Privacy notice
Short version: your voice is heard, not kept. Your words stay on your phone. We don’t know who you are.
Draft of 12 October 2026, for review by a solicitor before launch.
Who we are
Spake is made by [legal name and address, solicitor]. We are the data controller. Email privacy@leavingcertorals.ie.
What we collect, and why
| What | Where it lives | How long | Why |
|---|---|---|---|
| Your voice, one answer at a time | On your phone. In our server’s memory for a few seconds while it is processed | On the phone until you delete it. Never stored on a server | So the examiner can hear you |
| The words you said, and the feedback | Your phone | Until you delete them | So you can read and edit them |
| An anonymous account number, your age band, when you gave consent | Supabase, in the EU | Until you delete your account, or 12 months after your pass ends | To know what you are allowed to do |
| How many minutes you practised each day | Supabase, in the EU | 12 months | Fair-use limits |
| A parent’s email address, if you are under 16 | Supabase, in the EU | 30 days after they confirm, then only a hash | To get their consent |
| Purchase records | Apple, Google, RevenueCat | As the stores require | To unlock your pass |
We do not collect your name, email, school, date of birth or location. We never make a voiceprint, and we never try to read how you feel from your voice.
Who processes it
- Deepgram (EU servers): turns French, Spanish and German speech into text. Keeps nothing.
- Microsoft Azure (EU region): turns Irish speech into text, makes the examiner’s voice, checks pronunciation. Keeps nothing.
- Anthropic (Claude): reads the words to write the examiner’s next question and your feedback. No name or identifier is sent. [solicitor: direct API or EU endpoint, spec 14.3]
- Supabase (EU), Cloudflare (EU placement): the account record and the server that connects everything.
- Resend: sends the one consent email to a parent.
Legal basis
[solicitor] Consent for processing your voice, which you give in the app and can withdraw in Settings. Contract for the season pass. Legitimate interest for fair-use counters and error reports, which contain no words you said.
If you are under 16
In Ireland you need a parent or guardian to confirm before we process your voice. The app asks for their email, sends them one link, and waits. They can withdraw at any time from the same email, and processing stops.
Your rights
- Delete everything: Settings → Your data → Delete everything. Two taps. It removes your account on our server and wipes the phone.
- Export: the same screen makes a file of your transcripts and feedback.
- Ask us anything about your data at privacy@leavingcertorals.ie. You can also complain to the Data Protection Commission, dataprotection.ie.
The AI
The examiner is an AI, and the app says so on every screen where it speaks. It gives practice feedback, not an official mark. It never predicts your grade and never comments on how you sounded or felt.