Privacy Policy

1. Information We Collect

1.1 Information You Provide Directly

• Account & contact information: name, email address, password, organization, role, country.
• Billing information: payment method details (processed by third-party providers such as Stripe), billing address, transaction history.
• Program application data (SoeMind Foundry): the problem you want to solve, your target user, what you have built so far, your availability for the cohort, and any prototype, portfolio, or project links you choose to share.
• OwlThuTa practice data: speaking audio recordings, written IELTS-style answers, multiple-choice responses, practice scores, mock-test results, AI-generated feedback, study session activity, uploaded study materials, and waitlist sign-ups.
• Support communication: messages you send us via email or support forms.

1.2 Information Collected Automatically

• Usage data: pages viewed, features used, actions taken, date and time of activities.
• Device & log data: IP address, browser type, operating system, device identifiers, referring URLs, crash reports.
• Cookies & similar technologies: session cookies, preference cookies, analytics cookies (see Section 9).

1.3 Information from Third Parties

• Payment processors (confirmation of payment, last 4 digits of card, payment status).
• Authentication providers (e.g., Google Sign-In, if enabled).
• Analytics partners (aggregated usage metrics).

We do not knowingly collect sensitive personal information (e.g., health, biometric, religion) unless explicitly provided by you. Please avoid submitting such information unless necessary.

2. How We Use Your Information

Providing and operating the Services

• Creating and managing user accounts.
• Reviewing program applications and operating cohorts.
• Generating IELTS practice feedback, mock-test scoring estimates, and progress reports.
• Processing payments and subscriptions.

Improving and developing the Services

• Analyzing usage patterns, debugging, and monitoring performance.
• Improving AI feedback quality and product features using aggregated or de-identified data.

Communication

• Sending service-related messages (account notices, billing, cohort schedule, OwlThuTa beta updates).
• Responding to support requests.
• Sending non-essential updates only if you opt in; you can unsubscribe at any time.

Security & legal compliance

• Detecting and preventing abuse, unauthorized access, or illegal activities.
• Meeting legal, tax, accounting, and regulatory obligations.

3. OwlThuTa Practice Data

When you use OwlThuTa, we process the following categories of data to provide IELTS practice features:

• Speaking audio recordings — to generate AI feedback on pronunciation, fluency, and band-style estimates.
• Written answers — to generate AI feedback on task achievement, grammar, vocabulary, and structure.
• AI feedback and band estimates — generated outputs from our AI providers that we store with your account.
• Practice scores, mock-test results, and progress history — to show your progress over time.
• Uploaded study materials — only when you choose to share them with the platform.
• Beta waitlist information — email address and any optional details you provide.

Use for model training. We do not use your speaking recordings, written IELTS answers, or uploaded study materials to train our own or third-party AI models without your explicit consent. Aggregated and de-identified data may be used to evaluate and improve feedback quality.

Third-party AI providers. Generating IELTS feedback may require sending the minimum necessary content (e.g., a transcribed answer or a short audio clip) to third-party AI providers (e.g., LLM and speech APIs) that we contractually require to process the data only on our behalf and not retain it for their own model training.

Deletion. You may delete individual speaking recordings, written answers, and practice records from your account at any time. You may also request deletion of your entire OwlThuTa account by contacting contact@soemindai.com.

Retention. Practice data is retained while your account is active. Inactive accounts may have practice data deleted after a defined retention period (described in-product); aggregated, de-identified analytics may be retained indefinitely.

4. AI Product Builder Program Data

If you apply to or participate in the SoeMind Foundry program:

• We collect and store the application form fields you submit (problem, target user, what you have built, availability, optional links).
• We may store program-related materials you share during the cohort (e.g., MVP documents, demo notes, user-research summaries) in our coaching workspace.
• Program application data is used to evaluate applications, plan the cohort, and provide coaching. We do not sell or share this data with third parties for advertising.
• You retain ownership of your ideas, MVP documents, and code. SoeMindAI claims no ownership of your business idea or product.
• You can request that your program materials be deleted after the cohort ends by contacting contact@soemindai.com.

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

If you are in the European Economic Area (EEA) or UK, we process your personal data under one or more of the following legal bases:

• Contract: to provide you with the Services you request (e.g., the program cohort, OwlThuTa practice).
• Legitimate interests: to improve our Services, maintain security, and communicate with you where our interests are not overridden by your rights.
• Consent: where required (e.g., certain cookies, marketing communications, or use of recordings for model improvement).
• Legal obligation: to comply with applicable laws.

6. How We Share Information

We do not sell your personal information.

We may share information with:

Service Providers & Vendors

• Cloud hosting and storage providers
• Payment processors (e.g., Stripe)
• Email and communication platforms
• Analytics tools
• Third-party AI providers used to generate IELTS feedback (limited to the minimum content required)

These parties process data on our behalf under contractual obligations to protect it.

Legal & Safety Reasons

We may disclose information if we believe it is necessary to comply with law, protect rights or safety, or enforce our Terms.

Business Transfers

In connection with a merger, acquisition, asset sale, or similar transaction, your information may be transferred. We will notify you where required by law.

7. International Data Transfers

SoeMindAI Inc. is incorporated in the United States (Delaware), and we may process data on servers or with providers located in multiple countries. If you are located outside the United States, your information may be transferred, stored, and processed in countries with different data protection laws than your country. We take appropriate measures to protect your data, consistent with applicable law.

8. Data Retention

We retain personal information for as long as necessary to:

• Provide and maintain the Services (including ongoing program cohorts and OwlThuTa accounts)
• Comply with legal obligations
• Resolve disputes and enforce agreements

Aggregated or de-identified data may be retained indefinitely. You may request deletion of your account and associated data by contacting contact@soemindai.com, subject to our need to retain certain data for legal or legitimate business reasons.

9. Cookies & Tracking Technologies

We use cookies and similar technologies to keep you logged in, remember preferences, analyze site traffic, and improve performance.

• Essential cookies: required for basic functionality.
• Analytics cookies: to understand how the Services are used.
• Preference cookies: to store settings and language preferences.

You can control cookies through your browser settings. Disabling some cookies may affect functionality.

10. Your Rights and Choices

Depending on your location, you may have rights regarding your personal information, including:

• Access: request a copy of the personal data we hold about you.
• Correction: request correction of inaccurate or incomplete data.
• Deletion: request deletion of your personal data (including speaking recordings, written answers, and program materials), subject to legal limits.
• Restriction: request that we limit processing in certain cases.
• Objection: object to certain processing based on our legitimate interests.
• Portability: request a copy of your data in a structured, machine-readable format.

To exercise these rights, contact us at contact@soemindai.com. We may need to verify your identity before responding.

11. Children's Privacy

Our Services are not directed to children under 13, and we do not knowingly collect personal information directly from children under 13. OwlThuTa is intended for IELTS learners (generally 16+); the AI Product Builder Program is intended for builders aged 18+.

If you believe we have collected personal information from a child under 13 without appropriate consent, please contact us immediately at contact@soemindai.com and we will take steps to delete it.

12. Security

We use reasonable technical and organizational measures to protect personal information, including encryption in transit, access controls, authentication, and monitoring. However, no system is 100% secure. If we discover a security incident that affects your data, we will notify you as required by law.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will update the "Last updated" date and provide additional notice (e.g., email or in-app) for significant changes. Continued use of the Services after changes become effective means you accept the updated Privacy Policy.

14. Contact Us

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

SoeMindAI Inc.
Email: contact@soemindai.com