Privacy Policy

sylby is a product of Sylby GmbH. This privacy policy will explain how our organization (collectively “sylby”, “us”, or “we”) uses the personal data we collect from you when you use our website and/or our application.

Be assured that the protection of your data has the highest priority for us. As an organization that is built upon AI technology we understand the importance of our role in this regard. 

Table of contents

  • What data do we collect?
  • How do we collect your data?
  • How will we use your data and who do we share it with?
  • How do we store your data?
  • What happens if you opt out of sharing your data with us?
  • Marketing
  • What are your data protection rights?
  • Changes to our privacy policy
  • How to contact us
  • How to contact the appropriate authority

What data do we collect?

We collect the following data from you:

  • your user name, email address and password
  • your native language and voice recordings
  • functional information about our apps performance through crash reports
  • technical information about your device like your operation system, your device’s brand and model, the build number, system version, and the sylby app version
  • app usage and analytics data (e.g. lessons completed or videos watched)
  • your subscription history with sylby 

Please note that we only access your microphone when you actively press the record button in our app and we only collect the recordings that you share with us through the send function in the app. 

We securely store your data on AWS servers located in Germany and subject to European data protection laws.

How we use your data

We collect your data so that we can:

  • process your subscription and manage your account
  • email you with special offers, updates or other updated content (only if you opt in for marketing, you can withdraw your consent at any time)
  • improve our app and our services, including our speech recognition

Your subscription and payments are handled by Google Play Store or Apple App Store, respectively. Please refer to their privacy policies for more information about purchases and how your data is collected and used during that process.

We use your voice recordings and native language in order to enhance our speech recognition model. However, we do not link it to any other kind of personal data that you share with us. We also use your voice recordings in order to provide feedback to you inside the ap . We will not use your recordings for any other than the above stated purposes and we do not share it with any third party. 

In order to manage our app’s performance, crash reports are sent to US-based company Firebase Crashlytics. However, these reports do not include any personal data. Only technical data about devices or the nature of the crash are sent and collected for this purpose. This is the only data that is processed outside of EU borders, however, it cannot be linked to your identity. 

Also, we track your activity in our app like which lessons you have completed or your results in order to visualize and measure your progress. We also track other activities like which videos are being watched or how long it takes users to complete lessons. We use this data in an anonymised way to improve and ensure the quality of our product. We want to provide you the best service we can offer, and do need your help and feedback for it. We use third-party Analytics Service Providers (Mixpanel, Twilio Segment) to monitor and analyze the use of our Service.

Mixpanel is a business analytics service that tracks user interactions with web and mobile applications and provides tools for analysis. For more information about Mixpanel, including how to exercise your rights under the GDPR or the CCPA, please contact Mixpanel directly at https://help.mixpanel.com/.

Twilio Segment is the customer data platform that collects, filters, and controls customer data.For more information about Twilio, including how to exercise your rights under the GDPR or the CCPA, please visit Twilio directly at https://www.twilio.com/.

How we store your data

We securely store your data on AWS servers located in Germany and subject to European data protection laws.

We keep your account information (e.g. your user name, email address and password) for the duration of your subscription until you ask us to delete it. In accordance to European law we have to keep some data for a certain amount of time.

What happens if you opt out of sharing your data?

Using our services requires the collection of your voice recording. Without that, our service will not work the way it is supposed to be. We cannot give you feedback on your pronunciation without your voice recordings.

Legal Basis

 

The storage of your data is based on your consent and is necessary for the performance of the contract, that you want us to fulfil (Art. 6 § 1 lit. a-b GDPR). You can revoke your consent at any time. The legality of the data processing operations already carried out remains unaffected by the revocation.

 

Marketing

We would like to send you information about products and services of ours that we think you might like. Therefore, you can register for our email newsletter. 

If you have agreed to receive marketing, you can always opt out at a later date. If you no longer wish to be contacted for marketing purposes, you can opt out at any time in the profile tab in our app.

We use the services of the German based company rapidmail to send out our newsletter and manage its subscribers. We therefore share your name and email address with them. Please refer to their privacy policy for more information.

 

What are your data protection rights?

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

  • The right to access - You have the right to request us for copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification - You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
  • The right to erasure - You have the right to request that we erase your personal data, under certain conditions.
  • The right to restrict processing - You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • The right to object to processing - You have the right to object to our processing of your personal data, under certain conditions.
  • The right to data portability - You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@sylby.com, or write to us: sylby GmbH, Altensteinstraße 40, 14195 Berlin. 

Changes to our privacy policy

We keep our privacy policy under regular review and place any updates on this web page. This privacy policy was last updated on 27 October 2022. 

How to contact us

If you have any questions about our privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact our data protection officer:

Email us at: privacy@sylby.com

Or write to us at: sylby GmbH, Altensteinstraße 40, 14195 Berlin

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office. For Berlin, Germany, that is the Berlin Commissioner for Data Protection and Freedom of Information:

Email: mailbox@datenschutz-berlin.de

Address: Friedrichstr. 219, 10969 Berlin

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