Privacy Policy

1. Introduction

As Native, operated by WSA Desenvolvimento Unipessoal Ltda ("we", "our", or "us"), is committed to protecting your privacy and being fully transparent about how your data is collected and used. This Privacy Policy explains how we collect, process, disclose, and safeguard your information when you use our application and website.

By using As Native, you acknowledge that conversations on our platform may be subject to monitoring by artificial intelligence systems, as described in detail in Section 5 of this policy.

2. Information We Collect

We may collect the following types of information:

• Account Information: Name, email address, native language, and the languages you are learning.
• Usage Data: Information about how you interact with the app, including sessions completed, speaking time, topics practiced, and feature usage patterns.
• Conversation Data: Audio and transcript data from your practice sessions. This data is processed in real time by our AI systems for moderation and feedback purposes and may be retained for model improvement, as described in Section 5.
• Performance Metrics: Fluency scores, topic adherence rates, conversation quality indicators, and other learning-related signals generated from your sessions.
• Device Information: Device type, operating system, browser type, and IP address.

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the As Native platform.
• Match you with compatible native speakers based on language, topic, and session history.
• Monitor conversations in real time to detect and respond to harassment, abusive behavior, and off-topic misuse.
• Generate personalized progress reports that surface insights about your fluency, speaking patterns, and areas for improvement.
• Train and improve our AI moderation models and learning algorithms using aggregated and anonymized conversation data.
• Enforce our community guidelines and take action — including temporary or permanent bans — against users who violate them.
• Comply with applicable legal obligations.

4. Data Sharing & Disclosure

We do not sell your personal information to third parties. We may share data with:

• Service Providers: Third-party services that help us operate the platform, including hosting providers, real-time communication infrastructure, and AI processing services. These providers are contractually bound to handle your data only as instructed by us.
• Legal Requirements: When required by law or to protect the rights, safety, and integrity of our users and platform.

5. AI Monitoring & Data Processing

Conversations on As Native may be monitored by artificial intelligence systems. Not every session will necessarily be processed, but those that are will be handled exclusively for the purposes described below. By using our platform, you consent to this possibility. The following explains how AI is used and what happens to your data:

• Real-Time Moderation: Our AI systems analyze conversations in real time to detect harassment, inappropriate conduct, abusive language, and behavior that violates our community guidelines. Users identified as engaging in such behavior may be warned, suspended, or permanently banned.
• Harassment Detection: Conversation patterns are continuously analyzed to identify harassment signals — including repeated unwanted contact, offensive language, and grooming behavior. These detections are used to protect users and maintain a safe environment.
• Model Training & Algorithm Improvement: Conversation data — including transcripts, audio features, and derived metrics — may be used in anonymized and aggregated form to train our AI moderation models, improve our speech analysis algorithms, and enhance the accuracy of our fluency assessment tools. We take reasonable steps to remove or pseudonymize personally identifiable information before using data for training purposes.
• Personalized Learning Reports: Our AI monitors your speaking patterns across sessions — including vocabulary range, topic adherence, fluency progression, and conversation score trends — and uses this data to generate personalized reports that help you understand where you are improving and where to focus next.
• No Third-Party AI Training: Your personal data is not shared with or used to train third-party AI systems outside of As Native's direct service providers.

6. Data Retention

We retain your account data for as long as your account is active. Conversation transcripts and audio data used for moderation may be retained for up to 12 months. Anonymized data used for model training may be retained indefinitely. You may request deletion of your personal data at any time by contacting us at privacy@asnative.com.

7. Data Security

We implement industry-standard security measures including encryption in transit (TLS) and at rest. Access to conversation data is restricted to authorized systems and personnel. However, no method of electronic transmission is 100% secure, and we cannot guarantee absolute security.

8. Your Rights

Depending on your location (including rights under GDPR and LGPD), you may have the right to:

• Access, correct, or delete your personal data.
• Withdraw consent for data processing (note: some processing is required to use the platform).
• Request a copy of your data in a portable format.
• Object to or restrict certain processing activities, including use of your data for AI model training.
• Request information about automated decisions made about you, including moderation actions.

To exercise any of these rights, contact our Data Protection Officer at dpo@asnative.com.

9. Children's Privacy

As Native is not intended for users under the age of 13. We do not knowingly collect personal information from children under 13. If we discover such data has been collected, we will delete it promptly. Users between 13 and 18 should review this policy with a parent or guardian.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the updated policy on our platform and updating the "Last updated" date at the top of this page. Continued use of As Native after changes are posted constitutes your acceptance of the updated policy.

11. Contact Us

If you have any questions about this Privacy Policy or how your data is handled, please contact us at privacy@asnative.com or reach our Data Protection Officer at dpo@asnative.com.
WSA Desenvolvimento Unipessoal Ltda · Av. República do Líbano, 2341, Sala 308, Goiânia — GO, Brazil