Privacy Policy

Effective Date: July 17, 2026 | Version 1.0

1. Introduction & Scope

Vernato (operated by Vernato Ltd., "we," "us," or "our") provides a specialized pronunciation improvement platform. This Privacy Policy establishes our comprehensive framework governing the collection, utilization, storage, and protection of personal data when you engage with our mobile application, cloud systems, and website.

In alignment with Article 25 of the General Data Protection Regulation (GDPR) on "Data Protection by Design and by Default," privacy considerations are embedded directly into the technical and operational architecture of the Vernato service. This document describes how we process your information and detail the security protocols we employ to protect your rights.

2. Information We Collect

We adhere to strict data minimization principles. We only collect the personal details necessary to deliver real-time speech evaluation, track learning progress, and facilitate secure subscription billing.

2.1 Account & Authentication

When you register a user account with Vernato, we collect the credentials and profile details required to establish your profile:

  • Identity Metadata: Standard email address, display name, and optional profile image URL.
  • Preferences: Target language configurations, difficulty levels, and personalized learning goals.
  • Credential Isolation: Authentication is handled through Firebase Authentication, supporting secure standard email log-ins, Google Sign-In, and FIDO2 Passkeys. Password hashes and cryptographic credentials are never stored directly on our internal servers.

2.2 Pronunciation & Voice Data

To provide automated pronunciation scoring, the Vernato platform processes spoken voice recordings:

  • Audio Input: Spoken audio recorded natively via the iOS AVFoundation and Speech frameworks.
  • Analysis Metrics: Computed accuracy scores (covering phoneme accuracy, duration, stress, and pronunciation metrics) along with the transcribed text.
  • Transient Processing: Raw audio buffers are processed in-memory or briefly cached on-device for analysis and are immediately deleted upon assessment completion. We do not persist raw voice files in the cloud.

2.3 Usage Metrics & Stripe Billing

To monitor system integrity, enforce subscription boundaries, and process upgrades, we collect:

  • Usage Logging: Platform usage, assessment logs, and error rates tracked to maintain system health and enforce our Fair Usage Policy.
  • Payment Segregation: Payment processing is handled by Stripe and the Apple App Store. Vernato servers do not store credit card numbers, CVVs, or billing addresses. We only retain the Stripe Customer ID and subscription status flags.

3. Purpose & Data Utilization

Your personal information is used exclusively for the following purposes:

  • Service Delivery: Conducting speech assessments, delivering corrective phonetic feedback, and persisting your training history.
  • Progress Optimization: Analyzing accent improvement over time, managing language settings, and issuing achievement milestones.
  • Abuse Prevention: Enforcing rate limits and usage thresholds through the voice_usage subcollection to prevent automated API abuse.
  • Account Lifecycle: Initiating session management, resetting user states upon logout to prevent data bleeding, and handling customer billing.

4. Security & Architecture by Design

Security is embedded at the engineering level. We utilize standard cryptographic protocols and access control structures to protect information.

4.1 Firestore Rules & Access Control

Our Cloud Firestore database is locked behind strict owner-based validation. A default "deny all" rule is established at the root, and subcollections nested under user paths (e.g. learner_profile, voice_sessions, results) explicitly restrict access to the matching authenticated user ID:

match /users/{userId} {
  allow read, write: if request.auth != null && request.auth.uid == userId;
}

4.2 App Check & API Gatekeeping

To prevent unauthorized data harvesting and API misuse, Vernato enforces Firebase App Check during application initialization. All production clients must successfully pass device attestation (using Apple DeviceCheck or App Attest) before receiving authorization to execute database queries or call voice assessment endpoints.

4.3 Credentials & Keychain Services

Sensitive identifiers, FIDO2 credentials, and session secrets are stored securely within the iOS Keychain Services and protected by the Secure Enclave. Local application preferences (such as visual appearance or notification preferences) are saved in UserDefaults using non-sensitive keys, strictly separating interface state from personal credentials.

5. Audio Handling & AVFoundation

Spoken practice sessions utilize the native iOS device microphone. Before launching any audio assessment, the application prompts you with explicit permission dialogues for Microphone Access and Speech Recognition.

Raw audio buffers captured via AVAudioEngine or AVAudioRecorder are held temporarily in-memory or on local storage strictly for evaluation. These files are permanently deleted on-device immediately after the AI speech models generate transcriptions and scores. We do not store raw voice files in cloud storage.

6. Your Rights & Control

We provide clear mechanisms for you to manage, review, and request the deletion of your personal data at any time.

6.1 Access & Portability

You have the right to request a complete copy of the data associated with your account. Upon request, we will generate and deliver a structured JSON or CSV file containing your profile parameters, settings, and assessment history within 7 business days.

6.2 Account Deletion & Retention

You can permanently delete your account directly through the settings interface in the mobile application. Triggering account deletion initiates a cascading delete that permanently removes all documents from users/{userId} and nested subcollections.

Associated Stripe customer data is systematically scrubbed within 30 days of account deletion, provided no active billing dispute or required regulatory retention applies. Transient guest records and anonymous tracking identifiers are automatically deleted after 30 days.

8. Contact & Support

If you have any questions or concerns regarding this Privacy Policy, our data protection audits, or to request a data export, please contact our support team:

This privacy policy is subject to changes. Users will be notified of material changes within the mobile application settings.