Version 2.5 · effective 2026-10-11
FizzUp Privacy Policy
1. Who we are
The controller for the processing described in this Policy is DB 77 CUW Sp. z o.o., ul. Żółkiewskiego 31, 87-100 Toruń, Poland, NIP 8792706635, REGON 381680838, KRS 0000755526 (“FizzUp”, “we”, “us”).
Privacy contact: privacy@fizzup.ai.
General support and complaints: support@fizzup.ai.
If a Data Protection Officer is appointed, the contact details will be published in the Legal Centre.
2. Scope
This Policy covers the FizzUp mobile app, website, individual accounts, organisation-sponsored accounts, Family plans, AI features, user communications, payments and support.
FizzUp is intended for adults (18+). Section 14 explains the rules for people who have stated an age under 18.
3. Special B2B rule: the organisation pays for access but does not receive private coaching data
In B2B, an organisation may purchase and assign a FizzUp seat to a user. Funding the seat does not give the organisation access to the user's Private Coaching Layer.
3.1 Organisation administration data
For data needed to create an organisation workspace, invite users, assign seats, bill the organisation or process organisation materials, the roles may be split as follows:
- the organisation acts as controller for data it provides to FizzUp for licence administration or other documented instructions;
- FizzUp acts as processor for that limited scope under the DPA;
- once a user activates their own account, FizzUp may simultaneously process certain account data as an independent controller where necessary to provide FizzUp directly to that user.
An organisation admin sees, by name, only the data needed to administer licences: name or account label, work email, role and department in the organisation, invitation status (with invitation and activation dates), membership status and whether the user has completed onboarding. The admin also sees the title and date of a certificate if the organisation issued one. The admin does not see, by name, the number or duration of sessions, the last-active date or minutes used.
The data visible to the Organisation Admin are described in this Policy and in the Enterprise Terms. The Customer is responsible for establishing an appropriate legal basis and providing required transparency to its employees or contractors. Licence-utilisation data must not be used as the sole basis for a decision concerning employment, pay, promotion, performance evaluation or termination.
3.2 Private Coaching Layer
For the Private Coaching Layer, FizzUp acts as an independent controller. This includes in particular:
- conversations and transcripts;
- comparison-task recordings, saved optionally with the user's consent (up to 7 days);
- language errors, exercise results, educational scoring and recommendations;
- goals, learning plans and coaching memory;
- detailed session history and progress data;
- individualized AI-generated educational inferences.
The organisation, sponsor, manager or licence admin does not receive these data and cannot require them to be disclosed as organisation data. By name, they see only the data listed in section 3.1: identifying information, invitation, activation and onboarding completion. They do not see the number, timing or content of sessions, the last-active date, CEFR level, errors, results, saved phrases, recommendations or AI-generated narratives.
Organisation reporting contains aggregated statistics only. Group results and activity are shown only when the group contains at least 10 active participants. Departments with fewer than 3 people are merged into “other”, and the department breakdown is hidden if subtraction would reveal a group smaller than 10. Reports cover completed weeks or months only.
4. Family
In a Family plan every member has their own independent account. Paying for or managing the plan does not by itself give access to other members' private coaching data.
Without a member's consent, the organiser sees: name or account label, email address, invitation, activation and onboarding status, billing information and the plan settings the organiser assigns to members (for example daily limits, available coaches, quiet hours).
The organiser sees a member's progress (for example estimated level, number of sessions, saved phrases, last activity, activity history) only if the member allows it in the app. The member can withdraw this at any time, with immediate effect. Even with consent, the organiser does not see language errors, conversation content or AI-generated session summaries. A certificate issued by the organiser may show the level and session count at the time it was issued.
If a member has stated an age under 18 in their profile, a parent or guardian decides whether their progress is shared: only the plan owner can see it, and only after guardian consent confirmed through a link sent to the guardian's email address (section 14).
5. Data we process, why and for how long
| Data category | Purpose and legal basis | Basic retention |
|---|---|---|
| account data: email or phone, name, identifier, authentication data, birth year or age band if provided | create and secure the account; Art. 6(1)(b) and (f) GDPR | until account deletion: email, name and login data are then removed and the account record remains as an anonymous marker; the phone number and birth year currently remain in that record — we delete them on request to privacy@fizzup.ai |
| settings, learning plan, progress and learning activity, saved phrases | provide and personalise the service; Art. 6(1)(b) GDPR | until the user deletes them (privacy settings: “Delete now” or a chosen period) or deletes the account |
| coach memory: remembered facts, session summaries, detected language errors and recommendations | coaching continuity and personalisation; Art. 6(1)(b) GDPR | until the user deletes them (privacy settings: “Delete now”, “Never save” or a chosen period) or deletes the account |
| voice-conversation transcripts, conversation text and answer text in comparison tasks | conversation, feedback, history and continuity; Art. 6(1)(b) GDPR | 90 days by default, then deleted automatically; the user can choose “Never save”, “Delete now”, “Delete after review” (at the latest after 90 days), another period, or keeping them until they delete them; after the text is deleted, session metadata, counts and scores remain without the words spoken |
| text chat with the coach | conversation and learning continuity; Art. 6(1)(b) GDPR | until account deletion |
| live conversation audio | transfer to the active AI/speech provider and generate a response; Art. 6(1)(b) GDPR | FizzUp does not store this audio; provider processing follows the applicable contract/configuration |
| comparison-task recordings (“Compare progress”), only if the user turned saving on | playback and comparison of the user's own answers; consent, Art. 6(1)(a) GDPR | up to 7 days, then deleted automatically; earlier if the user chooses “Delete after review”, deletes the recording, withdraws consent or deletes the account; the user can also choose “Never save” |
| organisation data: invitation, seat, activation, onboarding completion | B2B licence administration; Art. 6(1)(b)/(f) for the relevant controller | for the B2B contract and settlement period; the user's private account may continue independently |
| technical data, IP, app version, device, logs | security, diagnostics and abuse prevention; Art. 6(1)(f) GDPR | server logs are kept by the hosting provider under its settings and we do not extend them; the log of administrative actions and security events in our database — currently no automatic deletion period |
| app usage events (product analytics), ratings and comments entered in the app | product improvement and communications; Art. 6(1)(f) GDPR | currently no automatic deletion period, including after account deletion (they stay linked to the deleted account's internal identifier); not used for coaching; we delete them on request to privacy@fizzup.ai |
| WhatsApp messages with FizzUp, if the user uses them: content and phone number | communications; Art. 6(1)(b)/(f) GDPR | currently no automatic deletion period, including after account deletion; we delete them on request to privacy@fizzup.ai |
| consents (including parent/guardian consents and Family progress-sharing consents), their withdrawal and accepted document versions | demonstrate compliance and manage preferences; Art. 6(1)(c)/(f) GDPR | during the account and after deletion as evidence of compliance; currently no automatic deletion period |
| payments, invoices, transaction identifiers | payment, accounting and complaints; Art. 6(1)(b)/(c) GDPR | for the period required by tax/accounting law |
| support and complaints | handle requests; Art. 6(1)(b)/(f) GDPR | currently no automatic deletion period, including after account deletion; on request we delete closed tickets that are not needed for claims |
| marketing: newsletter and commercial email | send communications the user agreed to; consent, Art. 6(1)(a) GDPR and Art. 398 of the Polish Electronic Communications Law — we send marketing email only with prior consent | until consent is withdrawn; evidence of consent and withdrawal for the period needed to show compliance |
| beta list and FizzUp Ideas waitlist (form at fizzup.ai/beta and fizzup.ai/ideas): email, first name (optional), English level, learning goal, preferred language, source (the “how did you hear about us” answer and the link's utm parameters), 18+ confirmation (required: the beta is for adults only, in line with section 14), version and date of accepting this Policy, progress-email consent (yes/no, date), signup and confirmation dates, landing page path | invite the person to the beta or tell them FizzUp Ideas has opened, contact them about it and select people for each wave; steps taken at the person's request before entering into a contract, Art. 6(1)(b) GDPR | unconfirmed signup: deleted automatically at the latest 10 days after signing up (the link works for 72 hours + 7 days); confirmed signup: up to 3 months after the beta ends, never longer than 24 months from signup, or until the person leaves the list (the “Remove my signup” link in the confirmation email or privacy@fizzup.ai), whichever comes first |
| beta list: FizzUp progress emails and invitations to future tests, if the person ticked that consent | send communications the person agreed to; consent, Art. 6(1)(a) GDPR and Art. 398 of the Polish Electronic Communications Law; the address is confirmed by clicking a link (double opt-in) | until consent is withdrawn or the person leaves the list; evidence of consent and withdrawal (without the signup's content) for the period needed to show compliance |
| protecting the public forms (beta list, FizzUp Ideas, account deletion without the app) against abuse: cryptographic hashes (HMAC) of the IP address and email address, attempt time | limit requests per connection and per address; legitimate interest, Art. 6(1)(f) GDPR | 48 hours, then deleted automatically; neither the raw IP address nor the email address is stored in this ledger |
| transactional email: confirmations, sign-in, invitations, billing, account notices | account and service operation; Art. 6(1)(b) GDPR | as account data; copies of sent messages at the email provider (Hostinger) under its settings |
Retention settings in the app. In Profile › Privacy and data the user decides how long we keep their data:
- comparison-task recordings: “Delete after review” by default (at the latest after 7 days); also “Never save” or “Delete after 7 days” — a longer period cannot be chosen;
- transcripts: 90 days by default; also “Never save”, “Delete after review” (at the latest after 90 days), 30 days, 1 year, or keep until the user deletes them;
- coach memory and learning activity: kept until the user deletes them by default; also “Never save”, 30 days, 90 days or 1 year.
Each of these groups also has a “Delete now” button. “Never save” blocks storing new data from the moment it is chosen and deletes data already stored at the next automatic run. The run for transcripts, coach memory and activity happens once a day; for recordings, every hour.
After data are removed from active systems, copies may remain for a limited period in secured backups according to infrastructure-provider schedules and disaster-recovery procedures. Backups are not used as active user profiles. If disaster recovery restores deleted data, the deletion request is re-applied to the extent technically possible and legally required.
6. Loss of a B2B seat and continued relationship with FizzUp
Removing a seat ends organisation-funded access and disconnects the account from the organisation. It does not automatically transfer or delete the user's private history.
After a seat is removed, FizzUp may keep the private account and coaching data independently of the former organisation so the user can:
- receive a new seat in the same or another organisation;
- move to B2C or Family;
- export or delete their data.
The data remain subject to the user's right to deletion and to the periods in section 5 (for example recordings up to 7 days, transcripts 90 days by default). We currently do not automatically delete whole inactive accounts, or accounts after seat loss or subscription end: the account and remaining data stay until the user deletes them. If we introduce automatic deletion of inactive accounts, we will update this Policy and notify users before deletion. After a seat is removed, the former organisation has no access to the private account or coaching data.
7. Voice, transcripts and external AI providers
FizzUp may use different AI model, speech and infrastructure providers. Users use FizzUp features; the underlying provider may change for quality, availability, safety or cost reasons.
Before first using the voice feature, the user receives a clear disclosure that live audio and its transcript are transferred in real time to a third-party AI provider — currently Google (Gemini API) — and confirms that the notice was presented and acknowledged. The same provider analyses the conversation text after the session (assessment, coach memory, learning plan) and recognises and synthesises speech (Google Cloud Speech-to-Text and Text-to-Speech). This confirmation is separate from accepting the Terms. If the user does not complete the required confirmation, the dependent feature will not start. The confirmation is not consent where processing is based on performing the user-requested service.
Live conversation audio passes through the FizzUp server to the provider and is not stored by FizzUp. We store the transcript text under section 5. The only voice recordings we keep are comparison-task recordings — only after the user turns saving on, and for up to 7 days.
Processing necessary to provide the requested feature is generally based on Art. 6(1)(b) GDPR. Where a specific optional feature relies on consent, withdrawal does not affect the lawfulness of prior processing.
8. No model training on private content
FizzUp does not use private conversations, transcripts, recordings or coaching data to train general AI models.
FizzUp requires external services, through available contractual terms and settings, not to use transferred data to train their general/public models where this is supported by the contracted service.
FizzUp may use anonymous or effectively aggregated data to improve teaching methodology, exercise design, content sequencing, product ergonomics and feature effectiveness, provided those data do not allow a specific person or private conversation to be reconstructed.
9. Recipients and providers
We use providers for hosting and database (Railway), AI and speech (Google: Gemini API and Google Cloud Speech), payments (Stripe, Apple, Google Play), sign-in, notifications and email: transactional and marketing email is sent through Hostinger's mail server (SMTP), which also hosts our mailboxes and domain. Google is the only active AI provider; the other AI providers in the registry are approved for possible activation and currently receive no data. FizzUp's servers run in the EU (Railway, the Netherlands). Beta-list and FizzUp Ideas waitlist data is stored in our database at that hosting provider, and the email asking to confirm the address is sent through Hostinger's mail server, like our other transactional email. Only authorised FizzUp team members can access the list. The full registry, including optional providers, is in “Subprocessors and Providers”.
We do not sell personal data. We do not use private conversations for behavioural advertising.
10. Transfers outside the EEA
Where a provider processes data outside the EEA, we use an appropriate lawful transfer mechanism, including an adequacy decision, the EU-US Data Privacy Framework for an eligible recipient, or the European Commission's Standard Contractual Clauses together with a transfer assessment and supplementary measures where needed.
11. Educational profiling and automated decisions
FizzUp may build an educational profile, for example recurring errors, learning pace, preferences and suggested next steps. It is used to personalise learning.
FizzUp does not use this profile to make solely automated decisions that produce legal effects or similarly significantly affect the user. A FizzUp language score is not an official language certificate or an employment decision.
12. Your rights
Subject to the GDPR, users may request access, a copy, rectification, deletion, restriction, portability and may object. Consent can be withdrawn at any time.
Account deletion and data export are available in the app. An account can also be deleted without the app at fizzup.ai/delete-account: after you enter an email address, we send a link valid for 24 hours to the address of the account, and the account is deleted only after you confirm on the FizzUp page. The page does not reveal whether an account with that address exists. To leave the beta list or the FizzUp Ideas waitlist, use the “Remove my signup” link in the confirmation email or write to privacy@fizzup.ai; leaving deletes the signup and keeps only a note without personal data that it was withdrawn. The in-app export does not currently include the text chat with the coach — we provide a copy on request. A deletion request or another data-rights request may also be sent to privacy@fizzup.ai; we may request identity verification before acting on it.
We respond without undue delay, generally within one month. Users may lodge a complaint with the Polish Data Protection Authority (Prezes UODO) or another competent supervisory authority.
13. Security
We use risk-appropriate measures including encrypted transport, access controls, tenant separation, least privilege, security logging, backups, provider review and incident-response procedures.
No information system can guarantee absolute security. Incidents are assessed and notified as required by applicable law.
14. Age
FizzUp is intended for adults (18+) and is not directed at children.
The app does, however, include a parent/guardian consent mechanism. If a user has stated an age under 18 in their profile, the following do not work without guardian consent: purchases, saving comparison-task recordings and sharing progress in a Family plan. The guardian confirms consent by clicking a link sent to their email address (valid for 14 days) and can also withdraw it — withdrawing consent to recordings deletes the saved recordings. Verification consists only of confirming the email address given as the guardian's.
If a guardian contact for notifications has been assigned to a learner's account, the guardian may receive an email about a missed scheduled lesson.
If we reliably determine that a person under 18 uses FizzUp without guardian consent, we may suspend the account and take steps to delete the data in accordance with law.
15. Changes
We may update this Policy as law, product features or providers change. Material changes affecting processing will be communicated in the app or another appropriate channel. The Privacy Policy is a transparency notice; we do not require artificial “consent to the privacy policy” where consent is not the correct legal basis.
The Polish version of this Policy is the reference version in the event of an unintended drafting discrepancy with the English translation. This does not limit rights granted by mandatory law.
The Polish version is the reference version. This English text is a translation; in case of an unintended difference, the Polish version prevails.