Dialogi — Privacy Policy

Effective date: 15 September 2026

Version: 3.1

This policy explains what personal data we collect when you use the Dialogi app ("the App"), why, on what legal basis, who we share it with, how long we keep it, and your rights.

1. Who is responsible (data controller)

Dialogi App Ltd, company number 517034419, 1006 Itzhak Zuckerman St., Dimona 8615700, Israel ("Dialogi", "we").

Privacy contact: info@dialogiapp.com. We have not appointed a statutory data protection officer; the privacy contact above handles all requests.

Representative in the European Union (Art. 27 GDPR): Prighter Group with its local partners (Prighter EU Rep GmbH, Alcalá 116, 6 izquierda, 28009 Madrid, Spain). Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, or make use of your data subject rights, please visit: https://app.prighter.com/portal/13793982453 (please quote ID-13793982453 in any correspondence). EU/EEA users may contact the representative on any matter relating to this policy, in addition to or instead of contacting us.

2. What data we collect, and whether you must provide it

There is no legal obligation to provide data; providing it is voluntary. If you do not provide required data, the consequence is that we cannot provide the relevant part of the Service.

We do not collect: payment card numbers; precise location; contacts; photos other than the profile picture your sign-in provider shares; biometric identifiers (see Section 4). Google and Apple act as independent controllers for the sign-in service and for purchases, under their own privacy policies.

3. Why we use your data and on what legal basis

Where we rely on legitimate interest, we have assessed that our interest does not override your rights; you may object (Section 9). For users in Israel, processing is carried out with your informed consent given at registration and for the purposes described in this policy, in accordance with Section 11 of the Protection of Privacy Law 5741-1981.

4. Voice data and artificial intelligence

4.1. The tutor is an AI system. Your speech is transcribed and answered by automated AI models operated for us by third-party providers (Section 5). No human listens to your lessons in real time. Our staff may see lesson summaries only to provide support you request, to investigate abuse, or as required by law.

4.2. No biometric identification. We do not create voiceprints and do not use your voice to identify or authenticate you. Voice data is processed only to understand what you said.

4.3. No storage of audio or full transcripts. Audio is discarded after transcription; after each lesson we keep only an automatically generated summary (topics, mistakes, level indication) so the next lesson can build on it.

4.4. Provider training. We use our AI providers under business/API terms under which, to our understanding, they do not use your content to train their models and retain it only briefly for abuse monitoring. We do not use your voice or conversations to train our own models without asking you first.

4.5. No automated decisions with legal effect. Level assessments and lesson recommendations are generated automatically to personalise your practice; they have no legal or similarly significant effect on you and you can ask us to review them.

4.6. Sensitive topics. Please avoid sharing health, religious, political or other sensitive information in lessons. If you do, it is processed only as part of the conversation and is not stored beyond the lesson summary; we do not use it for any other purpose.

5. Who we share data with

We share personal data only with providers that process it on our behalf under data-processing agreements, or where the law requires. We update this list whenever a provider changes.

We do not sell personal data. We may disclose data if required by law, court order or a competent authority, to protect life or safety, to prevent fraud, or in a merger or sale of the business (with notice to you and, where required, your consent).

6. Tracking technologies, analytics and advertising identifiers

6.1. The App does not use browser cookies, but the SDKs above may store identifiers on your device and read device information.

6.2. Analytics (Firebase Analytics and AppsFlyer) help us understand how the App is used. Where your local law (e.g. in the EU) requires consent before non-essential identifiers are stored or read, we ask for it in the App, and you can withdraw it at any time by e-mailing info@dialogiapp.com or through your device settings.

6.3. Advertising attribution (Meta and AppsFlyer) tells us whether an ad campaign led to your install. On iOS this happens only if you allow tracking in the App Tracking Transparency prompt; on Android you can reset or delete your advertising ID in device settings, or e-mail us to withdraw consent. We do not show third-party ads inside the App.

7. International transfers

We are based in Israel and use providers in the United States and the European Union.

• Users in the EU/EEA: transfers to Israel are covered by the European Commission's adequacy decision for Israel. Transfers to the United States rely on the EU-US Data Privacy Framework where the provider is certified, and otherwise on the European Commission's Standard Contractual Clauses with supplementary measures. You may request a copy of the relevant safeguards at info@dialogiapp.com. Data of EU/EEA users held in Israel also benefits from the Israeli Protection of Privacy Regulations (Provisions Regarding Data Transferred to Israel from the EEA) 5783-2023.
• Users in Israel: transfers abroad are made in accordance with the Protection of Privacy Regulations (Transfer of Data Abroad) 5761-2001, to countries with adequate protection or under contractual commitments providing equivalent protection.

8. How long we keep data

9. Your rights

Depending on where you live, you have the right to:

• Access the personal data we hold about you and receive a copy;
• Rectify inaccurate or incomplete data;
• Erase your data ("right to be forgotten");
• Restrict processing in certain circumstances;
• Data portability — receive data you provided in a structured, machine-readable format (EU/EEA);
• Object to processing based on legitimate interest, and to direct marketing at any time;
• Withdraw consent at any time, without affecting processing before withdrawal;
• Not be subject to automated decisions with legal or similarly significant effects (we make none — see 4.5);
• Lodge a complaint with a supervisory authority: in Spain, the Agencia Española de Protección de Datos (www.aepd.es); in any other EU/EEA country, your national authority; in Israel, the Privacy Protection Authority (www.gov.il/he/departments/the_privacy_protection_authority).

EU/EEA users may also submit requests through our representative's portal: https://app.prighter.com/portal/13793982453 To exercise your rights, e-mail info@dialogiapp.com. We respond within one month (extendable by two further months for complex requests, with notice). We may ask you to verify your identity, for example by contacting you through your account e-mail. Exercising your rights is free unless requests are manifestly unfounded or excessive.

Delete your account: Settings › Delete Account in the App, or https://www.dialogiapp.com/legal/delete-account Deleting the account does not cancel an app-store subscription — cancel it in your Apple/Google account.

10. Children

The App is for users aged 16 and over. Users aged 16–17 should use the App with parental approval. We do not knowingly collect data from children under 16 (this is above the digital-consent age in every EU country, including 14 in Spain, and above 13 under U.S. COPPA). If you believe a child under 16 has an account, contact us and we will delete it.

11. Security

We apply industry-standard technical and organisational measures: encryption in transit (TLS) and at rest, access controls and least-privilege access, logging, vendor due diligence and data-processing agreements. No system is completely secure; if a breach is likely to result in a risk to your rights we will notify the competent authority and, where required, you, without undue delay.

12. Users in the United States

If you are a California resident and the California Consumer Privacy Act applies to us , you may have rights to know, delete, correct, and opt out of the "sharing" of personal information for cross-context behavioural advertising. Advertising attribution (Section 6.3) may be "sharing"; you can opt out by declining tracking on the App Tracking Transparency prompt, by resetting your advertising ID, or by e-mailing info@dialogiapp.com, and we honour Global Privacy Control signals where technically detectable. We do not sell personal information and do not knowingly collect data from consumers under 16. We will not discriminate against you for exercising your rights.

13. Changes to this policy

We will post any new version in the App with a new effective date. For material changes we will notify you in advance by in-app notice or e-mail; where a change requires your consent under applicable law, we will ask for it. Updates to the provider list in Section 5 that do not change the purposes of processing are not material changes.

14. Language

This policy is provided in English, Spanish and Hebrew. For users in Spain the Spanish version prevails; for users in Israel using the Hebrew version, the Hebrew version prevails; otherwise the English version prevails.

15. Contact

info@dialogiapp.com · Dialogi App Ltd, 1006 Itzhak Zuckerman St., Dimona 8615700, Israel · EU representative: Prighter Group with its local partners — https://app.prighter.com/portal/13793982453