SageLens – Privacy Policy and Personal Data Text

Last updated: October 4, 2026 | Effective date: October 4, 2026

Welcome to SageLens, an AI-powered educational technology application and web platform developed and operated by Akram Boudjellal, located in Algeria ("SageLens," "Company," "we," "our," or "us"). SageLens provides interactive conversational AI language tutoring, speech practice, vocabulary retention, and proficiency tracking services ("Services").

As an entity established and operating in Algeria, our personal data processing is governed by Algerian Law No. 18-07 of June 10, 2018 on the Protection of Physical Persons in the Processing of Personal Data (as amended and complemented by Law No. 25-11), and conducted in accordance with the regulatory standards established by the National Authority for the Protection of Personal Data (ANPDP – Autorité Nationale de Protection des Données à Caractère Personnel).

Notice for International Users & Non-EU Entity Statement (GDPR Art. 27): SageLens operates from Algeria and has not appointed a permanent representative within the European Union under Article 27 of the General Data Protection Regulation (EU) 2016/679 ("GDPR"). However, we voluntarily align our data handling with the core substantive principles of the GDPR (transparency, data minimization, purpose limitation, storage limitation, and data security) and applicable provisions of the California Consumer Privacy Act / California Privacy Rights Act ("CCPA/CPRA"). International users may exercise their Data Subject Access Rights (DSARs) directly through our dedicated Data Protection contact at privacy@sagelens.app.

This Privacy Policy explains how we, acting as the statutory Data Controller, collect, process, store, disclose, and safeguard your personal data, and provides comprehensive instructions on how you can exercise your legal rights and request permanent account deletion.

1. Data Protection Principles

We process all personal data in strict compliance with fundamental privacy principles:

Lawfulness, fairness, and transparency: We process data lawfully, with complete transparency regarding our data handling operations.
Purpose limitation: Data is collected only for specified, explicit, and legitimate educational and service-delivery purposes.
Data minimization: We collect only data that is adequate, relevant, and strictly necessary for providing our AI language learning features.
Accuracy: We take reasonable measures to maintain the accuracy and currency of your personal data.
Storage limitation: Data is kept in an identifiable form only for as long as necessary to fulfill the purposes for which it is processed.
Integrity and confidentiality: Data is safeguarded with robust security controls against unauthorized processing, loss, or destruction.

2. Collection of Personal Data & Data Categories

Depending on how you use SageLens, we collect and process the following categories of personal data:

Data Category	Specific Data Types & Description
Identity & Contact Information	Full name, display name, and email address provided during registration or when contacting our customer support team (support@sagelens.app).
Profile & Account Information	User ID, account credentials (hashed passwords), native language, target English CEFR proficiency level (A1 to C2), user avatar, and language learning preferences.
Authentication & Social Sign-In	If you sign in via third-party providers: Google Sign-In: Google User ID, verified email address, display name, and authentication tokens. Apple Sign-In: Apple User ID, relay email address (or direct email if opted in), and identity tokens. We do not receive or store your third-party account passwords.
Audio & Voice Recording Data	When you use our voice tutoring features or pronunciation practice, we request permission to access your device microphone: Audio streams are processed transiently in memory by contracted speech-to-text inference engines to generate real-time transcripts and pronunciation feedback. No Biometric Identifiers or Voiceprints: Voice audio is processed strictly for linguistic transcription and pronunciation assessment. SageLens does not extract, generate, process, or store biometric identifiers, voiceprints, or geometric vocal/facial templates from your recordings. No permanent audio storage: SageLens does not permanently store raw voice recordings on servers. Transient audio buffers are discarded immediately after transcription (within seconds to at most 24 hours in volatile memory). No advertising use: Your voice data is never sold, rented, or used for advertising or marketing profiling. Prohibition & Incidental Processing of Unsolicited Sensitive Data: You are instructed not to speak or share sensitive personal data (e.g., payment details, health data, political opinions, religious beliefs, or national identity numbers) during voice or chat sessions. Because conversational AI features accept open-ended input, any sensitive or special-category personal data you voluntarily disclose during practice is processed purely as an incidental, transient technical necessity to generate your immediate linguistic response. SageLens does not deliberately solicit, profile, or retain such data.
Learning, Educational & Session Data	Conversation transcripts exchanged with the AI Tutor, vocabulary words saved, spaced-repetition quiz scores, planned review schedules, mistake tracking and corrections, session duration, and learning streaks. This data is used solely to provide continuity and personalize your learning journey.
Technical, Device & Security Data	Device type and model, operating system version, app version, browser specifications, language settings, interaction timestamps, crash logs, and push notification tokens (if enabled). At the networking layer (TCP/IP), client IP addresses are processed transiently in volatile memory by web servers and reverse proxies (such as Nginx) strictly to transmit HTTP responses, defend against denial-of-service (DDoS) attacks, and enforce real-time API rate limits. Zero IP Address Storage for Website Visitors: We do not collect or store IP addresses of website visitors in our application database; all website analytics are strictly aggregated and anonymous (broad country, city, and page counts). We never track precise GPS coordinates, nor do we sell or link IP addresses to ad brokers or behavioral profiling.
Customer Transaction Information	Order information, transaction identifiers, purchase date, and subscription status processed via Apple App Store or Google Play Store. SageLens does not collect, process, or store credit card numbers, CVVs, or banking information. Financial transactions are conducted directly and securely through store platform payment systems.

3. Purposes of Processing & Legal Bases (GDPR Art. 6)

Under data protection laws, we rely on the following legal grounds for processing personal data:

Processing Purpose	Legal Basis (GDPR)	Details
Providing Core Educational Services	Performance of a Contract (Art. 6(1)(b))	Creating and administering your account, conducting AI conversational tutoring, generating vocabulary quizzes, computing CEFR progress, and saving session summaries.
Speech & Voice Interaction	Explicit Consent (Art. 6(1)(a)) & Contract (Art. 6(1)(b))	Processing microphone audio in memory to convert speech to text and evaluate fluency. You can revoke microphone permission at any time in device settings.
Customer Transactions & Paid Features	Performance of a Contract (Art. 6(1)(b))	Validating in-app purchases and subscription receipts through store platforms to deliver paid features requested by you.
Security, Fraud Prevention & Network Stability	Legitimate Interests (GDPR Art. 6(1)(f) & Recital 49; Algerian Law No. 18-07)	Ensuring network and information security, detecting abusive or unauthorized inputs, preventing automated brute-force and DDoS attacks, enforcing API rate limits, maintaining server stability, and routing to low-latency infrastructure. Under GDPR Recital 49 and Algerian Law No. 18-07, processing connection identifiers strictly necessary for security and electronic service continuity constitutes a recognized overriding legitimate interest.
Reminders & Push Notifications	Consent (Art. 6(1)(a))	Sending opt-in daily practice reminders, streak alerts, or review notifications. You can disable notifications anytime in app or device settings.
Legal & Regulatory Compliance	Legal Obligation (Art. 6(1)(c))	Complying with accounting, tax, statutory audit, and lawful requests from competent law enforcement authorities.

Zero Data Selling & Profiling Commitment: SageLens does not sell, rent, monetize, or trade your personal data, IP addresses, audio records, or learning progress to data brokers, advertising networks, or any commercial profiling entities. IP addresses are never used for cross-site behavioral tracking.

4. Third-Party Service Providers & AI Processors

To operate SageLens reliably and securely, we engage trusted third-party service providers. These entities process data exclusively on our behalf under strict Data Processing Agreements (DPAs) and confidentiality obligations:

Cloud Hosting & Infrastructure: Contracted third-party cloud hosting and database service providers that maintain our server infrastructure, database storage, and secure user authentication.
Payment Processors & Store Platforms: Apple Inc. (App Store) and Google LLC (Google Play) process in-app transactions and manage subscription billing.
AI Inference & Speech Services: Contracted artificial intelligence providers process conversational prompts, Speech-to-Text (STT), and Text-to-Speech (TTS). Data transferred to AI providers is encrypted, processed transiently in volatile memory, and is not used to train public foundation models.
Application Stability & Telemetry: Contracted application stability and crash analytics providers that monitor errors and optimize software performance without collecting direct personal identifiers.

5. Account and Data Deletion

At SageLens, you may permanently delete your account and all associated data at any time, in full compliance with Google Play Developer Policies and Apple App Store Review Guidelines.

Warning: Account Deletion Is Permanent and Irreversible

When you delete your account, all of the following data is immediately and permanently wiped from our active production systems:

Your user profile, account credentials, and linked OAuth identifiers
All AI tutor conversation history, voice transcripts, and session summaries
Your saved vocabulary words, quiz history, CEFR level assessments, and learning statistics
Your personalized preferences, streak records, and planned daily quizzes
Push notification tokens and device associations

How to Delete Your Account

Option 1: In-App (Instant & Recommended)

Open the SageLens mobile application.
Navigate to the Profile tab on the bottom navigation bar.
Scroll to the bottom of the screen and tap Delete Account.
Read the confirmation prompt and type DELETE to confirm.
Your account, profile, and all associated personal data are instantly and permanently erased from our active servers.

Option 2: Email Deletion Request

If you cannot access the application or have already uninstalled it, you can request manual deletion by contacting our privacy team:

Send an email to: privacy@sagelens.app or legal@sagelens.app
Subject line: "Account Deletion Request"
Please send the request from the email address registered with your SageLens account. Our data protection team will verify and finalize your deletion within 48 hours.

Important Notice Regarding Subscriptions:

Deleting your SageLens account does not automatically cancel active recurring subscriptions purchased through Google Play or Apple App Store. Subscription billing is governed by the platform owners. To avoid unwanted renewals, please cancel your active subscription directly in your device store settings before deleting your account:

Android: Open Google Play Store → Profile Icon → Payments & Subscriptions → Subscriptions → SageLens → Cancel.
iOS: Open Settings → Your Apple ID → Subscriptions → SageLens → Cancel Subscription.

Data Retention Schedule

Account & Learning Profile Data: Retained as long as your account remains active. Permanently deleted from active databases immediately upon account deletion.
AI Tutor Conversation History & Transcripts: Retained for up to 90 days to support ongoing spaced repetition and conversational context, or until account deletion, whichever occurs first.
Voice & Microphone Audio: Processed in volatile memory only; never retained or stored on persistent server storage.
Website Analytics & Zero IP Storage: We do not collect or store IP addresses in our website visitor analytics database. Website traffic records track only aggregate, non-identifiable parameters (broad country and city, page paths, visit duration, and anonymous session IDs). Temporary server-level connection logs (Nginx) used strictly for DDoS mitigation are rotated and automatically deleted within 7 to 14 days by host system log management.
Encrypted Disaster Recovery Backups: Encrypted system snapshots retained strictly for disaster recovery are cycled and completely overwritten within 30 days.

6. Your Privacy Rights

Depending on your jurisdiction (including under GDPR and CCPA/CPRA), you are entitled to the following rights:

Right of Access (Art. 15 GDPR): You have the right to obtain confirmation as to whether your personal data is being processed and request a copy.
Right to Rectification (Art. 16 GDPR): You have the right to request correction of inaccurate or incomplete personal data.
Right to Erasure / "Right to Be Forgotten" (Art. 17 GDPR): You have the right to have your data erased permanently via the app or email.
Right to Restriction of Processing (Art. 18 GDPR): You have the right to request restriction of processing under certain circumstances.
Right to Data Portability (Art. 20 GDPR): You have the right to receive your personal data in a structured, commonly used, machine-readable format.
Right to Object (Art. 21 GDPR): You have the right to object to processing based on legitimate interests.
Right to Withdraw Consent: Where processing is based on consent (such as microphone access or push notifications), you may withdraw consent at any time.
Right to Lodge a Complaint: You have the legal right to lodge a complaint with a competent supervisory authority. In Algeria, complaints may be lodged with the National Authority for the Protection of Personal Data (ANPDP – Autorité Nationale de Protection des Données à Caractère Personnel) via its official platform (https://anpdp.dz). Users in the European Union or other jurisdictions may lodge a complaint with their national data protection authority.

To exercise any of these rights, contact us directly at privacy@sagelens.app.

7. Data Security & Cross-Border Transfers

We implement industry-standard technical and organizational security measures to protect your personal data, including:

Industry-standard cryptographic encryption protocols for data in transit across public networks.
Robust encryption at rest for stored database records and credentials.
Strict principle of least privilege access controls and administrative safeguards.

International Transfers & ANPDP Regulatory Compliance: SageLens operates globally and utilizes contracted cloud and AI inference infrastructure that may be located outside Algeria. In accordance with Articles 43 and 44 of Algerian Law No. 18-07, cross-border data processing is declared to the ANPDP, and we ensure adequate contractual safeguards are executed with international sub-processors, including European Commission Standard Contractual Clauses (SCCs) and robust Data Processing Agreements (DPAs).

8. Children's Privacy

SageLens requires all users to be at least 13 years of age. In strict compliance with child online privacy regulations (including COPPA, GDPR Art. 8, and Algerian Law No. 18-07), we do not knowingly solicit, collect, or process personal data from children under 13.

Minors between 13 and 18 years of age (or under the applicable age of digital consent in their jurisdiction, including up to 16 years in certain European Union member states) may access and use SageLens only with the verifiable authorization and active supervision of a parent or legal guardian. If you believe a child under 13 has provided personal data without parental authorization, please contact us immediately at privacy@sagelens.app so that we can promptly remove the account and permanently delete all associated data.

9. Changes to This Privacy Policy

We may amend or update this Privacy Policy from time to time to reflect changes in our Services, legal obligations, or technical infrastructure. Any modifications will be posted on this page with an updated "Last updated" date.

For material changes, we will provide additional notice through an in-app banner, notification, or email prior to the changes taking effect.

10. Data Controller & Contact Information

If you have questions, feedback, or concerns regarding this Privacy Policy or our data handling practices, please contact our Data Protection team:

Data Controller: Akram Boudjellal (Operating as SageLens)
Country of Establishment: Algeria
Privacy & Data Protection: privacy@sagelens.app
Legal Inquiries: legal@sagelens.app
Customer Support: support@sagelens.app