Privacy Policy

Privacy Policy — English

1. Controller and contact

Provider and data controller: Decaseo di Magni Federico, a sole proprietorship owned by Federico Magni.
Business address: Via Geromina 10, 24047 Treviglio (BG), Italy.
VAT number: IT03808600161.
Email for support, withdrawal and privacy: info@fredspeak.com. You can also use our contact page.

This notice explains FredSpeak’s current processing under the GDPR and applicable Italian privacy law. Reading it or browsing is not blanket consent. Use the contacts above for data rights.

2. Account, subscription and payments

We process account ID, username, email, password hash, preferences, Premium status and billing information needed for the transaction, including name, address and tax details where required. Records can include order/payment IDs, amounts, currency, dates, refunds and limited payment-method metadata. Stripe or PayPal handles payment details through its integration; the FredSpeak application database does not store full card numbers or card security codes.

Purposes/legal bases: requested account, subscription, payments and contractual support (GDPR 6(1)(b)); tax/accounting and legal duties (6(1)(c)); proportionate fraud prevention and legal claims (6(1)(f)). Mandatory fields are needed for that service or duty; optional fields are identified as such.

3. Progress and public leaderboard

Premium records include completed lesson slots, verified rubies, module totals, recent activity counters, preferences, resume point and aggregate voice statistics. The app does not keep a permanent answer-by-answer quiz history. These data provide requested learning features (GDPR 6(1)(b)). Guest progress and preferences are stored in browser IndexedDB and are not imported into Premium.

The public leaderboard shows a nickname, verified ruby total and ranking. The default nickname is generated without using your name or email; if you change it, choose a nonidentifying nickname. Account email, billing details and recordings are not public. Expiry alone does not immediately remove an entry; the 30-day post-subscription retention period below applies.

The leaderboard relies on our legitimate interest in providing a limited, pseudonymous learning comparison (6(1)(f)). We have documented the purpose, necessity, risks and safeguards in an internal balancing assessment. You may object or request removal at info@fredspeak.com or through our contact page. We can hide your public entry while preserving your private learning progress and subscription; you do not need to delete your account to make this request.

4. Microphone recordings and analysis

Microphone exercises are optional. Your browser requests microphone permission. Recording alone does not send audio for analysis: upload occurs when you request feedback. Clips are limited to 15 seconds and 4 MiB. The clip, expected phrase and necessary request identifiers pass through the private queue and AI-based recognition service; it returns pronunciation estimates, recognized sounds and phrase comparisons. Noise or other voices can be captured: record only yourself and avoid personal or sensitive information.

The application, database, private analysis queue and phoneme-recognition models run on the same OVHcloud server in Italy, managed directly by the controller. Voice analysis is performed there, without sending recordings to an external speech-analysis API. Amazon SES is used for email delivery, not speech analysis, and voice clips are not attached to routine service emails. Lesson content is generated using AI; this does not require sending your account information or recordings to an external lesson-generation service.

Voice recordings are personal data. This feature does not create voiceprints for unique identification or use incoming clips to train the current model. A voice is not automatically special-category biometric data merely because it is recorded. The requested optional analysis relies on performance of the service (6(1)(b)); microphone permission is a technical authorization, not consent to unrelated uses. You may decline recording and use textual activities. Do not submit another person’s voice without lawful authority.

5. Guest identifiers and security logs

Guest access is not wholly anonymous or wholly confined to your device. A signed Guest cookie, pseudonymous IDs and keyed IP-derived digests support usage limits, temporary quiz tickets and abuse prevention. A digest is pseudonymous, not guaranteed anonymous. IP addresses, timestamps, requested URLs, browser information and technical errors may also appear in web-server or security logs. We do not deliberately log passwords, full card details or voice content in routine access logs. FredSpeak does not introduce a hardware fingerprint for this purpose.

Proportionate security processing relies on our legitimate interest in protecting accounts, availability and fair use (6(1)(f)), or a legal duty where applicable (6(1)(c)). The balancing assessment considers short retention, limited access and pseudonymization. Routine web and security logs have a 30-day retention period; a narrowly relevant record may be retained longer for a documented security incident, legal obligation or active claim, with periodic review. Short-lived application tickets and rate limits follow the shorter periods below.

The Premium system may also maintain internal login, visit and page-view counters for account operation and service administration. These are not advertising profiles or a permanent record of quiz answers. Account-linked counters follow the account retention period; statistics that are irreversibly anonymized may be kept without identifying you.

6. Contacts and withdrawal requests

Contact messages include name, email, message and notice acknowledgement. They are sent through Amazon Simple Email Service (Amazon SES) to support: delivery infrastructure and the recipient mailbox process the message even though the contact plugin creates no message database. We use Amazon SES for transactional messages such as account communications, support routing and withdrawal receipts. A JavaScript challenge, empty honeypot and brief keyed IP-derived rate limit prevent automated abuse. General inquiries rely on legitimate interest; precontractual or account support on 6(1)(b). The notice checkbox is not marketing consent.

Online withdrawal records include account ID, name, email, selected contract or order reference, request ID and server timestamp. The request is stored to document receipt and emailed to the provider and to you as a receipt. Delivery status and retry information may be recorded. Legal duties and protection of claims provide the bases (6(1)(c), and 6(1)(f) where appropriate). Submission does not itself erase the account or issue a refund. Ordinary correspondence and withdrawal files are retained for 12 months after the matter is closed, subject to the legal-record exceptions below.

7. Retention

• Premium accounts and learning progress: retained during paid access and for 30 days after that access ends, to allow you to return. If Premium is renewed within that period, retention continues for the renewed service. After the period, account data, learning progress, account-linked usage counters and the public leaderboard entry are deleted or irreversibly anonymized, except for limited records separately needed by law or for an active claim. This is the retention rule, not a promise of permanent recovery after expiry. Necessary site-administration accounts are retained for operating the service rather than treated as expired student subscriptions. Recent activity counters cover approximately 14 days.
• Guest browser data: progress remains until you clear site data or the browser removes it. A local recording may remain briefly for feedback handoff; stale entries older than approximately one hour are removed when the app accesses that store, not by a guaranteed background timer.
• Active server audio and analysis results: audio working files are removed when analysis settles or orphan cleanup runs. Terminal results and provider job-ledger entries normally expire after approximately one hour. Deletion depends on functioning workers and cleanup; unresolved jobs can remain until reconciled. Backup copies, if any, follow the separate backup cycle below.
• Anti-abuse records: short rate-limit windows, quiz tickets around 20 minutes and Guest voice quotas around 24 hours. Pending reservations may remain until resolved. The Guest cookie lasts up to 30 days.
• Ordinary support email and withdrawal files: 12 months after closure of the request. We retain only specifically necessary records beyond this period where a legal obligation or a documented outstanding dispute requires it; routine correspondence is not kept indefinitely merely because a dispute is theoretically possible.
• Invoices and mandatory accounting or tax records: ordinarily 10 years under applicable Italian recordkeeping rules, or a different period specifically required by law. These records are kept separately from learning progress. Fiscozen and the relevant accounting professionals process the information needed for these duties.
• Routine web and security logs: 30 days, except for relevant records isolated for a documented incident, legal duty or active claim.
• Backups: made daily on the same OVHcloud server in Italy, with a rolling 30-day retention. A copy may therefore contain data already removed from the live system for up to a further 30 days. Backups are not used as ordinary working archives; after a restoration, previously required deletions and restrictions must be reapplied. A change of backup location or provider will be reflected in this notice.

Deletion rules are applied through the controller’s retention and review procedures; they do not depend on you requesting erasure. You can request earlier erasure where the GDPR permits it. A record retained for an exception has restricted use and is reviewed when the exception ends.

8. Recipients and providers

The controller is the only person with ordinary administrative access to the FredSpeak server, WordPress, database and backups. No additional FredSpeak staff or external maintenance contractor is currently authorized. This does not mean that infrastructure, email, accounting and payment providers cannot process the data needed for their contracted services or legal duties.

• OVHcloud: hosts the website, application, database, backups and private phoneme-analysis service on the same server in Italy. The controller directly manages the application and analysis models; OVHcloud supplies the infrastructure. The OVHcloud contracting entity and applicable processor terms are identified in the hosting contract. See OVHcloud data protection information.
• Amazon Web Services — Amazon SES: delivers transactional email and processes the necessary recipient addresses, message content and delivery or anti-abuse metadata. It does not host FredSpeak’s pronunciation-analysis engine. SES processing depends on the AWS region and service configuration used; international email routing and provider processing are addressed below. See the Amazon SES data-protection information and AWS privacy information.
• Fiscozen S.p.A.: supplies invoicing and accounting software. For the invoice data managed by the controller through that software, Fiscozen acts as a processor under its service agreement. A professional providing tax advice may act as an independent controller for their professional and legal duties. Only relevant identity, billing, transaction and tax information is shared, not voice recordings or learning progress. See Fiscozen’s privacy information.
• Stripe and PayPal: process payment information. They may act as independent controllers for payments, fraud prevention and their own legal duties, and as processors for specific contracted tasks. See the Stripe Privacy Policy and PayPal Privacy Statement.
• Other legally necessary recipients: competent authorities and professional advisers when required for a legal duty or a specific claim. No advertising, analytics, newsletter or third-party help-desk provider is currently used by FredSpeak.
• The public: receives only the leaderboard fields described above.

Providers acting as processors are subject to applicable GDPR Article 28 arrangements. Data access is limited to what the relevant task requires. FredSpeak does not sell recordings or account data.

9. International transfers and security

The core application, database, backups and voice analysis are hosted in Italy. This does not mean that every email, payment or accounting operation stays in Italy. Amazon SES, payment providers and their subprocessors may process data in other countries, including the United States or other countries outside the European Economic Area (EEA), depending on the contracted service and routing. Email also travels to the mail provider chosen by its recipient.

Where a restricted transfer occurs, it requires the applicable GDPR Chapter V safeguards. Depending on the recipient and operation, these include a valid adequacy decision that covers the recipient, or the European Commission’s Standard Contractual Clauses with the necessary assessment and supplementary safeguards. The AWS Data Processing Addendum incorporates transfer provisions, including Standard Contractual Clauses where applicable. Stripe, PayPal and Fiscozen describe their relevant processing and transfer arrangements in their notices linked above. We do not rely on the former Privacy Shield, and accepting this notice is not blanket consent to unrestricted transfers.

You can contact info@fredspeak.com for information about the recipients, relevant locations and safeguards applicable to your data, or a copy of the applicable safeguards with necessary confidential details protected.

Security measures include access controls, password hashing, signed requests, private analysis access and limited technical identifiers. The service must use HTTPS in production, with restricted administrative access, updates, backup controls and incident management. No system guarantees absolute security. Personal-data breaches are assessed and notified to authorities and affected people where legally required.

10. Cookies and browser storage

FredSpeak currently uses first-party technical storage and limited internal Premium counters. It does not use advertising pixels, Google Analytics, Meta Pixel, remarketing, newsletter tracking or cross-site marketing profiles. The current storage types are:

• fredspeak_guest: first-party, signed, HttpOnly cookie, up to 30 days; supports the Guest identity, usage limits and requested features. HTTPS enables its Secure attribute.
• fredspeak-guest IndexedDB: local Guest progress, preferences and temporary recording handoff. Progress remains until cleared or removed by the browser; temporary recordings follow the cleanup rule above.
• wordpress_logged_in_* and wordpress_sec_* / wordpress_* authentication cookies: used when you sign in. They normally operate for the browser session; selecting Remember Me allows persistence for approximately 14 days, subject to WordPress session validation and its security grace period. Logging out invalidates the relevant login session.
• wordpress_test_cookie: a session cookie used by WordPress login flows to check cookie support, when that flow sets it.
• wp-settings-* and wp-settings-time-*: user-interface preferences, where used, normally up to one year.
• pmpro_visit: a first-party session marker used by the Premium plugin to avoid counting the same visit twice within a session. Internal account usage counters are not shared with advertising networks.
• PHPSESSID: may be used as a session cookie by Premium checkout to maintain the payment flow.
• Installable app preferences and public cache: if you dismiss the installation invitation, the first-party localStorage preference fredspeak-install-dismissed-until suppresses it for seven days. An installed standalone window does not show the invitation. The Service Worker uses Cache Storage only for the public offline screen and selected icons; it does not cache account pages, quiz or API responses, payments or voice recordings. Public cached files remain until updated or site storage is cleared. Installation and the native confirmation are controlled by your browser.
• Temporary browser session storage: may hold the identifier of a pending pronunciation job; it is not the permanent Premium progress record.
• Payment-provider storage: Stripe or PayPal may set cookies or use browser storage for their checkout, authentication, security and fraud-prevention functions. Their notices describe the names, duration and choices for their own domains; these can vary by payment method and provider configuration.

Necessary technical storage does not require cookie consent under applicable Italian rules. Any nonessential tracking requiring consent must remain blocked until a valid choice, with an accessible way to withdraw it. Continued browsing is not consent. Browser settings let you clear or block site data; doing so may log you out, disrupt checkout or erase Guest progress. Clearing a device does not erase server account or billing records.

10.1 Cookies and other storage technologies

FredSpeak uses cookies and other browser storage technologies to manage access, platform features, preferences, and learning progress. The tables below describe the names, purposes, and retention periods of the technologies identified during the review on October 27, 2026.

First-party cookies are associated with the domain fredspeak.com. WordPress, Paid Premium plans Pro, and Smart Cookie Kit identify the software that uses them; using this software does not automatically make these cookies third-party cookies.

First-party cookies

The pmpro_visit cookie is used to count visits and is distinct from cookies used exclusively for authentication, security, and checkout functionality.

WordPress cookies associated with sign-in and preferences

The following cookies may be used when you sign in to an account, reset a password, or use the relevant WordPress preferences. They are not all set during ordinary Guest browsing. The parts [hash] and [id] represent variable components of the cookie name.

The cookie’s lifetime in the browser is separate from the validity of authentication on the server. Under WordPress’s default behavior, authentication normally remains valid for 2 days without “Remember Me,” even though session cookies are used.

IndexedDB, localStorage, sessionStorage, and PWA caching

The platform also uses the following technologies within the origin https://fredspeak.com. These storage mechanisms are not HTTP cookies, but they can retain data on your device.

You can manage data stored in your browser through its cookie and site data settings. Deleting this data may result in the loss of Guest progress, preferences, and locally available recordings.

11. Rights and complaints

Under GDPR conditions, you may request access/copies, rectification, erasure, restriction and portability, and object to legitimate-interest processing. Consent can be withdrawn without affecting earlier lawful processing; direct marketing can always be opposed. We may verify identity proportionately: do not send identity documents unless necessary and securely requested. Requests are normally free. We respond within one month; a lawful extension of up to two more months for complexity/volume is explained within the first month.

Erasure does not remove records lawfully retained for obligations; pending voice jobs may need safe reconciliation. Also clear browser storage to remove Guest device data. You can complain to the Italian Garante or another competent EU authority and seek a judicial remedy.

12. Automation, children and updates

Quiz marking, rubies, pronunciation scores and usage limits are automated learning/operational features. The current system does not make solely automated decisions with legal or similarly significant effects under GDPR Article 22. Report scoring/access errors to support. Paid accounts are intended for adults 18 and over; do not submit children’s recordings/data. Inappropriate collection will be assessed and addressed. Marketing needs its own lawful basis; account creation does not subscribe you to promotional email. Processing changes will be reflected here, with extra notice or consent where required.