Privacy Policy

Effective Date: 03/30/2026

This Privacy Notice explains how Tellem Technologies, LLC (“Tellem”, “tellem”, “we”, “us”, or “our”) collects, uses, shares, and otherwise processes personal data in connection with our websites (the “Sites”), the Tellem application (the “App”), and the related content, platforms, services, products, and other functionality offered on or through our services (collectively, the “Services”). This Privacy Notice does not address our privacy practices relating to Tellem job applicants, employees, and other personnel. Please note that this Privacy Notice is not a contract and does not create any legal rights or obligations beyond those that may otherwise exist under applicable law.

1. Who We Are

Company Name	Tellem Technologies, LLC
Registered Office	131 Continental Dr, Suite 305, Newark, DE 19713, County of New Castle, USA
Data Protection Officer	Hendrik Schuette (team@tellem.org)

Tellem serves as the controller of the personal data we collect, meaning we determine the purposes and means (the “why” and the “how”) of the processing of personal data in connection with our Services. Where we process data on behalf of our customers or third parties (for example, if you interact with our Services through another organization using Tellem’s platform), we act as a processor (also sometimes called a “service provider”) under contractual restrictions. If you have questions about such processing, please refer to the privacy policy of the relevant customer or business partner.

2. What Is Personal Data?

When we use the term “personal data” in this Privacy Notice, we mean any information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) to a particular person or household. Personal data does not include aggregated, de-identified, or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to a person.

3. Personal Data We Collect and Process

We collect and process various types of personal data in connection with the Services. Providing certain personal data is voluntary; however, if you choose not to provide this data, certain features of the Services may be unavailable to you.

3.1 Categories of Personal Data

Category	Examples	Purpose(s)
Account & Registration Information	Name (first, last), email address, encrypted password, etc.	User onboarding, authentication, account management
Usage & Activity Data	Chat messages, user input data, app/website interactions, IP address	Providing and improving AI services, analytics, and security, including generative AI and machine learning tools that may be integrated into our Services
Payment Information	Payment details (processed via Stripe or other third-party providers)	Transaction processing and billing
Communications Data	Messages sent via our Services or to our support channels	Customer support, inquiries, surveys, marketing, and updates
Technical Data	Device identifiers, security tokens, log files, usage analytics	Fraud prevention, security, service enhancement, personalized user experiences
Voice & Learning Data	Voice recordings, transcripts, pronunciation scores, AI-generated feedback	Providing speaking practice, generating learning insights, and improving learning outcomes
Onboarding & Assessment Data	Questionnaire answers, qualification results	Personalizing onboarding and tailoring the learning experience
Notification Data	Push notification tokens, reminder preferences, scheduled timestamps	Sending reminders and service notifications
Attribution Data	Install source, campaign parameters, device identifiers, IP-based location	Marketing attribution, campaign measurement, fraud prevention

Note: For payment information, Tellem uses third-party providers (e.g., Stripe) to securely process payments. We do not directly store sensitive financial data such as complete credit card numbers.

4. How We Collect Personal Data

4.1 Data You Provide Directly

You may provide personal data to us when you:

Create or manage an account
Enter payment details for transactions or subscriptions
Communicate with us via email, chat, phone, text, or social media
Using the App via the features like AI calls and messages
Consent to optional features, such as analytics
Participate in surveys, marketing activities, or promotional events
Use voice features (for example, speaking practice, voice calls, or pronunciation exercises)
Consent to optional features, such as notifications
Participate in onboarding questionnaires

Some of this data may be processed by third-party service providers when you use specific features of the App (for example, AI chat or voice calls). See Section 9.1 for a detailed breakdown of which providers receive which categories of data, when this occurs, and for what purpose.

4.2 Data Collected Automatically

We may automatically collect certain data from your device or browser when you use our Services, such as IP address, security tokens (e.g., for login sessions), and usage details (e.g., pages viewed, links clicked, time spent on each page). We may also automatically collect device identifiers and attribution information (for example, install source and campaign parameters). We use this data to:

Provide and maintain our Services
Analyze usage patterns to improve performance and user experience
Enhance security and detect fraudulent or malicious activity
Measure marketing performance and install attribution

4.3 Data Collected Through Third Parties

We may receive personal data about you from third parties, such as social media platforms, analytics providers (e.g., Mixpanel and Appstack), or other partners who help us operate, maintain, or market our Services. This may include attribution information such as install source, campaign parameters, timestamps, device identifiers, and IP-derived location.

4.3.1 Third-Party Authentication

We provide the option to sign up and log in using your Google account (“Google Sign-On”). When you use Google Sign-On:

We receive your Google account’s openid, profile and email claims, which include your name, email address, and profile picture URL.
This information is used solely to create and authenticate your Tellem account.
We store this information in our database for as long as your account is active.
You may revoke Tellem’s access at any time via your Google Account’s App permissions.

For details on how Google uses and protects your information, please see Google’s Privacy Policy: https://policies.google.com/privacy

We also provide the option to sign up and log in using your Apple ID (“Sign in with Apple”). When you use Sign in with Apple:

We receive a unique Apple-provided user identifier and, if you choose to share it, your name and email address.
This information is used solely to create and authenticate your Tellem account.
If you select Apple’s private relay email feature, Apple will generate a proxy email address that forwards messages to your personal inbox.
We store this information in our database for as long as your account is active.
You may revoke Tellem’s access at any time via your Apple ID account settings.

For details on how Apple uses and protects your information, please see Apple’s Privacy Policy: https://www.apple.com/legal/privacy/

5. How We Use Personal Data

We process personal data for a variety of business and commercial purposes depending on the nature of our relationship with you, which may include:

Fulfill or meet the reason the information was provided (e.g., contractual obligations, delivering requested Services)
Operate, maintain, administer, and improve the Services, including through AI tools integrated into our Services
Manage our organization and day-to-day operations
Communicate with you, including via email, text message, social media, and/or telephone calls
Request or collect survey responses, including feedback on Tellem, our partners, or our Services
Marketing and advertising, including sending you promotional materials and offers related to our Services or services/products we think you may find interesting
Personalize our Services, remembering your preferences and tailoring your experience
Process payments for our Services
Facilitate customer benefits and services, including customer support
Analyze usage, identify trends, and conduct research and analytics
Improve and develop our products (including training and refining AI or machine learning models)
Test, enhance, update, and monitor the Services, or diagnose/fix technology issues
Maintain safety and security, detect, prevent, and investigate fraud, unauthorized access, or other illegal activities
Enforce our Terms of Use, resolve disputes, carry out our obligations, and protect our rights or the rights and interests of third parties
Comply with contractual and legal obligations, including responding to lawful requests, court orders, and legal processes
Process voice recordings and transcripts to provide automated speech recognition, pronunciation feedback, and learning insights

5.1 Legal Bases for Processing

We rely on several legal bases to collect, use, and otherwise process your personal data, including:

Consent: For certain processing activities (e.g., optional analytics).
Contractual Necessity: To fulfill our contractual obligations and provide the Services you have requested (e.g., user account, payment processing).
Legitimate Interests: For operations necessary to protect our business (e.g., fraud prevention, security, service improvement), taking into account your fundamental rights and freedoms.
Compliance with Legal Obligations: To comply with applicable regulations or legal processes.

5.2 Automated Processing and AI Features

Certain features of the Services use automated processing and artificial intelligence to analyze speech, generate transcripts, provide pronunciation scores, and deliver personalized learning feedback. These processes are used solely to support language learning and do not produce legal or similarly significant effects. If you have questions about automated processing, you may contact us at team@tellem.org.

6. Data Retention

We retain personal data for as long as necessary to fulfill the purposes for which it was collected, plus any additional period required by law or to consider relevant statutes of limitations. The criteria used to determine retention periods may vary based on the legal basis for processing:

Contract: If we process personal data based on a contract with you, we generally retain such data for the duration of the contract and a reasonable period thereafter (e.g., for legal or regulatory compliance).
Legitimate Interests: When processing data based on our legitimate interests, we retain it for a reasonable period to fulfill those interests, taking into account your fundamental rights and freedoms.
Consent: Where data processing is based on your consent, we retain it until you withdraw your consent or until it is no longer necessary to provide the underlying service.
Legal Obligation: If processing is required by law, we retain the data for as long as necessary to meet our legal obligations.
Legal Claim: We may apply a “legal hold” to retain data beyond standard retention periods if we face a potential or actual legal claim, until that claim or threat is resolved.

7. Control Over Your Information

We strive to provide you with meaningful control over the personal data we process. You may exercise these controls in a variety of ways:

Access to Your Device Information
- You can control the Services’ access to certain device information (e.g., microphone, geolocation) via the “Settings” app on your device.
Email Communications Preferences
- You may unsubscribe from promotional email communications by clicking the “unsubscribe” link in each email.
- You cannot opt out of certain transactional or service-related messages (e.g., account verification, changes to our Services, security notices).
Modifying and Deleting Your Information
- If you have an account with us, you can update your information or delete your account by logging into your account settings. Changes may take some time to take effect. You can also contact team@tellem.org for assistance.

8. Cookies and Tracking Technologies

8.1 Cookies We Use

We use cookies, web beacons, and other similar technologies to collect information about your interaction with our Services. These technologies may be mandatory or optional:

Essential/Security Cookie: Required for basic site functionality such as login sessions (security token).
Analytics Cookies: We use Mixpanel and Appstack to helps us understand user interactions and usage patterns, including install attribution and marketing performance measurement.
Tracking Pixels: We use tracking pixels from Meta and TikTok to collect anonymous and aggregated data. These pixels record events such as page views, clicks, and other interactions to:
- Measure the effectiveness of our marketing and advertising.
- Understand user behavior to enhance overall user experience.

We respect “Do Not Track” settings in browsers to the extent feasible within our systems.

8.2 Managing Cookies

Consent & Cookie Management: Non-essential cookies and tracking pixels (including those from Meta, Mixpanel and TikTok) are only activated when you have provided your tracking consent. You may review and change your tracking preferences via your browser settings or our cookie management tool found on inside the footer section of tellem.org.
Browser Controls: You can also disable cookies directly through your browser or mobile device settings. Keep in mind that removing or rejecting cookies may affect the functionality of certain parts of our Services.

9. Data Transfers to Third Parties

9.1 Third-Party Service Providers and Data Shared

We use third-party service providers to operate and improve the Services. The table below describes the primary providers we use, the categories of personal data shared, when such data is shared, and the purpose of the sharing.

Provider	Data Shared	When It Is Shared	Purpose
OpenAI	Chat messages, conversation context, voice recordings (if applicable), speech transcripts	When users engage in AI-powered chat or voice features	Generate AI responses, feedback, and learning content
ElevenLabs	Text to synthesize, generated audio requests, voice-related metadata required for synthesis	During voice playback and call features	Text-to-speech generation
Mixpanel	Usage events, device identifiers, diagnostics data	During app usage	Analytics and product improvement
Appstack	Attribution data, install source, campaign parameters, device identifiers	During app usage	Mobile attribution and marketing analytics
Stripe	Payment-related data required to complete transactions	During purchases	Payment processing
DigitalOcean	Account data, usage data, stored content	During normal operation of the Services	Hosting infrastructure
Google Workspace	Email content and contact information	When communicating with users	Customer communication
Mailjet	Email address and transactional message content	When sending service emails	Transactional email delivery
Meta	Aggregated usage events and attribution data	During marketing and analytics activities	Advertising performance measurement
TikTok	Aggregated usage events and attribution data	During marketing and analytics activities	Advertising performance measurement
Apple (App Store)	Transaction data, subscription status, and limited subscription or service-use information relevant to refund review	When Apple requests information to evaluate a refund request for an App Store purchase	To assist Apple in reviewing refund requests and to comply with App Store requirements

All providers act as data processors on our behalf and are contractually required to apply appropriate data protection safeguards.

By using tellem’s AI-powered chat and voice features, you explicitly consent to the processing of your messages, voice recordings, speech transcripts, conversation context, and optional memory data by OpenAI and ElevenLabs solely for generating responses, providing learning feedback, and operating the Services. You control what information you share during conversations, and memory features can be disabled or cleared at any time in the App’s settings.

We may also share personal data in the following circumstances:

Affiliates and Subsidiaries
- We may share personal data with our corporate affiliates to provide or improve the Services.
Business Transfers
- If we are involved in a merger, acquisition, reorganization, or asset sale, your personal data may be transferred as part of that transaction.
Legal and Regulatory Authorities
- We may disclose personal data to courts, law enforcement, or regulatory bodies if legally required to do so (e.g., in response to a subpoena or court order) or to protect our rights or the rights of others.
With Your Consent
- We may share personal data for other reasons if we have your consent to do so.

10. Your Privacy Rights

Depending on where you reside, you may have certain rights regarding your personal data, including:

Access: Request details of the personal data we hold about you.
Correction: Request that we correct inaccurate data.
Deletion (Right to be Forgotten): Request that we delete your data, subject to legal exceptions.
Objection: Object to the processing of your personal data in certain circumstances.
Restriction: Request that we restrict the processing of your personal data in certain circumstances.
Withdraw Consent: Revoke consent where our processing is solely based on your consent.

To exercise any of these rights, please contact us at team@tellem.org. We will respond in accordance with applicable data protection laws.

11. Children’s Privacy

Our Services are not intended for use by individuals under 18. We do not knowingly collect personal data from minors. If you believe we have accidentally collected data from a minor, please contact us at team@tellem.org, and we will promptly delete it.

12. Data We Process on Behalf of Customers

In some circumstances, we process personal data on behalf of our customers or third parties who use our platform. When we process your personal data under the direction of a third party (the “controller”), that organization’s privacy policy will typically apply to their data practices, and we encourage you to review it. This Privacy Notice applies only to personal data for which Tellem is the controller.

13. Policy Updates

We may update this Privacy Notice from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. If we make changes, we will post the updated Notice on our Services with a new “Effective Date.” We encourage you to review this Notice periodically to stay informed of how we process your personal data.

14. Governing Law and Dispute Resolution

This Privacy Notice and any disputes arising out of or in relation to it are governed by the laws of the State of New York, United States, without regard to conflict-of-law principles. All disputes shall be subject to the exclusive jurisdiction of the state or federal courts located in New York, unless otherwise required by applicable law.

15. Contact Information

If you have any questions or concerns about this Privacy Notice, or if you wish to exercise any of your privacy rights, please contact our Data Protection Officer:

Data Protection Officer: Hendrik Schütte

Email: team@tellem.org

Address: 131 Continental Dr, Suite 305, Newark, DE 19713, United States

Thank you for choosing tellem. We are committed to protecting your privacy.