Kamo CZ
Privacy Policy
This Privacy Policy explains what personal data the Kamo CZ mobile application ("the app", "we", "us") collects, why, and what rights you have. We follow the EU General Data Protection Regulation (GDPR) and Czech data-protection law.
1. Who is responsible (data controller)
The controller of your personal data is:
- Name: Dai Hai Nguyen — registered entrepreneur (OSVČ)
- Business ID (IČO): 09179259
- Registered address: Čenětická 2413/1a, Chodov, 149 00 Praha 4, Czech Republic
- Contact e-mail: support@kamolabs.cz
2. What data we collect
| Category | Examples | Why |
|---|---|---|
| Account | E-mail address; sign-in identifiers if you use Sign in with Apple or Google | Create and secure your account; sync your data across devices |
| Learning data | Words you save, your written and spoken exam answers, scores, progress and mistakes to review | Provide the practice features and track your progress |
| Audio recordings | The voice recording you make during speaking practice | Sent to an AI service to transcribe and give practice feedback. Used only to generate your feedback; processed transiently and not stored against your account. |
| Usage & quota | Counts of AI requests per day, timestamps | Enforce fair-use limits and protect the service from abuse and runaway cost |
| Device security | An Apple App Attest device identifier | Verify requests come from a genuine, unmodified app (anti-abuse). This is a per-device identifier, not advertising tracking. |
We do not use any advertising or analytics tracking SDKs, we do not build advertising profiles, and we do not sell your data. The app does not use the Apple advertising identifier (IDFA) and does not track you across other apps or websites.
3. AI processing of your answers and audio
To give feedback on your writing and speaking, the text and audio of your answers are sent to third-party AI services (see processors below). This happens only when you request feedback. The content is used solely to generate your feedback, is processed transiently, and — to our knowledge — is not used by these providers to train their models. Please do not include sensitive personal information in your practice answers. AI feedback is for study only and is not an official exam result.
Additionally, the learning interests you set in your profile are sent to an AI service (the AI analysis provider listed below) to suggest conversation topics and videos that match them. This uses only the interest labels you choose — not your identity — and happens when you save your profile.
4. Legal bases (GDPR Art. 6)
- Performance of a contract — to provide the app, your account and sync.
- Consent — for sending your audio/answers to AI services for feedback. You can withdraw consent at any time by not using the AI feedback features.
- Legitimate interests — to keep the service secure and prevent abuse and excessive cost (device attestation, usage limits).
5. Who processes your data (sub-processors)
We use the following providers to run the service. They process data on our behalf under data-processing terms:
| Provider | Purpose |
|---|---|
| AI analysis provider | AI evaluation of written/spoken answers and tutor chat |
| Speech-to-text provider | Speech-to-text transcription of speaking answers |
| Google (Sign-In) | Optional "Sign in with Google" authentication |
| Supabase | Account authentication and database hosting of your learning data |
| PowerSync | Syncing your learning data across your devices |
| Google Cloud Run | Hosting our backend service that brokers AI requests |
| Resend | Sending account e-mails (e.g. e-mail confirmation) |
Our backend and database are hosted in the European Union (Google Cloud, region europe-west4; Supabase, EU region). Some sub-processors are based outside the EU/EEA and may process data there; where that happens, transfers rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses.
6. How long we keep your data
- Account and learning data: kept while your account exists. Deleted when you delete your account.
- Usage/quota events: automatically deleted after a short retention window (about 35 days).
- Audio recordings: processed transiently to generate feedback and not retained against your account.
7. Your rights
Under the GDPR you have the right to access, rectify, erase, restrict or object to processing, data portability, and to withdraw consent. To exercise any of these, contact us at support@kamolabs.cz.
You also have the right to lodge a complaint with the Czech supervisory authority, the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), uoou.gov.cz.
8. Deleting your account and data
You can permanently delete your account and all associated data at any time inside the app: Settings → Delete account. This erases your account and your learning data and cannot be undone. You may also request deletion by e-mail at the address above.
9. Security
All network traffic uses encrypted HTTPS/TLS. Requests to our backend are verified with Apple App Attest. Your learning data is protected by row-level security so that only your account can access your rows. We do not embed third-party AI keys in the app.
10. Children
The app is intended for users aged 15 and older (the age of digital consent under Czech law) and is not directed at younger children. If you are under 15, you may use the app only with the consent of a parent or guardian. If you believe a child has provided us personal data without such consent, contact us and we will delete it.
11. Changes to this policy
We may update this policy. Material changes will be reflected here with a new "last updated" date.
12. Contact
Questions about privacy: support@kamolabs.cz.