Privacy Policy

Effective date: 29 September 2026

Welcome to Tutoro! Your privacy is important to us. This Privacy Policy explains what information Tutoro OÜ (“Tutoro”, “we”, “us”) collects when you use the Tutoro app on Android and iOS (the “App”) and our websites tutoro.pro, teams.tutoro.pro and creators.tutoro.pro (the “Websites”, together with the App the “Services”). It also explains why we collect it, who we share it with, how long we keep it and the rights you have. If you do not agree with this Privacy Policy, please do not use the Services.

1. 1. Who we are
2. 2. Information we collect
3. 3. How we use your information
4. 4. Data sharing and third-party services
5. 5. International transfers
6. 6. Data security
7. 7. Your rights
8. 8. Retention of data
9. 9. Cookies and similar technologies
10. 10. Children’s privacy
11. 11. Tutoro for Teams and creators
12. 12. App Store and Google Play
13. 13. Changes to this Privacy Policy
14. 14. Contact us

1. Who we are

The Services are provided by Tutoro OÜ, a company registered in Tallinn, Estonia. Tutoro OÜ is the controller of the personal data described in this Privacy Policy, except where section 11 says otherwise. You can reach us about anything in this Privacy Policy at [email protected].

2. Information we collect

Account information

• Email address: used to create and sign in to your account, and to send you sign-in codes and account messages.
• Name and username: used by your tutor to address you and shown to other learners in leagues and battles.
• Profile picture: optional. It is shown to other learners, and anyone who has its link can open it.
• How you sign in: with Google, with a one-time code sent to your email, or with Facebook where we offer it. We do not keep a password for your learner account.

Profile and onboarding answers

When you start, we ask why you are learning English, what you find hardest, your goals and your interests. Some answers are optional, such as your gender and your age or date of birth. We also keep your app language, your time zone, your daily reminder time and the English level estimated by your placement lesson. We use these answers to choose your course and to personalise your lessons.

Learning activity

Lessons, exercises, stories and vocabulary you complete, your course and level, and your game progress: XP, streaks, Energy, Almases, items, tasks, achievements, league positions and battle results.

Conversations with your AI tutor

The messages you write or dictate in AI Chat, your tutor’s replies, and the corrections and feedback you receive. They are stored with your learning progress so you can continue a lesson and look back at it.

Voice

The App uses your microphone only when you tap to speak, and only after you give permission.

• Speaking to your tutor: your recording is sent to our servers and transcribed into text. We keep the recording privately so you can get pronunciation feedback on what you said. It is kept until you delete your account.
• Dictation in exercises: on Android the audio is streamed from your device directly to Google Cloud Speech-to-Text. On iOS it is recognised by Apple’s speech recognition, which may send the audio to Apple.
• Pronunciation feedback: the recording and the sentence you were saying are sent to our pronunciation-scoring provider.

Camera and your character

If you create your character from a selfie, the photo is analysed on your device to suggest your character’s features. The photo is not uploaded to us. This feature is only for users aged 13 and older.

Purchases

Subscriptions and Almases are bought through Google Play or the Apple App Store. We receive the purchase and subscription records (product, transaction identifiers, status and dates) so we can unlock what you paid for. We never receive your card details.

Device information

Device type, operating system, app version and language, and diagnostic data.

Usage data

How you use the App, such as the features and screens you open, crash reports and performance diagnostics. When the App reports an error to our servers, the report includes your IP address, the app or browser version and your account identifier.

Notifications

If you allow notifications, your device receives a push token from Firebase Cloud Messaging, and we send reminders at the time you choose. You can turn notifications off at any time.

Invite and referral links

When someone opens a Tutoro invite link, we record the visit with the IP address and browser details, and tutoro.pro stores a tutoro_ref cookie for 30 days so that a later sign-up can be connected to the invite.

Location data

We do not collect your precise location. We use your device’s time zone so that daily goals and streaks follow your day, and we keep a general location only if you enter it yourself.

3. How we use your information

We use the information we collect to:

• Provide the Services: run your account, your lessons, your AI tutor, your progress and your purchases, and keep them in sync across your devices. Legal basis: performing our contract with you.
• Personalise your learning: choose your course and level, and let your tutor use your name, goals and interests. Legal basis: performing our contract with you.
• Run leagues and battles: show your username, picture, XP and results to other learners. Legal basis: performing our contract with you.
• Send you messages: sign-in codes and account and purchase messages (performing our contract), and reminders and notifications you have switched on (your consent, which you can withdraw at any time).
• Keep the Services safe and working: prevent fraud and abuse, fix crashes and errors, and improve the App using usage statistics. Legal basis: our legitimate interests.
• Meet legal obligations: for example accounting and tax records, and lawful requests from authorities. Legal basis: legal obligation.

We do not train AI models of our own on your conversations. Your tutor’s corrections and level estimates are learning aids: we do not make decisions with legal or similarly significant effects about you by automated means.

4. Data sharing and third-party services

We do not sell your personal information. We share it only with service providers who help us run the Services, and in the situations listed after the table.

Service providers

Other learners

Your username, picture, level, XP and results are visible to other learners in leagues, leaderboards and battles.

Your employer

If an organisation gives you access through Tutoro for Teams, it sees the limited information described in section 11.

Legal compliance

We may disclose information if required to comply with legal obligations, or to protect the rights, property or safety of our users, the public or Tutoro.

Business transfers

If Tutoro is involved in a merger, acquisition or sale of assets, your information may be transferred as part of it. The new owner would remain bound by this Privacy Policy.

5. International transfers

Tutoro is based in Estonia, in the European Union. Some of the providers listed in section 4 process data outside the European Economic Area. That includes the United States (for example OpenAI, Google, DigitalOcean and Meta) and the People’s Republic of China (DeepSeek). These countries may not offer the same level of data protection as the European Economic Area. We send each provider only what its feature needs. You can ask us about the safeguards that apply to a transfer at [email protected].

6. Data security

We protect your data with measures including encryption in transit and access controls. Voice recordings are stored privately. While we strive for the highest level of security, no transmission or storage method is completely secure.

7. Your rights

Under the European Union’s General Data Protection Regulation you have the right to:

• Access the personal data we hold about you and receive a copy of it.
• Correct data that is inaccurate or incomplete.
• Delete your data.
• Restrict or object to certain processing, including processing based on our legitimate interests.
• Receive your data in a portable format.
• Withdraw your consent at any time, where we rely on it.
• Complain to a data protection authority. In Estonia that is the Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee). You can also complain to the authority where you live.

How to use them:

• Delete your account: in the App, open your Profile, tap the gear icon to open Settings, then tap “Delete account”. See the account deletion guide.
• Clear your learning progress only: Settings, then “Clear Data”. See the data clearing guide.
• Everything else, including a copy of your data: write to [email protected] from the email address linked to your account.
• Notifications: turn them off in the App’s Settings or in your device settings.

We answer requests within one month. We may ask you to confirm your identity first.

8. Retention of data

We keep your data for as long as you have an account, and for the shorter periods below:

• If you start setting up the App but never create an account, that data is deleted after 7 days.
• Sign-in codes expire after 15 minutes.
• The IP address and browser details recorded for an invite link are removed after 90 days.
• Daily activity statistics for Tutoro for Teams are kept for 400 days, for the organisation’s reports.
• Purchase, invoice and tax records are kept for the period accounting law requires.

When you delete your account, we delete your account, profile, learning progress, AI tutor conversations and voice recordings. Some records are kept after that: purchase and invoice records we must keep by law, referral attribution records, and Teams activity statistics until they expire. Copies may also remain in backups for a limited time.

9. Cookies and similar technologies

Our Websites do not use advertising or analytics cookies. They store only what they need to work:

• Your language, theme and cached page content, in your browser’s local storage.
• Your signed-in session on the Teams and creators consoles.
• The tutoro_ref cookie for invite links (30 days), and a short-lived security cookie while a creator connects a social account.

Our Websites load fonts from Google Fonts, so your browser connects to Google’s servers. The App stores your settings and some content on your device.

10. Children’s privacy

Tutoro is not intended for children under 13. We do not knowingly collect personal data from children without verified parental consent. If you believe a child has given us personal data, please contact us and we will delete it.

11. Tutoro for Teams and creators

If your employer gives you a seat

An organisation can give you Tutoro through Tutoro for Teams. Before you take the seat, we ask you to agree, and we record the date and the version of the text you agreed to. While your seat is active, the organisation’s administrator can see:

• The email address they invited, and your username and full name.
• Your seat status, league, English level, XP, days practised, streak and minutes practised.

They never see your account’s own email address, the content of your lessons, anything you said to your tutor, your recordings or your transcripts. They see no activity from before your seat started or outside it.

Organisations

When an organisation buys Tutoro for Teams, we process its administrator’s name, email and phone number, the organisation’s billing details and invoices, and card payments through Stripe. When someone requests a demo, we keep their name, organisation, email, phone number and message to reply to them.

Creators

For creators who join our creator programme at creators.tutoro.pro, we process their email, display name, country and language, the IP address and browser details at sign-up and when they accept terms, the social accounts they connect (handle, profile, video statistics and access tokens), their payout details (PayPal, Wise or bank account) and their earnings. We use this to run the programme, pay creators and prevent fraud. The creator programme terms also apply.

12. App Store and Google Play

We ensure that:

• The data the App collects is described in the App Store “App Privacy” section and the Google Play “Data safety” section.
• Features that need a permission (microphone, camera, notifications) are used only after you grant it, and you can withdraw it in your device settings at any time.
• You can turn off non-essential features that use data, such as notifications.
• No unnecessary data is collected, processed or shared.

13. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in the Services or in legal requirements. The date at the top shows when it last changed. We will tell you about significant changes in the App or by email.

14. Contact us

For any questions or concerns about this Privacy Policy, or to use your rights:

• Email: [email protected]
• Company: Tutoro OÜ, Tallinn, Estonia
• Website: tutoro.pro