Privacy Policy
This Privacy Policy explains how POFKARIO HOLDINGS LIMITED, a company registered in the Republic of Cyprus under registration no. HE 467843, with its registered office at Promachon Eleftherias 1, 1st floor, Office 18/19, Agios Athanasios, 4103, Limassol, Cyprus ("Lingvoo", "we", "us"), collects, uses, shares and protects personal data when you use our websites lingvoo.com and lingvoo.ai (including start.lingvoo.com and app.lingvoo.com), the Lingvoo web application and the Lingvoo translator that joins your meetings (the "Services"). It also explains your rights.
For the purposes of the EU General Data Protection Regulation (GDPR) and the UK GDPR, POFKARIO HOLDINGS LIMITED is the controller of your personal data. Where you add the translator to a meeting, you decide whether that meeting is translated and are responsible for informing the other participants (see section 4).
Contact for privacy questions: support@lingvoo.com. We have not appointed a data protection officer; privacy questions are handled through that address.
Any translation of this Policy is provided for convenience; the English version prevails.
1. Personal data we collect, why, and on what legal basis
| Purpose | Data | Source | Legal basis (GDPR art. 6(1)) |
|---|---|---|---|
| Create and manage your account, sign you in | Name, email address; if you sign in with Google, your Google profile name, email and picture | You; Google | Contract (b) |
| Provide live translation and captions | Meeting audio and video received by the translator; speech and voice data; the meeting link you paste; selected languages and session mode; session times; minutes used; generated captions, translations and transcripts | You; the meeting you send the translator to | Contract (b) |
| Run the demo | Microphone audio from your device for up to a short demo session, a random demo visitor identifier, IP address (to apply demo limits) | You; automatically | Legitimate interest (f): offering a trial of the product and preventing abuse |
| Process payments and manage subscriptions | Payment and subscription status, identifiers linking them to your account, amount and currency, and in some payment notifications the card brand and last 4 digits. Card numbers and billing details are collected by Stripe and do not reach our servers | You; Stripe | Contract (b); legal obligation (c) for accounting and tax records |
| Understand how Lingvoo fits your needs | Answers to the sign-up questionnaire: work or personal use, role, company size and website, number of multilingual calls per week, primary meeting platform, intended use | You | Legitimate interest (f) |
| Customer support | Messages and feedback you send us, including through the in-app chat, and your email address | You | Contract (b); legitimate interest (f) |
| Service email | Email address; sign-in codes, receipts, billing and account notices | You | Contract (b) |
| Product updates and offers by email | Email address, opt-in status | You | Consent (a) — you can withdraw at any time |
| Security, fraud and abuse prevention, error monitoring | IP address, device, browser and operating system type, bot-protection check results, error reports with page and interaction events (no IP address is attached to error reports) | Automatically | Legitimate interest (f): keeping the Services secure and working |
| Offer local currency and taxes | Approximate location derived from your IP address by our hosting and payment providers | Automatically | Contract (b); legal obligation (c) |
| Product analytics | Page views and product events on our websites and in the app, with a random visitor identifier; linked to your account when you sign in. Events describe what was done, not what was said or typed | Automatically (cookies/browser storage) | Consent (a) in the EEA, the UK and Switzerland; legitimate interest (f) elsewhere (see section 8) |
| Advertising measurement | Referring page and campaign parameters (such as UTM tags) and advertising click identifiers (such as gclid); conversion events (for example, a purchase); for enhanced conversions, a SHA-256 hash of your email with a payment record | Automatically; our payment records | Consent (a) |
| Legal compliance and defence of claims | Records of payments, subscriptions, minute grants, refunds and correspondence | Our records | Legal obligation (c); legitimate interest (f) |
Where we rely on legitimate interests, you can object at any time (see section 10). You do not have to provide personal data, but without the data needed for the contract we cannot create an account or provide the Services.
We do not use the content of your meetings (audio, captions, translations) for advertising, and we do not sell personal data.
2. Meeting audio, captions and transcripts
- Real-time processing only. Audio and video of the meeting received by the translator while it is in your meeting are processed in real time by our meeting-bot provider and our translation provider solely to produce translation and captions. Processing stops when the session ends.
- No recordings. Our meeting-bot provider runs in zero-data-retention mode: no recording of the meeting is kept after the call, and we keep no recordings, photos or videos of participants.
- Captions are stored. Automatically generated captions and their translations (with timestamps and language metadata) are stored for every session in the account that ran it.
- Who can see captions. While a session is running, its captions are visible to anyone holding the session's listener link, without signing in. After the session ends, only the account that ran the session can access them.
- Deletion. Captions and transcripts are kept until you ask us to delete them: write to support@lingvoo.com from the email address on your account.
3. Sources of personal data
- You, when you create an account, answer the questionnaire, start a session or demo, buy a plan, or contact us.
- Meetings you send the translator to, which include the speech of other participants.
- Automatically, through cookies, browser storage and similar technologies (see our Cookie Policy at lingvoo.com/cookies) and server logs.
- Third parties: Stripe (payment and subscription status) and Google (when you sign in with Google).
4. Other meeting participants
The translator processes the speech of everyone in the meeting, not only the account holder. The person who adds the translator must inform all participants and obtain any legally required consent before doing so (see Terms of Use, section 5). If you took part in a meeting translated by Lingvoo and want to exercise your rights, contact support@lingvoo.com; we will help where we can identify the session, and may need to involve the account holder who ran it.
5. Who we share personal data with
We share personal data only with the following service providers (processors acting on our instructions under data processing terms), each for the stated purpose:
| Provider | Purpose | Location |
|---|---|---|
| Recall.ai | Meeting bot that joins your call and receives meeting audio and video for real-time processing (zero data retention) | United States |
| Palabra.ai | Real-time speech recognition, translation and speech synthesis; audio and captions travel through Palabra's media infrastructure (LiveKit) | United States / EU |
| OpenAI | Real-time speech translation for certain session modes, where that mode is selected | United States |
| Amazon Web Services | Hosting of the application and database; sign-in through Amazon Cognito | EU (Stockholm) |
| Stripe | Payment processing, subscription billing and the billing portal | EU (Stripe Payments Europe, Ireland) |
| Resend | Delivery of service email and, if you opted in, product updates | United States |
| Sentry | Error monitoring; stored in the EU, without IP addresses, no session replay | EU |
| PostHog | Product analytics; stored in the EU; session recording off; page addresses recorded without payment or advertising click identifiers | EU |
| Crisp | In-app support chat | EU (France) |
| Cloudflare | Bot protection (Turnstile) on the quiz and demo | United States (global network) |
| Sign in with Google; the Google STUN server used by the listener page to set up the audio connection (receives your device IP address, no audio or captions); and, with your consent, Google Ads and Google Tag Manager for advertising measurement | United States / EU | |
| Slack and Telegram | Internal notifications to our team about new registrations (including questionnaire answers) and product feedback | United States (Slack); United Kingdom / EU (Telegram) |
We may also share personal data:
- with people you authorise, such as anyone you give a session's listener link to;
- with affiliates that help us operate the Services, including a related operator, which shares our infrastructure and processes personal data for that infrastructure on our behalf;
- with authorities, courts and advisers where required by law or to establish, exercise or defend legal claims; and
- in connection with a merger, acquisition or sale of assets, subject to this Policy.
6. Advertising measurement and enhanced conversions
With your consent, we use Google Ads and Google Tag Manager to measure how well our advertising works. These services may set and read cookies on our domains, receive information about pages you visit and actions you take on our websites and in the app (for example, that a purchase was completed), and recognise your device across websites and apps.
Enhanced conversions: when you pay for a plan, an intro offer or a minute pack (including renewals) and you have consented to advertising measurement, our servers may send Google Ads a record of that payment: amount and currency, time, an order reference, the advertising click identifier saved when you arrived from an ad, and a SHA-256 hash of your email address, normalised as Google requires before hashing. Google receives the hash, not your readable email address, and uses it only to match the payment to the ad. If a payment is refunded, we tell Google so that the conversion is withdrawn or reduced. Without your consent we do not send this record. Google processes this data under the Google Ads Data Processing Terms.
You can withdraw consent at any time through the "Cookies" link in the footer of our websites or by writing to support@lingvoo.com; this stops further transfers.
7. International transfers
Our main hosting is in the EU. Some providers listed above process personal data in the United States or other countries outside the European Economic Area. Such transfers rely on an adequacy decision (including the EU–US Data Privacy Framework, where the provider is certified) or on Standard Contractual Clauses approved by the European Commission, together with supplementary measures where needed. Contact us for a copy of the relevant safeguards.
8. Cookies
We use cookies and similar technologies as described in our Cookie Policy at lingvoo.com/cookies. Cookies that are strictly necessary to provide the Services are always on. In the EEA, the UK and Switzerland, analytics and advertising cookies are used only with your consent, which a banner asks for on your first visit; elsewhere they are on by default. You can change your choice at any time through the "Cookies" link in the footer.
If you open the sample call offered on our websites, it is shown from a third-party provider's page embedded in ours; that provider may set its own cookies and collect technical data (such as your IP address, browser and device information) and, if you join the call, the microphone and camera input you allow, under its own privacy policy.
9. Retention
- Account data: while your account is active, and deleted within 30 days after you ask us to delete the account, except as below.
- Meeting audio and video: not retained after the call.
- Captions and transcripts: until you ask us to delete them, or until your account is deleted.
- Demo audio: processed in real time and not retained.
- Payment, subscription, minute and refund records: kept after account deletion for as long as required for accounting and tax purposes under Cyprus law (up to 7 years) and to prevent misuse.
- Analytics and advertising identifiers: for as long as needed for the purposes in section 1 (PostHog visitor identifier up to 365 days), and no longer used once you withdraw consent.
- Support conversations: up to 3 years after the conversation is closed.
10. Your rights
If the GDPR or UK GDPR applies to you, you have the right to:
- access your personal data and receive a copy;
- rectify inaccurate data;
- erase your data ("right to be forgotten");
- restrict processing;
- data portability for data you provided to us under contract or consent;
- object to processing based on legitimate interests, and at any time to direct marketing;
- withdraw consent at any time, without affecting processing before the withdrawal; and
- lodge a complaint with a supervisory authority. Our lead authority is the Office of the Commissioner for Personal Data Protection, Cyprus (www.dataprotection.gov.cy); you may also complain to the authority where you live or work.
To exercise your rights, including deleting your account or the captions of your sessions, write to support@lingvoo.com from the email address on your account. We reply within one month, which may be extended as allowed by law. We may ask you to confirm your identity.
Communication preferences. You can stop promotional email through the unsubscribe link or by writing to us; service email such as sign-in codes and billing notices continues while you have an account.
California and other US states. We do not sell or share personal information for cross-context behavioural advertising without consent, and we do not use sensitive personal information to infer characteristics. US residents may request access, correction or deletion at support@lingvoo.com.
11. Google API data
Our use and transfer of information received from Google APIs complies with the Google API Services User Data Policy, including the Limited Use requirements.
12. Security
We use appropriate technical and organisational measures to protect personal data, including encryption in transit, encrypted storage, access controls and least-privilege access for staff, and monitoring for errors and abuse. No system is completely secure; if we become aware of a personal data breach that affects you, we will notify you and the authorities as required by law.
13. Children
The Services are not directed to children. You must be at least 18 years old to create an account. We do not knowingly collect personal data from children under 16; if we learn that we have, we delete it promptly. Contact support@lingvoo.com if you believe a child has provided us with personal data.
14. Changes to this Policy
We may update this Policy. We will announce material changes on lingvoo.com, by email or in the app before they take effect. The current version is always available at lingvoo.com/privacy.
15. Contact
POFKARIO HOLDINGS LIMITED Promachon Eleftherias 1, 1st floor, Office 18/19, Agios Athanasios, 4103, Limassol, Cyprus Registration no. HE 467843 Email: support@lingvoo.com