Loka -- Privacy Policy

Last updated: 2026-05-11
Status: Beta service. This policy may evolve as we expand features and reach.

This Privacy Policy describes what data Loka ("we", "us") collects, how we use it, who we share it with, and the choices you have. By using the Service you agree to this policy and to the Terms of Service.

Spec: [LEGAL-01]

What We Collect

Category	Examples	Why
Account	Email, password hash, signup timestamp, account-acceptance timestamp	Authentication, account management
Profile	Preferred L1 (your first language), preferred L2 (the language you study), CEFR estimate, voice preference	Personalizing the tutor to your level
Voice	Microphone audio you send during sessions; transcripts of that audio	Realtime conversational practice
Learning state	Tasks attempted, breakdowns detected, items addressed, session outcomes	Adapting the curriculum to you
Analytics	Anonymous browsing events (signup_started, task_completed, etc.); aggregate profile properties (CEFR estimate, L1, L2)	Product improvement; measuring whether Loka actually helps

What We Do NOT Collect

We do not collect or store PII (email address, name) in our analytics profile data. The PostHog person profile carries only language and CEFR fields.
We do not track you across other websites; we use no advertising cookies or third-party trackers beyond the processors listed below.
We do not geolocate you by IP.
We do not sell your data to advertisers or data brokers.

Third-Party Processors

Loka uses the following third-party service providers to operate. By using Loka you consent to data flowing to these providers for the stated purposes.

Processor	What we send	Purpose	Notes
OpenAI (`gpt-realtime` Realtime API)	Microphone audio (live streamed); transcripts of voice turns; structured instructions for the AI tutor	Real-time conversational AI	OpenAI's API terms govern their handling. Audio is processed for inference; not used to train OpenAI models by default.
Google Gemini (`gemini-2.5-flash`)	Text-only payloads: task transcripts (post-session); structured prompts for re-task generation and post-session evaluation	Re-task generation; post-session evaluation	Google's API terms govern their handling. Text-only; no audio.
PostHog (analytics)	Anonymous event names + non-PII properties (e.g., `app_version`, `cefr_estimate`, `signup_method`, `task_id`)	Product analytics, funnels, retention measurement	No email, no name, no IP on the person profile. Hosted on PostHog Cloud (US region).
Railway (hosting)	Server-side application data: account records, learner-model rows, session logs, atomic-item states	Application hosting and database persistence	SQLite database stored on the Railway container volume; session logs stored as JSON files on the same volume.

How Long We Keep Data

Account and learner-model data: as long as your account is active.
Session logs and transcripts: retained for evaluation, debugging, and product improvement during the beta period. We may pilot retention windows post-beta.
Analytics events: per PostHog's data-retention defaults.

Deleting your account permanently removes your learner-model data, session history, session logs, and atomic-item state from our database.

Your Rights

Access: contact us to request a copy of the data we hold about you.
Deletion: use the in-app account-delete affordance (forthcoming in a subsequent release) or contact us. Deletion cascades through all our systems described above.
Correction: edit your profile (L1, L2, voice, CEFR) at any time via the in-app settings (forthcoming).

For GDPR / CCPA / similar rights in your jurisdiction, contact us using the address below. We do not currently have a Data Protection Officer; in the interim, requests are handled directly by the project owner.

Children

Loka is not directed at children under 13. We require you to confirm you are 13 or older at signup. See the Terms of Service for the age requirement.

Cookies and Local Storage

Loka uses:

A first-party session cookie (volley_session) to keep you signed in.
LocalStorage / cookies (set by PostHog's browser SDK) to keep an anonymous browsing identifier stable across page reloads. This identifier is not linked to PII.

No third-party ad or tracking cookies are used.

Changes to This Policy

We may update this policy as the product evolves. Material changes will be communicated by email or in-app notice. The "Last updated" date at the top reflects the most recent revision.

Contact

Privacy requests, questions, or concerns: guan@volley-flow.com