Frasa Privacy Policy

This Privacy Policy explains how Frasa, Inc. ("Frasa", "we", "us") collects, uses, shares, and protects information when you use the Frasa mobile application and related services (the "App").

Frasa is an AI-powered language learning and assistance app. It helps you generate language suggestions, translations, role-play responses, vocabulary, practice exercises, and daily suggestions, and it can transcribe your speech and read phrases aloud.

Some Frasa features use third-party AI services. Before using AI-powered features, the App asks for your permission and lists what is sent and to whom before you agree.

2. What we collect and how

Frasa has no accounts and asks for no name, email or phone number. We collect:

• What you type — your messages and the recent chat context, when you use AI features.
• What you say — audio recorded only while you use the microphone.
• What you save — phrases and vocabulary, when they are used to generate suggestions or practice.
• Your learning settings — native language, target language and level.
• An installation identifier. When the App first runs, Apple's App Attest service confirms it is a genuine copy of Frasa on a genuine Apple device, and our server then assigns the installation a random identifier. It is used to apply daily usage limits and to match a subscription to the installation. It is not linked to you and is not an advertising identifier.
• Purchase status, when you subscribe.

All of it is collected inside the app, at the moment you use the feature that needs it. Frasa does not track you across other apps or websites, and contains no advertising or analytics SDK.

4. Who we share it with, and why

Frasa's own server passes your request to the company that fulfils it:

• Google (Gemini) — receives your messages, chat context, saved phrases and learning settings to generate replies, translations and practice, and receives phrase text to speak it aloud in some languages. On Apple Watch, your spoken question goes to Google directly: it is transcribed and answered in a single step.
• ElevenLabs — receives phrase text, the language and the chosen voice to generate pronunciation audio, and receives the iPhone's voice recordings to transcribe them. It never receives your conversation.
• Cloudflare — hosts Frasa's server, which routes the requests above and stores generated speech audio (see below). It does not use your data for its own purposes.
• RevenueCat — receives purchase and subscription events together with the installation identifier, so a subscription can be matched to the installation. No chat, voice or phrase data.
• Apple — handles payment (we never see your card details) and, once per installation, confirms through App Attest that the App is genuine. Apple learns that a copy of Frasa runs on that device, nothing about what you do in it.

Each of these companies acts as our processor and is required to use the data only to perform the service we asked for, and not to sell it.

5. How long it is kept

Your conversations, saved phrases and settings live on your device; deleting the app deletes them. The usage counters and the installation identifier live in the device's secure keychain and survive a reinstall — that is what keeps daily limits fair.

Frasa's server keeps no conversation content and no voice recordings. Per installation it keeps the attestation public key, the subscription tier as last reported by RevenueCat, the times of first and last use, and daily request counts; it also keeps request counts against a one-way hash of the network address (the address itself cannot be recovered from it). Both serve the daily limits. Generated speech — the spoken rendering of a phrase or of a reply — is stored under a content fingerprint with no user identity attached, so a phrase anyone has already listened to plays instantly for everyone; these clips are kept indefinitely. Reminders are scheduled locally on your device; Frasa has no push-notification infrastructure.

Providers retain data under their own policies, linked below.

6. Your choices

AI features are off until you turn them on, and the consent screen lists what is sent and to whom before you agree. You can withdraw consent at any time in Profile → AI & Privacy; AI chat, transcription, pronunciation, daily suggestions and generated practice stop working until you grant it again. The microphone is used only while you are recording.

8. International transfers

We may process information in the United States and other countries where we or our service providers operate.

Where required, we use appropriate safeguards for international transfers, such as standard contractual clauses or other lawful transfer mechanisms.

9. Children

The App is not directed to children under 13, or under 16 in certain jurisdictions. We do not knowingly collect personal data from children.

If you believe a child has provided personal data to us, contact us at dev@frasa.app and we will take appropriate steps.

10. Security

We use reasonable technical and organizational measures designed to protect information.

However, no method of transmission or storage is 100% secure. You should avoid submitting sensitive or highly confidential information into the App.

Provider privacy policies

The companies that process data on our behalf retain it under their own policies:

• Google Privacy Policy
• ElevenLabs Privacy Policy
• Cloudflare Privacy Policy
• RevenueCat Privacy Policy