Privacy Policy

Last Updated: September 23, 2026

I. INTRODUCTION

IdeaLabs Pte. Ltd. ("we", "us" or "our") takes your privacy seriously. This Privacy policy ("Privacy policy") explains our data protection policy and describes the types of information we may process when you install and/or use YayTalk, our AI-powered English speaking and conversation learning application for iOS and Android devices, together with our related website and web subscription services (collectively, the "App", "our App").

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

A natural person can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

Our Privacy policy applies to all users, and others who access the App ("Users").

For the purposes of the GDPR and other applicable data protection laws, IdeaLabs Pte. Ltd. is the data controller (for users in the Republic of Korea, the "personal information controller"), unless otherwise stated. Our contact details are provided in Section XIV.

This Privacy policy should be read together with our Terms of Service. Additional information for users in the European Economic Area, the United Kingdom and Switzerland is provided in Section XI, and for users in the Republic of Korea in Section XII.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

II. INFORMATION WE PROCESS

There are several categories of information that can be processed.

Functional Information

We ask for and process the following information when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.

Account Information (e.g. your e-mail address, or the account identifier provided by a third-party sign-in service you choose to use). We use this information to create and maintain your account, to keep your learning progress and subscription status in sync across your devices and between our mobile App and our website, and to restore your purchases.

User Content (i. e. the text and voice messages you send to the App, including your conversations with the AI tutor and your answers in lessons, exercises and the placement test, as well as any text, audio or other content generated by AI via the App, such as the AI tutor's replies, corrections and feedback). Subject to your compliance with certain rules and restrictions outlined in our Terms of Service, you may use User Content for your own personal learning purposes. However, any use of User Content is at your sole risk, i. e. you assume and bear all risks and responsibility associated with your use of User Content. It is your sole responsibility to ensure compliance with the applicable laws while using the User Content. Please note that we engage third-party AI model providers, including OpenAI, L.L.C., for the purpose of processing and generating AI-generated User Content. We also engage third-party speech recognition (speech-to-text) and speech synthesis (text-to-speech) service providers to transcribe your voice messages and to produce the AI tutor's voice. Please check Section IV to learn more about our service providers.

Learning Profile Information (e.g. your native language, learning goals, interests, self-assessed English level, placement test results, lesson history and learning progress). We use this information to assign lessons of a suitable difficulty level, to generate personalized learning content and to allow the AI tutor to remember relevant context from your previous sessions, so that your learning experience is continuous and tailored to you. For this purpose, the AI tutor may retain information you choose to share during your conversations (for example, your job or hobbies). Please do not share sensitive personal information (such as health, financial or identification data) in your conversations with the AI tutor.

Your conversation history and learning records are stored in your account so that you can review your past lessons within the App. However, we cannot guarantee that all historical User Content will remain accessible within the App indefinitely.

To learn more about the storage terms applicable to User Content, please review Section V of the present Privacy policy.

Processing of third parties' information. When using the App, you might share with us information relating to other persons (for example, by mentioning them in your conversations with the AI tutor), or your voice recordings may capture the voices of other people around you. In this case, you warrant that you have all necessary rights and authorizations to lawfully process such information and to share it with us and you acknowledge that you will be held responsible for the lawfulness of such data processing activity. You agree to fully indemnify us against any objection, claim, request for compensation for damage arising from such processing that we may receive from third parties whose information has been processed through your spontaneous submission in violation of the applicable laws. In any event, should you provide us with or otherwise process information of third parties, you warrant that this processing is based on an appropriate legal basis.

In order to talk with the AI tutor and practice speaking, the App needs access to your microphone. This access will require that you grant a specific permission through a request that will appear on your device. You can revoke this permission at any time in your device settings; however, speaking-related features of the App will not be available without it.

Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, support form. We collect, store and process it by our cloud storage provider (Amazon.com, Inc.). We use such information to respond effectively to your inquiry, fulfill your requests, send you communications that you request and perform the requested services.

Voice Data and Speech Recordings

What We Collect: When you use the speaking features of the App, such as conversations with the AI tutor, speaking exercises or the speaking part of the placement test, the App records your voice through your device's microphone. Your recordings are converted into text and may be analyzed for pronunciation, fluency, grammar and vocabulary in order to provide you with learning feedback. We do not create voiceprints, and we do not use your voice data to identify or authenticate you.

Feedback and assessment results (such as your estimated English level or pronunciation feedback) are generated automatically by AI and are provided solely for learning purposes. They may not always be accurate and do not constitute an official certification of your language skills.

How We Use Your Voice Data: Voice recordings and their transcripts are processed exclusively to provide the learning features of the App, including real-time conversation with the AI tutor, speaking feedback, lesson personalization and progress tracking, and to maintain and improve the quality of these features. We do not use your voice data for advertising purposes. We do not sell your data.

Storage and Retention: Transcripts of your conversations are stored on our secure servers hosted by Amazon Web Services (AWS) as part of your conversation history and are retained as described in Section V. Audio recordings are processed to deliver the requested features and are not retained longer than necessary for that purpose.

Third-Party Processing: To provide speech recognition, speech synthesis and AI tutoring, your voice recordings and conversation text may be transmitted to trusted third-party AI and speech technology providers, including but not limited to OpenAI. These providers process the data only to deliver the requested functionality. For more information about our service providers, please refer to Section IV: Sharing of Your Information.

Payment Information

Our e-commerce providers are responsible for billing, processing and charging for purchases. Purchases made within the mobile App are processed by the Apple App Store or Google Play. Purchases made on our website are processed by our online reseller Paddle.com, which acts as the Merchant of Record. We cannot access or use your credit or debit card information. We only receive limited transaction information (such as order number, subscription plan and status, country and the e-mail address used for the purchase) in order to activate and manage your subscription in the App.

You may access the applicable purchase rules and policies directly from the respective e-commerce provider.

Information That Is Processed Automatically

On the basis of your permission we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our App (Identity For Advertisers for iOS devices). Some integrated advertising or analytics tools (check Section IV to see the list of them) launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically once you allow our App to track your activity. You can withdraw your permission at any time - please check opt-out options in Section VII below.

We may process some information about your device and your user behaviour on the ground of our legitimate interest. This information falls within categories of data described above in Subsection "Information That Is Processed Automatically", it is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We use this information for improving our App and giving our users the best experience.

Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).

Cookies and Similar Technologies

Our website and App use cookies and similar technologies, such as software development kits (SDKs), pixels, device identifiers and local storage (together, "Cookies"). Cookies are small pieces of data stored on or read from your device.

Analytics and marketing Cookies are only used with your consent, which you give through the cookie banner on our website or, on iOS, through the App Tracking Transparency prompt. You can change or withdraw your consent at any time through the cookie settings on our website, your browser settings, or the settings of your device as described in Section VII. Withdrawing your consent does not affect the lawfulness of processing carried out before the withdrawal. For more details about the Cookies we use, including their providers and purposes, please see our Cookie Policy.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy.

Please note that while integrating external services we choose third parties that can assure they apply all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may also share certain information with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

We may engage the following third-party service providers, as well as speech recognition and speech synthesis service providers, in order to provide us with necessary infrastructure for delivery and improvement of our services:

In case you want to learn more about the services and privacy options (including opt-out) please consult the correspondent websites and privacy policies.

Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

V. HOW LONG WE RETAIN YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

Specific storage terms applicable to User Content. Your conversation history, transcripts, learning profile information and learning records are retained for as long as your account exists, so that you can review your past lessons and so that the App can continue to personalize your learning. When you delete your account, this data is deleted or anonymized, except where its retention is required by law. Audio recordings are processed only for as long as necessary to provide speech recognition and speaking feedback.

VI. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

To exercise any of the rights described above, you can contact us through service@support.idealabs.mobi. We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.

When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the Section IV of this Privacy policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

VII. HOW TO OPT OUT

Opt-out of marketing tracking

If you don‘t want third-party service providers to use the personalized ads on the basis of your interests please follow the instructions below:

iOS: go to Settings > Privacy & Security > Tracking and turn off "Allow Apps to Request to Track", or disable tracking for the App individually. Please find additional information here.

Android: go to Settings > Google > Ads (or Settings > Privacy > Ads, depending on your device) and choose "Delete advertising ID" or opt out of ads personalization.

On our website, you can manage marketing and analytics Cookies at any time through the cookie settings on our website or your browser settings. For more information, please see Subsection "Cookies and Similar Technologies" in Section II and our Cookie Policy.

Please mind when you opt out of certain interest based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

Opt-out of Location Data Processing

If you don’t want third-party service providers to use your precise location data, or street-level location information about you please follow the instructions below:

iOS: go to "Settings > Privacy & Security > Location Services", select the App and set location access to "Never". Please see additional information here.

Android: go to "Settings > Location > App location permissions", select the App and choose "Don't allow".

VIII. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service providers‘ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us via the e-mail address provided in Section XIV below.

IX. CHILDREN‘S PRIVACY

Our App is not intended for children under the age of 13. We do not knowingly collect or solicit any personal information from children under 13. No one under age 13 may provide any personal information to the App. If you are under 13, do not use or provide any information on this App or through any of its features.

Users who have reached the age of 13 but are under the age of 18, or under the age of majority in their country of residence, may only use the App with the consent and supervision of a parent or legal guardian.

In addition, where local law sets a higher minimum age for consenting to the processing of personal data, users below that age may only use the App, and we will only process their personal information, with the consent of a parent, legal guardian or legal representative. In particular:

Where parental or legal representative consent is required, we will make reasonable efforts to verify that such consent has been given, taking into account available technology. If we learn that we have collected personal information from a child without the required consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child without such consent, please contact us at service@support.idealabs.mobi.

X. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA), requires us to disclose the categories of Personal Information we collect and how we use it, the categories of sources from which we collect Personal Information, and the third parties with whom we share it, which we have explained above.

California residents have the following rights under California law:

To exercise any of these rights, please contact us at service@support.idealabs.mobi. We will respond to verifiable requests within 45 days; where necessary, we may extend this period by an additional 45 days and will inform you of the extension.

California Online Privacy Protection Act (CalOPPA)

In accordance with CalOPPA, this Privacy policy describes the categories of Personal Information we collect, the third parties with whom we may share it, how you can review and request changes to your Personal Information (Section VI), and how we notify you of changes to this Privacy policy (Section XIII).

Our website does not currently respond to browser "Do Not Track" signals. You can manage tracking and interest-based advertising as described in Section VII and through the cookie settings on our website.

XI. ADDITIONAL INFORMATION FOR USERS IN THE EEA, THE UK AND SWITZERLAND

We process your personal data on the following legal bases under Article 6(1) GDPR (and the UK GDPR and the Swiss Federal Act on Data Protection, where applicable):

International Data Transfers

We are established in Singapore, and some of our service providers are located in countries outside the EEA, the UK and Switzerland, such as the United States. Where personal data is transferred to a country that has not been recognized by the European Commission (or the competent UK or Swiss authority) as providing an adequate level of data protection, we rely on appropriate safeguards, such as the Standard Contractual Clauses adopted by the European Commission or, for certified recipients in the United States, the EU-U.S. Data Privacy Framework. You may request a copy of the relevant safeguards by contacting us.

Data Protection Inquiries

Users in the EEA, the UK and Switzerland may direct any inquiry relating to the processing of their personal data, including inquiries under Article 27 GDPR and Article 27 UK GDPR, to us at service@support.idealabs.mobi. Information about our representative, where applicable, will be provided upon request.

Supervisory Authorities

You have the right to lodge a complaint with the data protection supervisory authority of the EEA member state of your habitual residence, place of work or place of the alleged infringement. For example:

XII. ADDITIONAL INFORMATION FOR USERS IN THE REPUBLIC OF KOREA (개인정보 처리방침)

This Section applies to users in the Republic of Korea and supplements the other Sections of this Privacy policy in accordance with the Personal Information Protection Act ("PIPA") and related laws. In the event of any conflict, this Section prevails with respect to users in the Republic of Korea.

Personal Information Processed and Purposes

You may refuse to provide optional information without any restriction on your use of the App's core features. If you refuse to provide required information, we may be unable to provide the App.

Retention Period and Destruction

We retain personal information until the purpose of processing is achieved or until you delete your account, and then destroy it without delay, except where retention is required by law, in which case the information is stored separately for the following periods:

Personal information stored in electronic form is deleted using technical methods that make it impossible to restore. Personal information recorded on paper, if any, is shredded or incinerated.

Provision of Personal Information to Third Parties

We provide personal information to third parties only with your consent or where permitted by law. Where you permit tracking, device identifiers and ad interaction data are provided to advertising and attribution partners (Meta Platforms, Inc.; AppsFlyer Ltd.) for campaign attribution and interest-based advertising, and are retained in accordance with the policies of those partners. You can withdraw this consent at any time as described in Section VII.

Entrustment of Processing (위탁)

We entrust the processing of personal information to the following service providers, and we supervise them to ensure that they process personal information securely in accordance with PIPA. A list of the specific providers is available upon request at service@support.idealabs.mobi.

Overseas Transfer of Personal Information (국외 이전)

We are established in Singapore, and personal information is transferred overseas to provide the App. The transfers are made over the network when you use the relevant features, and the information is retained until the purpose of entrustment ends or your account is deleted. Further details about the recipients, including their contact information and the specific countries of transfer, are available upon request at service@support.idealabs.mobi.

Recipient (contact)CountryItems transferredPurpose
IdeaLabs Pte. Ltd. (service@support.idealabs.mobi)SingaporeAll personal information described in this SectionOperation of the App
Amazon Web Services, Inc. (aws.amazon.com/privacy)Countries where the AWS data centers we use are locatedAll personal information described in this SectionCloud hosting and storage
OpenAI, L.L.C. (openai.com/privacy)United StatesConversation text, transcripts, learning profile informationAI tutoring and feedback
Speech recognition and speech synthesis service providersUnited States and other countriesVoice recordings, conversation textSpeech recognition and synthesis
Google LLC, Firebase (policies.google.com/privacy)United StatesDevice information, identifiers, usage logsAnalytics and crash reporting
Paddle.com Market Limited (paddle.com/legal/privacy)United KingdomE-mail address, country, payment and order informationPayment processing (website purchases)
Meta Platforms, Inc. (facebook.com/privacy) / AppsFlyer Ltd. (appsflyer.com/privacy-policy), with consent onlyUnited States and other countriesAdvertising identifiers, ad interaction dataAdvertising attribution

You may refuse the overseas transfer of your personal information by not using the relevant features or by deleting your account, or, for advertising partners, by withdrawing your tracking consent. However, as the transfers above (other than to advertising partners) are necessary to provide the App, refusing them means we will be unable to provide the App's services.

Rights of Data Subjects and Legal Representatives

You (and, for children under 14, your legal representative) may at any time request access to, correction or deletion of your personal information, request the suspension of its processing, or withdraw your consent by contacting us at service@support.idealabs.mobi or by using the settings in the App. We will respond without delay, and in any event within 10 days of receiving your request, unless there is a justifiable reason for delay, in which case we will notify you of the reason.

If you are under 14 years of age, we will process your personal information only with the consent of your legal representative.

Automatic Collection Devices

We use Cookies and similar technologies as described in Subsection "Cookies and Similar Technologies" of Section II. You can refuse them through your browser settings, the cookie settings on our website, or your device settings (Section VII). Refusing non-essential Cookies does not restrict your use of the App's core features.

Measures to Ensure the Safety of Personal Information

Chief Privacy Officer (개인정보 보호책임자)

We have designated a Chief Privacy Officer who is responsible for handling personal information and for addressing complaints and remedies of data subjects. You may contact the Chief Privacy Officer and the department in charge of personal information protection at:

E-mail: service@support.idealabs.mobi

Remedies for Infringement of Rights

If you need assistance or remedies regarding the infringement of your personal information rights, you may contact the following organizations:

XIII. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.

Whenever we change this Privacy policy, we will post those changes at https://yaytalk.ai/privacy-policy and other places that we consider appropriate, and update the "Last Updated" date above. Where changes are material, we will notify you in advance through the App or by other appropriate means, and where required by law, we will ask for your consent.

XIV. CONTACT US

If you have any questions about this Privacy policy or wish to exercise your rights, please feel free to contact us via service@support.idealabs.mobi.

IdeaLabs Pte. Ltd., Singapore
E-mail: service@support.idealabs.mobi
Our registered address and company registration details are available upon request.