Privacy Policy

1. Controller

For the processing described in this Policy, the controller is the party responsible for operating LizUp, identified in the contact details at the end of this page. Depending on the activity, contracted providers may act as processors or independent controllers.

2. Data we process

We may process data you provide, data generated while you use the platform and technical information required to operate the service.

• Name, email, language, time zone and profile information.
• Credentials and authentication information.
• Enrollments, courses, progress, answers, attempts, scores and rankings.
• Session bookings, support messages, vocabulary diary, portfolio and certificates.
• Speaking audio, transcripts and pronunciation, grammar, vocabulary and context analysis.
• IP address, access date and time, session, browser, device, error logs and security logs.

3. Payments

Payments may be handled by specialized providers. LizUp may receive transaction identifier, amount, currency, status, purchased product and information required for reconciliation. Full card details are generally processed directly by the payment provider.

4. Audio, activities and artificial intelligence

Speaking and other evaluations may process audio, transcripts, answers, activity instructions, rubrics and necessary academic context. Data may be sent to the AI provider enabled for the feature. Integrated providers include Google Gemini and OpenAI; actual use depends on service configuration.

Feedback and level estimates may inform teacher guidance and learning paths. Errors, unavailability, noise and model limitations may affect results. Students can request explanations or review through support, identifying the activity and attempt.

The described purpose is educational. LizUp does not use voice for biometric authentication in the current implementation. Submitting an activity does not authorize publishing recordings for marketing. Provider processing, retention and any provider reuse depend on the service and configuration; details may be requested from the privacy contact.

5. Purposes and legal bases

Data may be processed to create and authenticate accounts, deliver courses and features, track progress, grade activities, calculate assessments, issue certificates, enable live sessions, provide support, process payments, prevent fraud, protect the platform, comply with legal obligations, exercise rights and improve services.

• Contract performance and preliminary procedures requested by the data subject (LGPD, Article 7 V).
• Identified legal or regulatory obligations (Article 7 II).
• Exercise of rights under Article 7 VI.
• Legitimate interests (Articles 7 IX and 10), subject to necessity and balancing of expectations and rights; not a ground for sensitive data.
• Free, informed, specific and withdrawable consent (Articles 7 I and 8) for optional choices. Fraud prevention is a purpose, not a general legal ground.

6. Communications, cookies and similar technologies

Cookies and browser storage support sessions, security, language, theme, sidebar state and tutorials. Clearing them may end a session or reset preferences without automatically deleting scores and activities held in your account.

Embedded players such as YouTube and external services may process technical data under their policies. Manage cookies and microphone permissions in your browser. Nonessential features requiring consent need a specific choice before activation; this notice is not blanket consent for advertising or tracking.

7. Data sharing

LizUp does not sell personal data. Data may be shared with providers required for hosting, databases, storage, streaming, payments, email, technical monitoring and AI, or when needed to comply with legal obligations and protect rights and security. The Pronunciation Lab uses YouTube API Services to embed and control video playback. When a learner plays an example, YouTube and Google may receive technical access data under their own terms and policies. LizUp does not download or rehost YouTube audio or video for this feature.

8. Teachers, administrators and access control

Authorized teachers, administrators and staff may access student academic information and submissions when necessary for their duties. Access must follow role-based permissions and controls.

9. International transfers

International transfers must meet both a processing legal ground and a valid LGPD Article 33 mechanism under ANPD Resolution 19/2024, such as standard contractual clauses where applicable. Terms acceptance and privacy acknowledgement are not specific transfer consent. Actual destinations, recipients, purposes and transfer mechanisms must be disclosed in the operational details below.

10. Retention and deletion

Processing ends under LGPD Articles 15 and 16. Statutory duties, exercise of rights and other lawful retention grounds must be documented and limited to what is necessary. Account closure does not authorize indefinite retention of audio, answers or confirmation evidence. Backups need defined cycles, restricted access and safeguards against improper restoration.

If LizUp meets Article 15 of the Brazilian Internet Civil Rights Framework, application access logs must be retained confidentially and securely for six months, subject to applicable orders and requirements. This is not permission to keep all student content for six months or indefinitely.

The periods below distinguish complete operational data from the minimal academic archive. Placement data needed across enrollments uses the latest known access expiry. Missing dates, pending assessments and retention exceptions require assessment and regularisation, not indefinite retention. Erasure includes applicable storage and providers. Backups require effective cycles and deletion replay before reopening a restored system.

Os áudios de exercícios e nivelamento são conservados durante o acesso contratado ao curso e por até 180 dias após seu término, para avaliação, comparação de progresso e revisão. Uploads abandonados, sem atividade enviada, são excluídos em até 7 dias. Respostas completas, transcrições e feedback detalhado são conservados durante o acesso contratado e por até 12 meses após seu término. O arquivo acadêmico mínimo, contendo identificação, curso, período, notas, progresso, diagnóstico de nivelamento e relatório de evolução disponíveis, permanece vinculado à conta para consulta após o término do contrato, com revisão anual da necessidade de conservação e atendimento aos direitos do titular. Conversas de suporte são conservadas por até 365 dias após o encerramento; logs técnicos de diagnóstico, por até 90 dias. Registros de acesso sujeitos ao Marco Civil são conservados por seis meses, quando aplicável. Cópias de dados excluídos da base principal são eliminadas dos backups em até 30 dias, com controles para impedir sua reintrodução em restaurações. Registros contratuais, financeiros e evidências de aceite seguem prazos especificamente fundamentados em obrigações aplicáveis ou no exercício regular de direitos, com revisão periódica. Estatísticas agregadas podem ser conservadas para análise e melhoria da plataforma; sua conservação como dados anônimos depende de não permitirem identificação ou reidentificação razoavelmente possível. Exceções de conservação são documentadas, justificadas, limitadas aos dados necessários e submetidas a acesso restrito.

11. Security and incidents

LizUp adopts technical and administrative safeguards intended to protect data against unauthorized access, destruction, loss, alteration or improper disclosure. No internet-connected system is risk-free. Relevant incidents will be handled and communicated as required by applicable law.

12. Data subject rights

Under the LGPD, data subjects may exercise rights concerning their personal data, subject to applicable legal limitations.

Confirmation and access may be provided immediately in simplified form or through a clear and complete statement within 15 days of the request under LGPD Article 19. The access ticket displays this deadline and does not mean that the request is already fulfilled. Other rights follow applicable deadlines and conditions without charging the data subject.

• Confirmation of processing and access.
• Correction of incomplete, inaccurate or outdated data.
• Anonymization, blocking or deletion of unnecessary, excessive or unlawfully processed data.
• Portability under applicable rules and legal exceptions.
• Deletion of consent-based data subject to Article 16 retention exceptions.
• Information about sharing recipients.
• Information about refusing consent and consequences; easy, free withdrawal.
• Objection to processing without consent when LGPD requirements are breached.
• Review of exclusively automated decisions affecting interests and information on criteria under Article 20.
• Petitions to ANPD and consumer protection authorities where applicable.

13. Children and adolescents

Even with a primarily adult audience, the operator must assess likely access by children and adolescents and their best interests under LGPD Article 14, ANPD Statement 1/2023 and Law 15,211/2025 (Digital Child Protection Act) where applicable. Serving minors requires effective age-appropriate safeguards and responsible adult involvement where required; an adult-audience declaration does not replace these safeguards.

14. Changes and contact

This Policy may be updated to reflect legal, technological or operational changes. Privacy requests and data-subject rights may be submitted to the privacy contact shown at the end of this page. LizUp may request reasonable information to verify the requester's identity.

15. Privacy requests and identification

Contact the privacy channel for access, correction, sharing information, applicable deletion or explanations about automated processing. If no channel is listed, use support provided at purchase. Describe your requested right and related account.

Proportionate identity verification may be needed to prevent disclosure to another person. Never send passwords. The team must explain fulfillment, additional information needed or grounds for limitations within applicable legal deadlines. Petitions to ANPD are available where the law provides.

16. Data in reports and external services

PDFs may include names, scores, diagnostics, comments and learning history. Store them securely and share only with chosen recipients. Copies sent by email or stored elsewhere also depend on those recipients and services.

Your browser controls microphone access. The platform processes files submitted to activities; it does not presume permission for continuous ambient recording or public disclosure of your voice.

17. Purpose limitations and updates

Changes in purpose, new providers or features must be assessed and reflected in this Policy. Updating a notice does not replace any specific permission required.

This page shows a version and revision date. Documents remain accessible from login and student areas, including help and settings.

18. Confirmation records and optional choices

Terms acceptance, privacy acknowledgement and audio/AI notice acknowledgement are separate records. We store the version, language, text and controller details presented, hash, server timestamp and source linked to the account or order. These records support accountability and contract evidence, subject to minimization and limited retention.

Stored versions are not replaced by new text. Students can inspect their history and the confirmed copy in the privacy panel. A new revision may require confirmation; switching language alone does not repeat acceptance of the same revision.

Optional marketing consent is separate, unchecked by default and freely withdrawable without losing lessons. Essential account and contract messages do not depend on this choice. Acknowledging this Policy does not authorize new purposes, advertising, tracking or publication of image and voice.

20. Academic archive and platform analyses

LizUp provides an account-linked academic archive service. Necessary consolidated scores, assessed placement results, progress milestones, certificates and academic opinions may remain available after lesson access ends for consultation and report generation. The preserved archive excludes recordings and complete answers, undergoes an annual necessity review and remains subject to data subject rights. Removal may be requested through the privacy channel, subject to specifically documented retention duties.

Personal data necessary for educational service delivery and student assessment is processed on an appropriate legal basis. Internal analyses using personal data require specific, necessary and proportionate purposes; where legitimate interest applies, purpose, necessity, balancing and safeguards must be documented. Terms acceptance is not blanket consent for any analysis. Expired purposes or periods trigger treatment review without waiting solely for an erasure request.

Platform history analyses use monthly aggregates without names, identifiers, recordings, transcripts or answers. Small cohorts are suppressed, values rounded and student/class queries unavailable. Anonymisation requires reasonably preventing reidentification and ongoing assessment. Removing a name, replacing an ID or retaining a reversible key is pseudonymisation and remains subject to the LGPD.

19. Virtual assistant and team support

Support messages are stored to answer requests and maintain support history. Authorized team members can monitor and take over conversations. When a person takes over or the student requests human help, AI is paused and automatic responses still being generated are discarded.

Before using the assistant, a specific notice is shown and its text, revision and acknowledgement date are recorded. Only the necessary conversation excerpt is sent to the enabled provider (Google Gemini or OpenAI). Human support can be chosen without AI. Do not send passwords, card numbers or sensitive data; this channel does not automatically change grades, payments or rights.

Processing necessary for contractual support uses the applicable legal basis, such as performance of a contract or preliminary procedures requested by the data subject. The notice is not blanket consent for advertising, biometrics or model training. Retention, providers and transfers follow this Policy; team permissions are restricted and audited.