Privacy Policy

Effective Date: January 1, 2026 • Last Updated: December 15, 2025

1) Who We Are

PhonemeLab (operated by Chamberlin Innovations SASU)
Registered in France • SIREN: 993 523 836
Registered Address: 870 Rue des Thermes, 65130 Capvern, France
Email: support@phonemelab.com

We operate phonemelab.com and related services, including the PhonemeLab pronunciation practice app, teacher/student dashboards, and waitlist/email updates. We are the data controller under the GDPR.

2) What Personal Data We Collect

You Provide

Name and email
School or workspace inputs (class size, goals, languages, etc.)
Responses to practice questions or forms
Communication preferences

Collected Automatically

Browser user-agent and device type
IP address (temp in access logs for security)
Referrer (if available)

AI-Generated Data

When using PhonemeLab, we generate AI feedback, scores, and pronunciation guidance tied to your practice record.

No Advertising Cookies

We do not use advertising or behavioral tracking cookies. Only functional cookies (if any) required for the site to operate.

2.1) Student & Children's Data (COPPA & FERPA)

🛡️ Children's Privacy (COPPA)

PhonemeLab is an education tool intended for use by schools and teachers. We do not knowingly collect personal information directly from children under 13 without school/parental consent.

School Authorization

When a school or teacher utilizes PhonemeLab, they acknowledge that they have the authority to consent to the collection of student data on behalf of parents, as permitted by COPPA (in the US) and GDPR (in the EU).

Data Minimization

We only collect the minimal data necessary for the educational function: Student ID (pseudonymized recommended), audio recordings for pronunciation analysis, and performance scores. We do not build student profiles for commercial purposes.

2.2) Voice Data & AI Processing

🎤 How We Process Audio

When a student submits a recording, the audio file is securely transmitted to our AI processors (Speechace and OpenAI) solely for the purpose of generating feedback (scores, phoneme analysis, transcripts).

✅ No Training on Student Data

We have strict agreements with our AI providers ensuring that your student voice data is NOT used to train their public AI models. Your audio remains your property.

Audio Retention

Audio is stored to allow teachers to review student work (for up to 36 months). Teachers may delete recordings at any time via the dashboard.

3) How We Use Your Data

Generate and deliver practice feedback, reports, and dashboards
Contact you about your submission (optional)
Improve our tools, user experience, and content
Manage business operations and security
Comply with legal obligations

We do not sell your data or use it for advertising.

4) Legal Basis

Consent

When you submit the planner form or join the email list.

Legitimate Interest

Delivering your requested output, securing/maintaining services, and improving accuracy/experience without overriding your rights.

Legal Obligation

Accounting, audit, or compliance with French/EU law.

5) Storage & Transfers

Supabase (EU region) — database and hosting
MailerLite (EU/EEA) — optional email communications
No transfers outside the EU unless protected by GDPR safeguards (e.g., SCCs).

5.1) Authorized Sub-Processors (GDPR Art. 28)

To provide our service, we share strictly necessary data with the following compliant providers:

Provider	Location	Purpose	Training
Supabase	EU	Database, Auth, Storage	N/A
Speechace	US/EU	Pronunciation analysis engine	❌ No model training
OpenAI	US	Transcription & feedback (Enterprise API)	❌ No model training
Lemon Squeezy	US/Global	Merchant of Record, payments, tax	N/A
MailerLite	EU	Transactional emails for teachers	N/A
Cloudflare	Global	Security, CDN, DDoS protection	N/A

6) Retention

Practice submissions and recordings: up to 36 months (delivery, improvement, support, fraud prevention)
Email communications: until you unsubscribe
Server logs: 30–60 days for security, then deleted

You can request deletion at any time.

7) Your GDPR Rights

Access, correct, or delete your data
Object to or restrict processing
Withdraw consent
Data portability
File a complaint with CNIL (France)

To exercise your rights, email privacy@phonemelab.com.

8) Sharing Your Data

We only share data with service providers needed to operate the site (see Section 5.1 for full list). All providers are GDPR-compliant. We do not sell your data or share it with advertisers.

9) Security

HTTPS encryption (TLS 1.3)
Encryption at rest for all stored data
Access controls and least-privilege
Server-side processing and encrypted storage
72-hour breach notification (GDPR compliant)

No system is 100% secure, but we apply industry-standard protections.

10) Contact

Email: support@phonemelab.com
Privacy inquiries: privacy@phonemelab.com
Supervisory Authority: CNIL (France) — https://www.cnil.fr/