Privacy Policy

Gabb Global Corporation ("Gabb", "we", "us") builds a language learning platform used by schools and by individual learners. This policy explains what we collect, why, who we share it with, and how to get it removed.

We wrote this to be read. If anything here is unclear, write to privacy@gabbglobal.com and we will explain it in plain terms.

Who this policy covers
This policy applies to everyone who uses Gabb: students, teachers, school administrators, and individual subscribers. Where a school or district has signed an agreement with us, that agreement governs how we handle student data, and it takes precedence over this policy wherever the two differ.

What we collect
Information you give us
Account details: name, email address, the class or school you belong to, and your role.
For paid individual accounts, billing details. Payment card numbers are handled by our payment processor and never stored on our systems.
Voice recordings
Gabb teaches speaking. When a learner completes a speaking exercise, we record their voice and analyse it to score pronunciation at the level of individual sounds. This is the core of what the product does.

Recordings are processed by us and by our speech analysis provider to produce a score.
We retain recordings for [retention period], after which they are deleted.
We [do / do not] use learner voice recordings to train or improve machine learning models. [If you do, this needs separate, explicit consent and should be stated here in full.]
Learning activity
As a learner works, we record what the product needs in order to adapt: accuracy on each item, how long a response took, hesitation before speaking, retries, time spent in a session, and which level the learner is working at. We use these signals to adjust difficulty in real time and to show teachers who needs help.

These are measures of activity in a lesson. They are not a psychological, medical or clinical assessment, and Gabb does not diagnose learners or produce any clinical finding about them.

Device and usage information
Device type, browser, operating system, approximate location derived from IP address, and error logs. We use this to keep the service working and to investigate problems.

Children's information
Gabb is used in schools by students under 13. We take that seriously.

Schools consent on behalf of parents. Where a school or district signs up for Gabb, the school provides consent for its students under the Children's Online Privacy Protection Act, acting as the parents' agent. We require schools to give parents notice of what we collect and to obtain parental consent where their own policies or local law require it.
We use student data only to provide the service to that school. We do not build advertising profiles, we do not sell student data, and we do not use it for any purpose other than delivering and improving the educational service the school has purchased.
Student records. Where student information forms part of an education record under the Family Educational Rights and Privacy Act, Gabb acts as a school official with a legitimate educational interest and follows the school's direction on its use and disposal.
Individual accounts are for adults. Our direct consumer subscription is not offered to children under 13. A parent or guardian may create an account and supervise a child's use of it.
Deletion on request. A parent, guardian or school may ask us to delete a student's information at any time. Write to privacy@gabbglobal.com and we will action it within [number] days.
How we use information
To deliver lessons, score speech, and adapt difficulty to the learner.
To show teachers and school administrators how their students are progressing.
To operate, secure, troubleshoot and improve the service.
To communicate with account holders about the service.
To produce aggregated, de-identified statistics about how the product is used. Aggregated data never identifies an individual learner and is not reversible.
We do not sell personal information. We do not share it with advertisers. We do not use it to target advertising.

Research
Gabb runs studies with schools and research partners to measure whether the product works. Where we do:

Participation is agreed with the school or institution in advance.
Data used in research is de-identified unless a participant or their school has specifically agreed otherwise.
Studies involving identifiable data about minors are run under the oversight the partner institution requires, including ethics review where applicable.
Who we share information with
We share only what a provider needs to do its job, and only with providers bound by contract to protect it.

Provider	What it handles
[Speech analysis provider]	Pronunciation scoring from voice recordings
[Hosting provider]	Application hosting and database storage
[Authentication provider]	Sign-in and account security
[Payment processor]	Billing for individual subscriptions
[Audio generation provider]	Recorded pronunciation examples in lessons
We also share information when the law requires it, and we may transfer it as part of a merger or acquisition, in which case we will give notice before any personal information becomes subject to a different policy.

Where information is stored
Gabb is operated from the United States and information is stored on servers in [country or region]. If you use Gabb from outside that region, your information is transferred there. Where we work with schools outside the United States, we apply the additional protections that local law requires, and we will say so in the agreement with that school.

How long we keep information
Account information: for as long as the account is active, and [period] afterwards.
Voice recordings: [period].
Learning activity: for the duration of the school's agreement with us, then deleted or returned at the school's direction.
Billing records: as long as tax and accounting law requires.
Your rights
You can ask us to show you what we hold about you, correct it, delete it, or send you a copy. Schools can make these requests on behalf of their students, and parents can make them through their school or directly to us.

Depending on where you live you may have further rights, including under the California Consumer Privacy Act or the General Data Protection Regulation. We apply the same process to every request regardless of where it comes from. Write to privacy@gabbglobal.com.

Security
We protect information in transit and at rest with encryption, restrict access to the small number of people who need it, and separate each school's data so one school cannot see another's. No system is perfect. If a breach affects your information we will notify you and any required authority within the time the law allows.

Changes to this policy
If we change this policy in a way that materially affects how we handle personal information, we will give notice by email to account holders and post the change here before it takes effect.

Subscription Terms
Effective [date].

These terms apply when you subscribe to Gabb as an individual. If your school or district has signed an agreement with us, that agreement governs your use and these terms do not apply to you.

The service
Gabb gives you access to language learning lessons, speaking exercises with pronunciation feedback, and progress tracking, on the plan you have chosen. We add and change features over time. If we remove something significant from your plan, we will tell you before it happens.

Plans and pricing
Plan	Price	Billed
Monthly	[$15]	Every month
Annual	[$150]	Once a year
Prices are in US dollars and exclude any tax that applies where you live. If we change the price of your plan we will give you at least 30 days' notice by email, and the new price takes effect at your next renewal.

Billing and renewal
Your subscription renews automatically at the end of each billing period until you cancel.
We charge the payment method on file on the renewal date.
For annual plans, we email a reminder at least [number] days before renewal.
If a payment fails we will try again and let you know. If it keeps failing we may suspend access until it is resolved.
Cancelling
You can cancel at any time from your account settings, or by writing to support@gabbglobal.com. Cancelling stops the next renewal. You keep access until the end of the period you have already paid for.

Refunds
[Set your policy here. A common approach: a full refund within 14 days of a first subscription or an annual renewal, no refund for partial months. Some states and countries require specific refund rights, which override whatever you set.]

Free trials
Where we offer a trial, we will tell you how long it lasts and what happens at the end of it. If a trial converts to a paid subscription, we will say so clearly before you start it and remind you before the first charge.

Your account
Keep your login details to yourself. You are responsible for activity on your account.
One subscription is for one learner. Schools and organisations need a separate agreement.
Tell us promptly if you think someone else has accessed your account.
Acceptable use
Do not copy, resell, reverse engineer or scrape the service, attempt to break its security, upload unlawful content, or use it to harass anyone. We may suspend or close an account that does.

Our content
Lessons, audio, images, software and course material in Gabb belong to us or our licensors. Your subscription gives you a personal, non-transferable right to use them while it lasts, and nothing more. What you record and submit stays yours; you give us permission to process it in order to provide the service, as set out in the Privacy Policy.

Availability
We work to keep Gabb running and occasionally need to take it down for maintenance. We do not promise uninterrupted service, and we are not responsible for interruptions caused by your device, your network, or a provider outside our control.

Limits on our liability
Gabb is provided as it is. To the extent the law allows, we exclude implied warranties, and our total liability to you for any claim is limited to what you paid us in the 12 months before the claim arose. Nothing here limits liability that cannot lawfully be limited.

Ending the agreement
You can stop using Gabb at any time. We may suspend or end your access if you break these terms, if we are required to by law, or if we discontinue the service. If we discontinue the service we will refund the unused portion of what you have paid.

Governing law
These terms are governed by the laws of [state], without regard to its conflict of laws rules. [Add dispute resolution here if you want one: courts, arbitration, or small claims carve-out. This is a decision for counsel.]

Changes to these terms
If we change these terms we will post the new version here and email account holders at least 30 days before the change takes effect. Continuing to use Gabb after that means you accept the new terms. If you do not, cancel before they take effect and we will refund the unused portion of your current period.

Contact
Gabb Global Corporation