — to comply with applicable law

5. How We Share Your Information

We do not sell your personal information. We share information in the following circumstances:

AI Processing Subprocessors: Fluo uses Google's Gemini family of AI models (including the Gemini Live API for voice and Gemini TTS for generated speech) to power the tutoring, curriculum generation, and conversational features. This means your chat transcripts, voice audio, and related learning data are transmitted to and processed by Google as our service provider, subject to contractual data protection terms. We do not permit this data to be used to train Google's general-purpose models.
Other Service Providers: Payment processors, cloud hosting (Google Cloud), customer support tools, and analytics providers, all under confidentiality and data-protection obligations.
Advertising Partners: If you use the ad-supported Free Plan, we share limited device and usage information with advertising partners to serve and measure ads, subject to your consent choices and applicable law.

Advertising Partners: If you use the ad-supported Free Plan, we use Google AdMob to serve and measure ads within the app. AdMob may collect and use device identifiers (such as your device's advertising ID), IP address, and ad interaction data to serve ads and measure their performance. Google may also place cookies or use similar technologies as part of this process. You can learn more about how Google collects and uses this data at Google's Privacy Policy and How Google uses information from sites or apps that use our services. You can opt out of personalized advertising through your device's ad settings or via Google's Ads Settings. For users in the EEA, the UK, and certain US states with relevant privacy regulations, we request consent for ad-related data use and cookies in accordance with applicable law before ads are personalized.

Friends and Collaborators: If you use curriculum-sharing, group activities, or referral features, certain progress or activity information is visible to the friends you choose to share it with.
Partner Organizations: Where you access Fluo through a partner promotion (e.g., a university or travel company offering a discounted subscription), we may share limited enrollment or eligibility information with that partner.
Business Transfers: In connection with a merger, acquisition, or sale of assets.
Legal Requirements: When required by law, legal process, or to protect the rights, safety, or property of Project Quik, our users, or others.

6. International Data Transfers

Fluo and its AI processing subprocessors (including Google) operate globally, and your information — including voice and chat data — may be transferred to and processed in countries other than your own, including the United States and Singapore. Where required, we use appropriate safeguards such as Standard Contractual Clauses.

7. Data Retention

Because Fluo's core value depends on a persistent memory profile, friction log, and notebook, this learning data is generally retained for as long as your account is active so that your curriculum and tutoring remain personalized and cumulative. Older interaction history may be summarized ("rolled up") into condensed form over time rather than deleted outright. You may request deletion of your account and associated learning data at any time (see Section 9); we will delete or anonymize data that is no longer necessary once a deletion request is processed, except where retention is required by law.

Raw voice audio is generally retained only as long as needed to generate a response and support quality/troubleshooting, and is not indefinitely stored in identifiable form beyond what is needed for the Service, unless you have enabled a feature (such as a saved voice note) that requires longer storage.

In-App Purchase and Subscription Records: Records of in-app purchase transactions (including boosters and subscription plans) and associated usage data are retained indefinitely for anti-fraud, billing dispute, and audit purposes, even after account deletion. This data is retained separately from your learning profile and is not used to personalize tutoring content.

Promotion Records: When you redeem the student offer, or join through a friend's referral, we keep a keyed cryptographic hash of the email address involved — never the address itself — so that each address can claim each offer only once. This hash is retained after account deletion for that purpose only and cannot be used to recover your email address.

8. Cookies, Advertising, and Tracking Technologies

We use cookies and similar technologies to:

Keep you logged in and remember preferences
Analyze usage of the Service
On the Free Plan, serve and measure in-app advertising

You can manage cookie and ad-tracking preferences through your device or browser settings, and where required by law (e.g., in the EEA/UK), we will request consent before setting non-essential or advertising cookies. Upgrading to the Pro Plan removes ad-supported tracking associated with the Free Plan's advertising.

9. Your Privacy Rights

9.1 For Users in the EEA/UK (GDPR)

You have the right to access, correct, delete, restrict or object to processing of, and port your personal data, and to withdraw consent at any time. You may also lodge a complaint with your local data protection authority.

9.2 For California Residents (CCPA/CPRA)

You have the right to know what personal information is collected and shared, request deletion or correction, opt out of the sale or sharing of personal information for cross-context behavioral advertising, and not be discriminated against for exercising these rights. We do not sell personal information; if you are on the ad-supported Free Plan, certain data shared with advertising partners may constitute "sharing" under the CPRA, and you may opt out via your account or device settings.

9.3 For All Users

You can typically access, edit, or delete much of your account and learning data (including notebook entries) directly within app settings, or by contacting us using the information in Section 13. Deleting your account will remove your memory profile, friction log, and notebooks, subject to Section 7.

10. Data Security

We implement technical and organizational safeguards — including encryption in transit and access controls — to protect your information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Children's Privacy

Fluo is designed for young adults and is not directed to children under 16. We do not knowingly collect personal information from children under 16, including through voice or chat features. If we become aware that we have done so, we will delete it promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy in the app and on our website and updating the "Last Updated" date above. Continued use of the Service after changes take effect constitutes acceptance of the revised policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

Email: contact@projectquik.co