Privacy Policy

Last updated: September 1, 2026

Fluo Inc., a Delaware corporation at 13109 Paloma Drive, Orlando, FL 32837, United States ("Fluo," "we," "us," or "our"), is the controller of the personal data described in this Privacy Policy. This policy explains how we collect, use, disclose, and safeguard your information when you use the Fluo mobile and web applications, our website at fluolearning.com, and related services (the "Service").

1. Information We Collect

Account Information

  • Email address and, if you provide one, a display name (when you create an account)
  • Authentication data from third-party sign-in providers (Apple, Google), limited to your name and email
  • Your language settings (the language you are learning and the language you read in) and your AI-features choice

Learning Data

  • Vocabulary progress, spaced-repetition data, and learning statistics
  • Practice session history and performance
  • Text you submit for translation, and the translation history the app keeps for you
  • Questions you ask the AI tutor, and the answers, which are kept in your account's AI history

Video and Content Data

  • Videos you watch, playback progress, ratings, skips, and saves
  • Subtitle interactions (words tapped, translations viewed)
  • Reports you submit about a video or its subtitles, and related moderation records
  • Feedback posts, comments, and votes you make on the in-app feedback board; posts and comments are shown to other signed-in users together with your display name
  • Videos you add from your own device, if you use that feature, and the subtitles generated for them

Device and Usage Information

  • Device type, operating system, and app version
  • Screens you view in the app and features you use, and pages you visit on our website
  • On our website: clicks on page elements, the page or link that referred you, and campaign parameters in the link you arrived from
  • Error and crash diagnostics
  • Your IP address, and an approximate location (such as country or city) derived from it

We do not collect your precise location, contacts, photos (other than a video you choose to add), microphone audio, or advertising identifiers.

Information received by third-party video players

Most videos in Fluo play inside the official embedded player of the platform that hosts them, principally TikTok. When such a player loads, that platform receives your IP address and standard device and browser information and may set cookies, under its own privacy policy (for TikTok, see tiktok.com/legal/privacy-policy). Fluo does not send the platform your Fluo account details. We cannot control what a platform does with the information its player collects.

2. How We Use Your Information and Our Legal Bases

  • To provide the Service (performance of our contract with you): your account, learning data, video interactions, and the content you submit.
  • To personalize your learning (contract): our adaptive algorithm and spaced-repetition scheduling use your progress and interaction history.
  • AI features (your consent): personalized practice sentences, on-demand translations, and the AI tutor run only if you opt in; you can withdraw in Profile settings at any time.
  • Generating subtitles (contract, and our legitimate interest in operating the Service): audio and on-screen text from videos, including videos you add, are processed by speech-recognition and translation services.
  • Analytics and diagnostics (our legitimate interest in understanding and improving the Service, and your consent where the law requires it): usage events, device information, and error reports.
  • Communicating with you (contract, legitimate interest): account emails, support replies, and, if you asked for them, product updates.
  • Safety, moderation, and legal compliance (legitimate interest, legal obligation): handling reports, preventing abuse and fraud, responding to copyright notices, and keeping records the law requires.

We do not sell your personal information, and we do not use it for advertising or share it with advertisers.

3. Service Providers and Other Recipients

We use the following providers to operate Fluo. Each processes data on our behalf under a contract, except where noted.

  • Supabase — authentication and database hosting (United States)
  • Cloudflare — our API, storage and delivery of Fluo-hosted videos, thumbnails, and generated audio, and the website
  • Google Cloud Platform — audio extraction and speech-recognition processing for video subtitles
  • Google Gemini — AI text generation, translation, glossing, and search embeddings (AI features when you opt in; also subtitle processing)
  • OpenAI, xAI, and OpenRouter — additional AI model providers we may use for the same purposes; OpenRouter also provides speech recognition for some video audio
  • ElevenLabs — speech recognition for video audio and text-to-speech for study audio
  • MiniMax — text-to-speech for study audio
  • PostHog — product and website analytics and error diagnostics (United States)
  • RevenueCat — subscription management, using an anonymous account identifier
  • Apple and Google — sign-in and, for subscriptions, payment processing; they act as independent controllers under their own policies
  • TikTok and YouTube — providers of the embedded video players described in Section 1; they act as independent controllers under their own policies

Text you submit to AI features is sent to the AI provider only with the vocabulary and learning context needed to answer you. Your name, email, and account credentials are never sent to an AI provider. We use these providers through their business API services, whose terms restrict their use of the text to providing the response.

We may also disclose information when required by law, to respond to a valid legal process or a copyright notice, to protect the rights, safety, or property of Fluo, our users, or others, or in connection with a merger, acquisition, or sale of assets, in which case this policy continues to apply to your data.

4. Cookies and Similar Technologies

Our website uses a first-party analytics cookie and browser local storage, set by PostHog, to recognize your browser across visits and pages so we can measure how the site is used. This identifier lasts up to 12 months unless you clear it. We do not use advertising or cross-site tracking cookies. Session recording is switched off.

You can block or delete these cookies at any time through your browser settings; blocking them does not affect your ability to use the site. The mobile app does not use cookies; it stores an equivalent analytics identifier on your device, which is removed when you uninstall the app or delete your account. Embedded video players may set their own cookies, as described in Section 1.

5. Data Retention

  • Account and learning data: kept while your account is active. When you delete your account, we delete or anonymize your personal data within 30 days.
  • Translation history and AI tutor history: kept in your account until you delete the account.
  • Feedback posts and comments: kept for the community; on account deletion they are anonymized (your name and account link are removed).
  • Analytics: deleting your account also deletes your analytics profile and its events held by PostHog.
  • Videos you added: removed from the Service on account deletion.
  • Records we must keep: we retain limited information where required for security, fraud prevention, copyright-notice handling, or legal compliance, including creator agreement records (which include the accepting person's IP address and browser information) for as long as the related content or agreement is relevant.

6. Your Rights

Depending on where you live, you may have the following rights regarding your personal data:

  • Access — request a copy of the personal data we hold about you
  • Correction — request that we correct inaccurate or incomplete data; you can edit your display name and language settings in the app
  • Deletion — delete your account and data through the app's "Delete Account" feature, or via our account deletion page
  • Portability — request a machine-readable copy of your data
  • Objection and restriction — object to, or ask us to restrict, processing based on our legitimate interests
  • Withdraw consent — turn AI features off in Profile settings at any time; withdrawal does not affect processing that already happened
  • Complain — lodge a complaint with your local data-protection authority; in the United Kingdom that is the Information Commissioner's Office

To exercise any of these rights, contact us at [email protected] from the email address on your account. We respond within 30 days (45 days where U.S. state law allows), and we do not discriminate against you for exercising your rights. If we decline a request, you may appeal by replying to our response, and we will explain the outcome.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including encryption in transit (TLS), signed authentication tokens, row-level access controls in our database, and restricted administrative access. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Children's Privacy

Fluo is not intended for children under 13, or under the higher minimum age that applies in your country for consenting to online services. We do not knowingly collect personal information from children below that age. If we learn that we have collected personal data from such a child, we delete the account and its data promptly. If you believe a child has provided us with personal information, please contact us at [email protected].

9. International Data Transfers

Fluo is based in the United States, and our providers process data in the United States and other countries whose data protection laws may differ from those of your country. Where we transfer personal data from the European Economic Area, the United Kingdom, or Switzerland, we rely on providers that are certified under the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) or on standard contractual clauses approved by the European Commission and the UK, together with additional safeguards where appropriate. You can ask us for details of these safeguards.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will revise the "Last updated" date at the top of this page. If the changes are material, we will notify you through the app or by email before they take effect.

11. Contact Us

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

Fluo Inc.
13109 Paloma Drive
Orlando, FL 32837, United States
[email protected]