This Privacy Policy explains how we process personal data when you use the Klara language-learning app, our website and related services.
Klara provides personalised language-learning services using text, audio and video/avatar interactions as well as artificial intelligence. Depending on the feature used, different categories of personal data may be processed.
We process personal data in accordance with the General Data Protection Regulation (“GDPR”), the German Federal Data Protection Act (“BDSG”) and, where applicable, other relevant data protection laws.
The controller responsible for the processing of personal data is:
Klara Cognitive Learning GmbHIm Geyer 435781 WeilburgGermany
Email: jf@klaracl.comLegal notice: https://klara-cl.com/impressum/
Depending on how you use Klara, we may process the following categories of personal data.
We do not directly store full credit-card numbers, bank-account details or comparable payment information used for purchases in the Apple App Store or Google Play.
We process personal data in particular to create and manage user accounts, authenticate users, provide the Klara language-learning service, conduct text, audio and avatar/video conversations, generate AI-based responses and written transcripts, assess learning progress, adapt content to the user’s language level, maintain continuity across sessions, personalise the learning experience, manage trials and subscriptions, provide customer support, maintain security, analyse errors, perform usage and marketing analysis, carry out attribution and comply with legal and contractual obligations.
We process personal data where this is necessary to provide the Klara services requested by you. This includes, in particular, registration, authentication, language-learning functionality, text, audio and video conversations, AI processing, transcription, learning progress, CEFR information, personalisation, cross-session continuity and access administration.
Where legally required, we obtain your consent, in particular for certain analytics functions, marketing analytics, attribution technologies, device identifiers and optional device permissions.
Before personal conversation or learning data is transmitted for the first time to external AI, speech or avatar services, Klara informs users which providers are involved, which categories of data are transmitted and for what purpose.
Such transmission takes place only after the user has explicitly consented to the data sharing.
Consent may be withdrawn at any time with effect for the future through the privacy settings in the app. Functions that technically require the relevant external services may no longer be available after withdrawal unless consent is granted again.
Where permitted, processing may be based on our legitimate interests in security, abuse prevention, technical troubleshooting, stability, business administration and the establishment or enforcement of legal claims.
Klara generally does not require special categories of personal data within the meaning of Article 9 GDPR. However, users may voluntarily disclose such information in open conversations.
Such information may be processed as part of the current conversation, stored conversation history or transcript, and as part of information derived for learning continuity and personalisation.
Users should avoid providing sensitive personal data that is not necessary for the language-learning interaction.
Klara does not use such information for advertising, the creation of commercial user profiles or purposes unrelated to providing and personalising the language-learning service.
Klara’s backend and application infrastructure are operated using Amazon Web Services (AWS). The primary region is AWS eu-central-1 – Frankfurt, Germany.
Amazon Web Services EMEA SARL38 Avenue John F. KennedyL-1855 Luxembourg
Klara uses MongoDB Atlas for data storage in AWS Frankfurt (eu-central-1). The production configuration is designed to store personal Klara data within the EU/EEA. Cross-region storage outside the EU/EEA is not intended for this data.
The database may contain account, profile, authentication, learning, CEFR, chat, transcript, cross-session memory, subscription, access and campaign information.
AWS S3 is used, among other purposes, for uploaded profile images. These are deleted when the account is deleted, subject to limited technical backup periods and statutory retention requirements.
For the creation and administration of a Klara user account, we process username, email address, authentication information, hashed password information, internal backend user ID, account status and subscription or access status.
Passwords are not stored in plain text. User accounts are not publicly visible. The legal basis is generally Article 6(1)(b) GDPR.
Klara uses profile information to provide and personalise the language-learning service. This may include username, profile image, age range, gender, learning level, app language, target language and language-learning information.
Not all data stored in the Klara profile is transmitted to external AI services. In particular, first name or username, email address, age range and gender are not intentionally transmitted to the external AI services used by Klara.
Klara stores information about your learning progress in order to adapt the learning experience to your abilities and previous activities.
This includes, in particular, CEFR progress values, learning progress, information used to assess the current level, learning history and information derived from previous learning interactions.
This data is generally stored for as long as the user account exists. It is deleted when the user account is deleted or otherwise terminated, unless further retention is required by law.
Artificial intelligence is an essential component of Klara. AI systems are used to understand user input, generate conversational responses, conduct language-learning conversations, adapt conversations to the individual learning level, maintain continuity between sessions, process spoken interactions and provide avatar/video functionality.
Depending on the feature used, the following data may in particular be transmitted to and processed by external service providers:
The conversation context transmitted to external AI systems does not include the entire conversation history stored over the full period of use. The technically transmitted current conversation context is limited to a maximum of the most recent 100 conversation turns.
Before personal conversation or learning data is transmitted for the first time to external AI, speech or avatar services, the user is informed within the app about the data sharing and is asked to give explicit consent.
Under the configuration and agreements applicable to Klara, the external AI, speech and avatar services used by Klara do not use data processed as part of Klara for general model training, advertising or profiling for their own purposes.
Klara does not use artificial intelligence to make automated decisions that produce legal or similarly significant effects for users.
Klara uses Microsoft Azure OpenAI for AI-powered conversations and related functionality.
Depending on the interaction, the following information may in particular be processed:
First name or username, email address, age range and gender are not intentionally transmitted to Microsoft Azure OpenAI.
The Azure OpenAI processing used by Klara is configured for Microsoft’s European Azure infrastructure.
Microsoft does not use conversation data transmitted by Klara to train the underlying AI models or for its own advertising purposes.
For security and abuse-monitoring purposes, certain processed content may be retained for a maximum of 30 days. Where data is retained, the retention relevant to Klara takes place within the EU/EEA.
Klara stores information for cross-session memory in its own backend in order to provide continuity between learning sessions and a personalised learning experience.
This may include, in particular:
The memory is used to take previous learning progress into account, adapt future conversations, avoid unnecessary repetition and continue previous learning topics in a meaningful way.
Relevant parts of this information may be supplied as context to the AI service required for the respective function.
This information is generally stored in the Klara backend for as long as the user account exists and is deleted when the user account is deleted or otherwise terminated, unless statutory retention obligations apply.
Klara stores conversation history in the Klara database. This includes, in particular, text-chat conversations, AI-generated responses and written transcripts generated from spoken input.
The stored information is used to maintain conversational continuity, provide personalised learning, create and maintain cross-session memory, assess learning progress and provide relevant context for future sessions.
Conversation history and transcripts are generally stored for as long as the user account exists. They are deleted when the user account is deleted or otherwise terminated, subject to statutory retention requirements and limited technical backup periods.
Cancellation of a paid subscription does not automatically delete the Klara user account.
Klara allows users to conduct spoken language-learning conversations and requires access to the device microphone for this purpose.
The technical flow may in particular include the following processing:
User → ElevenLabs → AI conversation processing → ElevenLabs → User
The user’s microphone audio is transmitted to ElevenLabs in real time during the conversation and is processed there, in particular for speech recognition, speech processing and conducting the conversation.
Klara does not permanently store raw microphone audio from normal conversations. Klara does, however, store a written transcript of the spoken interaction as part of the conversation history.
This transcript is generally retained for as long as the Klara user account exists and is deleted when the account is deleted or otherwise terminated.
Klara uses ElevenLabs for speech recognition, voice output and agent-related processing of spoken conversations.
Zero Retention Mode is enabled for the production Klara agent.
Under this configuration, conversation content including user audio, transcripts, prompts and AI output is processed only as technically necessary to provide the respective interaction and is not retained by ElevenLabs after processing has been completed.
This does not affect the separate written transcript stored by Klara in its own database.
Under the configuration enabled for Klara, ElevenLabs does not use conversation data processed as part of the Klara service to train general-purpose models, for advertising or for profiling.
Because Zero Retention Mode is enabled for the production Klara agent, no permanent storage of conversation content takes place at ElevenLabs. Personal Klara data is not permanently stored by ElevenLabs outside the EU/EEA.
For certain spoken conversations, ElevenLabs may use external language models as subprocessors within its service. This may currently include Google Gemini.
Klara does not operate a separate direct integration with Google Gemini and does not transmit data directly to Google Gemini.
Where such processing takes place within the ElevenLabs service, it may include the conversation content, transcripts, system instructions and contextual information technically required for the respective interaction.
The Zero Retention configuration enabled for the production Klara agent applies to this processing. Conversation content is not used for general model training, advertising or the creation of unrelated user profiles.
Klara uses Simli AS, Oslo, Norway, to provide real-time avatar animation and lip-sync functionality.
Klara does not transmit the user’s raw microphone audio to Simli.
For an active avatar session, Simli receives only the information technically required to render the avatar, in particular:
Conversation transcripts, profile data and persistent Klara user identifiers are not transmitted to Simli.
Simli has confirmed to us that the TTS audio stream and the resulting avatar video are processed solely in real time and are not stored.
Simli retains only technical session logs for a maximum of 30 days. They are then deleted.
These session logs are stored exclusively within the EU/EEA. Personal Klara data is not stored by Simli outside the EU/EEA.
The TTS audio and avatar video processed on behalf of Klara are not stored or used for model training, advertising or profiling.
Depending on the feature used, Klara may request device permissions, in particular microphone access for spoken conversations and access to photos or files for selecting or uploading a profile image.
Granting such permissions is voluntary. You can change or revoke permissions at any time in your device settings. Certain features may not be available without the permissions required for them.
Profile images are stored using AWS S3 within the European infrastructure used by Klara and are associated with the respective user account. They are generally stored until replaced or deleted, or until the user account is deleted, subject to limited technical backup periods and statutory retention requirements.
Klara may offer users free trial periods or time-limited promotional access.
Where a free trial is provided directly by Klara, the app informs users about the scope and duration of the trial before it begins. Such a trial does not automatically convert into a paid subscription unless this is explicitly stated before the trial begins and confirmed through the relevant app-store subscription process.
Free or discounted access to otherwise paid digital functionality may be provided on iOS through Apple’s In-App Purchase, offer or Offer Code mechanisms. The applicable terms, duration and any renewal conditions are displayed as part of the relevant App Store process.
In connection with trials or promotional access, Klara processes, in particular, information about the start, validity and end of the access period and, where applicable, offer or transaction information provided by the relevant app store.
A trial start may be recorded as an analytics event where the appropriate consent has been provided.
Individual paid Klara subscriptions may be purchased through the Apple App Store or Google Play. Payment processing is carried out directly by Apple or Google.
Klara does not receive or store full credit-card numbers, bank-account numbers, security codes or comparable payment information provided by users to Apple or Google.
We receive only the information necessary to provide and manage the purchased access. This may include, in particular:
The respective terms of the Apple App Store or Google Play also apply to purchases and subscriptions.
Companies and other organisations may purchase or provide Klara access for eligible employees or other authorised persons.
To provide and manage such access, we may in particular process:
Personal learning content, conversation history, transcripts or cross-session memory information are not disclosed to an organisation merely because that organisation finances or provides access, unless there is a separate legal basis and transparent information to the user.
Klara uses Firebase Crashlytics, a service provided by Google, to detect and resolve crashes, technical errors and stability problems.
The following data may in particular be processed:
Username and email address are not intentionally transmitted as Crashlytics report fields.
Crash data is retained for a limited period in accordance with the configuration used and is then deleted or otherwise processed in accordance with the service settings.
Klara may use Firebase Analytics to understand how the application is used, make technical and functional improvements and measure the effectiveness of certain features.
Analytics for purposes that are not technically necessary is used only where the appropriate consent has been provided.
With the appropriate consent, the following may in particular be processed:
Analytics consent is not required to use Klara’s core service and may be withdrawn at any time with effect for the future.
Klara may use AppsFlyer to measure the effectiveness of marketing activities and understand which campaign or source led users to Klara.
Depending on consent, device settings and the requirements of the relevant operating system, the following data may in particular be processed:
Where tracking consent is required, the processing is based on Article 6(1)(a) GDPR. On Apple devices, we also observe the requirements of App Tracking Transparency.
Klara may process identifiers associated with referral links, marketing campaigns, influencers, events, promotional offers or corporate access.
Such identifiers may be used, in particular, to determine whether a specific source led to a registration, trial or subscription.
The information may be used for:
On iOS, such an identifier does not independently unlock paid digital functionality. Where free or discounted access to paid digital functionality is offered, access on iOS is granted through the mechanisms provided by Apple for this purpose.
Referral, campaign and offer information is not used to determine language proficiency or CEFR classification.
If you contact us by email, contact form or another communication channel, we process the information necessary to handle your request.
Account-related communication is generally based on Article 6(1)(b) GDPR. Other enquiries may in particular be based on Article 6(1)(f) GDPR.
When you access our website, technically necessary information is processed in order to provide the website, ensure security and detect technical errors.
united-domains AGGautinger Straße 1082319 StarnbergGermany
Our website is based on WordPress and may use WordPress-related services, extensions and technical components.
Our website and, where applicable, our application may use cookies, local storage technologies or comparable technical methods.
Technically necessary technologies may in particular be used to provide requested functions, ensure security, manage sessions and store user preferences.
Other technologies may be used for analytics, marketing measurement and campaign attribution. Where consent is legally required, such technologies are used only after consent has been provided.
We maintain profiles on social networks, in particular Instagram, Facebook, TikTok and YouTube, in order to provide information about Klara and communicate with interested persons and users.
When using these platforms, personal data may be processed independently of Klara by the relevant platform provider. The privacy policies of the respective platform operators also apply to this processing.
If you contact Klara directly through a social network, we process the information necessary to handle your message.
We use external service providers where this is necessary for the operation, provision, security and development of Klara.
Depending on the function used, these may include providers in the following categories:
Service providers receive only the information necessary for the relevant purpose and technical function.
Where service providers process personal data on our behalf, we enter into the contractual arrangements required by applicable data protection law.
Third parties to whom Klara transmits personal user data are required to protect that data to the same or an equivalent level as described in this Privacy Policy and required under applicable data protection laws.
Under the technical configurations and applicable agreements used for Klara, the AI, speech and avatar services used for Klara’s core functions do not use data processed as part of Klara for advertising, profiling or the training of general-purpose AI models.
Klara’s core backend, primary database and the permanent storage of conversation, learning and profile data required for the language-learning service are located within the EU/EEA.
For the AI, speech and avatar features used by Klara:
Where other service providers used by Klara process personal data outside the EU/EEA, this takes place only in accordance with the applicable data-protection requirements. Appropriate safeguards may include, in particular, adequacy decisions, the EU-US Data Privacy Framework, Standard Contractual Clauses or other legally recognised safeguards.
We generally retain personal data only for as long as necessary for the relevant purpose, unless longer retention is required or permitted by law.
Account and profile data are generally stored for as long as the user account exists. They are deleted when the user account is deleted or otherwise terminated, unless statutory retention obligations apply.
This information is generally stored until the user account is deleted or otherwise terminated.
Text conversations, AI responses and stored transcripts of spoken conversations are generally stored in the Klara backend for as long as the user account exists.
Klara does not permanently store raw microphone audio from normal conversations.
Zero Retention Mode is enabled for the production Klara agent. ElevenLabs does not permanently retain conversation audio, transcripts, prompts or conversational outputs after the relevant processing has been completed.
Certain content processed for security and abuse-monitoring purposes may be retained for a maximum of 30 days. The retention configured for Klara takes place within the EU/EEA.
The TTS audio stream transmitted by Klara to Simli and the resulting avatar video are not stored. Technical session logs are stored for a maximum of 30 days within the EU/EEA and are then deleted.
Crash, analytics and attribution data are processed in accordance with the relevant technical configuration, consent provided and applicable retention rules and are subsequently deleted or anonymised.
Profile images are stored until replaced or deleted by the user or until the user account is deleted.
Information that must be retained under tax, commercial, contractual or other legal requirements may be stored for the applicable statutory retention period.
Users may delete their Klara account within the app or request deletion of the account.
When the user account is deleted or otherwise terminated, active Klara records are generally deleted. This includes, in particular:
Secured backup copies may remain for a limited technical period. Information subject to statutory retention requirements may be retained until the applicable statutory retention period expires.
Deleting the Klara user account does not automatically terminate a subscription purchased through the Apple App Store or Google Play. Such a subscription may need to be cancelled separately through the relevant app store.
Consent to the transmission of personal data to external AI, speech or avatar services may be withdrawn at any time with effect for the future through the privacy settings in the app.
After withdrawal, no new personal data will be transmitted to the affected external services. Functions that technically require those services will no longer be available unless consent is granted again.
Withdrawal does not affect the lawfulness of processing carried out on the basis of consent before the withdrawal.
Where age range or gender has been set as an analytics user property on the basis of the relevant consent, these properties are reset on logout where technically provided for.
This is intended to prevent subsequent logged-out app activity from continuing to be linked to these properties of the Klara user profile.
This does not necessarily result in the retroactive deletion of analytics data that has already been lawfully processed. Analytics consent may be withdrawn at any time with effect for the future.
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, disclosure, destruction and misuse.
Where appropriate for the relevant processing, these measures include, in particular:
Where the GDPR applies, data subjects have, subject to the statutory requirements, in particular the following rights:
To exercise your rights, you may contact us using the contact details provided in Section 2.
Where Swiss data protection law applies, data subjects are entitled to the rights provided thereunder. These may include, in particular, access, rectification, deletion or destruction, objection to certain processing activities and the release or transfer of personal data in a commonly used electronic format.
International data transfers under Swiss data protection law are carried out in accordance with the applicable statutory requirements.
Certain personal data is required in order to use individual Klara features.
In particular, the following are required:
The use of external AI, speech and avatar services is technically required for certain Klara core functions. Before personal conversation or learning data is transmitted for the first time to such services, the user is informed about the data sharing and asked to provide explicit consent.
If such consent is not provided or is later withdrawn, the functions dependent on those services cannot be used.
Other information and consents are optional. In particular, analytics or marketing consent is not required to use Klara’s core service.
We may update this Privacy Policy, in particular where functions, service providers, technical infrastructure, retention configurations or legal requirements change.
The version made available through Klara or on our website at the relevant time applies. Where a change requires renewed consent or individual notification, we will obtain the relevant consent or inform the affected users accordingly.
“Personal data” means any information relating to an identified or identifiable natural person.
“Processing” means any operation performed on personal data, including in particular collection, storage, use, transmission, analysis, alteration and deletion.
“Content data” includes information provided or generated while using Klara, in particular text, transcripts, images, audio and other conversation-related information.
“Learning data” includes information about language-learning activity, proficiency level, progress, assessments and CEFR-related development.
“Cross-session memory” means summarised information from previous Klara interactions that is stored in order to provide continuity and personalisation in future learning sessions.
“External AI services” means third-party services used by Klara for AI-based conversation processing, speech recognition, voice output or avatar functionality.
