Privacy Policy

1. Introduction

Welcome to Sobolo AI ("Sobolo AI," "we," "us," or "our"). Sobolo AI is a language translation and learning platform for African languages, operated by Agoo AI LLC, a California limited liability company.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile application, website, and related services (collectively, the "Service"). By accessing or using the Service, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the Service.

We are committed to protecting your privacy and handling your data transparently, particularly given the sensitive nature of voice data and linguistic information. We comply with applicable data protection laws, including the California Consumer Privacy Act (CCPA), the Ghana Data Protection Act 2012 (Act 843), and the European Union General Data Protection Regulation (GDPR) where applicable.

2. Information We Collect

2.1 Information You Provide

• Account Information: When you create an account, we collect your phone number (used for OTP authentication), name, email address (optional), preferred languages, and profile information.
• Payment Information: If you subscribe to a paid plan, we collect payment information through our third-party payment processors (Paystack for mobile money transactions in Ghana; Stripe for international card payments). We do not store your full payment card numbers or mobile money PINs on our servers.
• Voice Data: If you use voice translation features, we process your voice recordings to convert speech to text. Voice recordings used for standard translation are processed in real-time and are not stored after the translation is complete, unless you opt in to voice recording contributions (see Section 2.3).
• Voice Clone Data: If you use the "My Voice" feature (available on the Gold tier), we collect voice samples that you voluntarily provide to create a personalized voice clone. This data is processed by our voice cloning provider and stored in encrypted form. You may delete your voice clone and all associated audio data at any time (see Section 7).
• Learning Data: Your lesson progress, quiz responses, pronunciation scores, and learning preferences.
• Community Contributions: If you participate in the Community Translator program, we collect the translations, corrections, validations, voice recordings, cultural context notes, and proverbs you submit. By contributing, you assign intellectual property rights in these contributions to Agoo AI LLC in accordance with our Terms of Service.

2.2 Information Collected Automatically

• Usage Data: We collect information about how you interact with the Service, including features used, pages visited, translations requested, lessons completed, session duration, and in-app actions. We use Ahoy (self-hosted analytics) and may use third-party analytics services such as Mixpanel or Amplitude.
• Device Information: Device type, operating system, browser type, app version, unique device identifiers, and mobile network information.
• Location Data: We collect approximate location information (country and region) based on your IP address. We do not collect precise GPS location unless you explicitly grant permission for location-based features.
• Log Data: Server logs that include your IP address, access times, referring URLs, and error reports.

2.3 Information from Third Parties

• Social Login Providers: If you sign in using Google, Apple, or Facebook, we receive your name, email address, and profile photo from the respective provider, as permitted by your privacy settings with that provider.
• Payment Processors: Paystack and Stripe provide us with transaction confirmation, subscription status, and partial payment identifiers (e.g., last four digits of a card or mobile money account) for billing and support purposes.

3. How We Use Your Information

We use your information for the following purposes:

• Provide and Improve the Service: Process translations, deliver lessons, track learning progress, calculate gamification rewards (XP, streaks, Sobolo Tokens), maintain leaderboards, and improve the accuracy of our translation and voice models.
• Account Management: Create and manage your account, authenticate your identity via OTP, process subscription payments, and communicate with you about your account.
• Personalization: Customize your learning experience, recommend content based on your proficiency level and interests, and adapt lesson difficulty.
• Community Features: Facilitate the Community Translator program, validate contributions, calculate token earnings, and display leaderboard rankings and contributor titles.
• Model Improvement: Use aggregated and de-identified translation data to improve our machine translation, speech recognition, and text-to-speech models for African languages. Community contributions that you submit through the Community Translator program are used to train and improve our proprietary language models.
• Communications: Send you service-related notifications (lesson reminders, streak alerts, contribution confirmations), account updates, and, with your consent, promotional communications. You can opt out of promotional communications at any time.
• Safety and Security: Detect and prevent fraud, abuse, and unauthorized access; enforce our Terms of Service; and protect the rights, property, and safety of our users and the public.
• Legal Compliance: Comply with applicable laws, regulations, legal processes, and governmental requests.
• Advertising (Free Tier): For Sobolo AI Lite (free tier) users, we display non-intrusive banner advertisements from culturally relevant advertisers via Google AdMob. Ads are never shown during active lessons or translation sessions. Paid subscribers do not see ads.

4. How We Share Your Information

We do not sell your personal information. We share your information only in the following circumstances:

• Service Providers: We share information with third-party providers who perform services on our behalf, including cloud hosting (Railway), payment processing (Paystack, Stripe), voice synthesis (ElevenLabs for voice cloning features), push notifications (Firebase Cloud Messaging), SMS delivery (Arkesel, Twilio), and analytics. These providers are contractually obligated to use your information only as necessary to provide services to us and are bound by confidentiality obligations.
• Community Features: If you participate in the Community Translator program or leaderboards, your chosen display name, language proficiencies, contribution count, token balance, and leaderboard title are visible to other users. Your real name, phone number, and email are never displayed publicly.
• Aggregated and De-Identified Data: We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you, including for academic research purposes and to advance African language technology.
• Legal Requirements: We may disclose your information if required by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, the safety of others, or to investigate fraud.
• Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as a business asset, subject to the promises made in this Privacy Policy.

5. Data Storage and Security

• Storage Location: Your data is stored on servers operated by Railway (cloud hosting infrastructure) located in the United States. Voice clone data is encrypted and stored in cloud storage with AES-256 encryption at rest.
• Encryption: All data is encrypted in transit using TLS 1.3. Sensitive data, including voice clone audio and payment information, is encrypted at rest using AES-256.
• Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis. We employ role-based access controls, audit logging, and regular security reviews.
• Retention: We retain your account information for as long as your account is active. If you delete your account, we will delete or de-identify your personal information within 30 days, except where we are required by law to retain it or where retention is necessary for legitimate business purposes (e.g., resolving disputes, enforcing our agreements). Voice clone data is deleted immediately upon your request or after 12 months of account inactivity. Community contributions (translations, voice recordings) that have been incorporated into our training datasets are retained in de-identified, aggregated form and cannot be individually extracted after processing.

6. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

6.1 All Users

• Access: Request a copy of the personal information we hold about you.
• Correction: Request that we correct inaccurate or incomplete personal information.
• Deletion: Request that we delete your personal information, subject to certain exceptions.
• Voice Clone Deletion: Delete your voice clone and all associated audio data instantly from within the app with one tap. Deletion is irreversible and immediate.
• Communication Preferences: Opt out of promotional communications at any time via the app settings or by following the unsubscribe link in any email.
• Notification Preferences: Manage push notification, email, SMS, and WhatsApp notification preferences in your account settings.

6.2 California Residents (CCPA)

In addition to the rights above, California residents have the right to:

• Know what personal information we collect, use, and disclose.
• Request deletion of personal information.
• Opt out of the sale of personal information. We do not sell your personal information.
• Non-discrimination for exercising your privacy rights.

To exercise your CCPA rights, contact us at privacy@agoo-ai.com.

6.3 European Economic Area Residents (GDPR)

If you are located in the EEA, you have additional rights including:

• Portability: Request your personal data in a structured, machine-readable format.
• Restriction: Request that we restrict processing of your personal data under certain circumstances.
• Objection: Object to our processing of your personal data for direct marketing or where we rely on legitimate interests.
• Withdraw Consent: Where we process your data based on consent, you may withdraw consent at any time.

Our legal bases for processing your personal data include: performance of a contract (providing the Service), legitimate interests (improving the Service, security), consent (voice cloning, promotional communications), and legal obligations.

6.4 Ghana Residents (Data Protection Act 2012)

We comply with the Ghana Data Protection Act 2012 (Act 843). Ghana residents have the right to access, correct, and request deletion of their personal data. You may lodge a complaint with the Data Protection Commission of Ghana.

7. Voice Data — Special Provisions

Given the sensitive nature of voice data, we provide the following additional protections:

• Standard Voice Translation: Voice audio submitted for translation is processed in real-time and is not stored after the translation is delivered, unless you are contributing a voice recording through the Community Translator program.
• Voice Clone ("My Voice"): Creating a voice clone requires explicit opt-in consent with a plain-language explanation. Your voice samples are encrypted at rest (AES-256) and in transit (TLS 1.3). Voice data is processed by our voice cloning provider (ElevenLabs) solely for the purpose of creating your personalized voice. Voice data is never shared with third parties beyond the cloning provider. You can delete your voice clone and all associated audio with one tap in the app. Deletion is irreversible and immediate. Voice clones are automatically deleted after 12 months of account inactivity.
• Community Voice Recordings: Voice recordings submitted through the Community Translator program are used to improve our speech recognition and text-to-speech models. By submitting a voice recording, you consent to its use for model training. Recordings are stored in de-identified form (separated from your account identity) after quality validation.

8. Children's Privacy

Sobolo AI is not directed to children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly. If you believe we have inadvertently collected information from a child, please contact us at privacy@agoo-ai.com.

9. Third-Party Links and Services

The Service may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party service you access.

10. Advertising

Sobolo AI Lite (free tier) users may see non-intrusive banner advertisements served by Google AdMob. AdMob may collect device identifiers and usage data for ad targeting purposes in accordance with Google's privacy policy. We do not share your translation content, learning data, or voice data with advertisers. Paid subscribers (Plus and Gold tiers) do not see advertisements.

You can manage your ad personalization preferences through your device settings:

• iOS: Settings > Privacy > Advertising > Limit Ad Tracking
• Android: Settings > Google > Ads > Opt out of Ads Personalization

11. International Data Transfers

Your information may be transferred to and processed in the United States and other countries where our service providers operate. These countries may have different data protection laws than your country of residence. Where required by applicable law, we implement appropriate safeguards for international data transfers, including Standard Contractual Clauses approved by the European Commission.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy in the app and, where appropriate, by email or in-app notification. The "Last Updated" date at the top of this policy indicates when the latest changes were made. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the revised Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: privacy@agoo-ai.com

Website: https://sobolo.ai

For data protection inquiries specific to Ghana, you may also contact the Data Protection Commission of Ghana at https://www.dataprotection.org.gh.