Chercha Privacy Policy
Version 1.0.8. Effective date: 2 October 2026. This policy explains what personal data we process, why, on what legal basis, who we share it with, how long we keep it and what rights you have.
1. Who is responsible
Smart Dynamic Systems LTD, a company registered in England and Wales under number 16430324, registered office at 66 Paul Street, London, England, EC2A 4NA (United Kingdom), is the controller. Privacy contact: support@getchercha.com or ayuda@getchercha.com, or “Data complaint” in Help in the app.
2. The essentials
- We process what we need to teach you the English of your region, to run the service and to improve Chercha. Every data item has a purpose stated here.
- In third-party tools (analytics and error reporting) we only use a pseudonymous account ID, never your name or email.
- We never store your immigration or visa status, how you arrived in the country, documents, health, religion, sexual orientation, political opinions or your country of origin. If you mention them in a conversation with the AI or in a text, we do not add them to your profile or to what your coach remembers about you. From “Where are you from?” we only keep the variety of Spanish used for explanations (for example, Dominican or neutral), not the country.
- Conversations with Chercha’s AI (the welcome call, sessions with your coach, the chat and the calls to tell us an idea or a problem) are kept for 30 days by our AI voice provider: calls are recorded and, for the chat, the text is kept. They are then deleted and are not used to train models. Before each type of conversation we ask for your permission (section 4).
- Your coach can remember what you share to help you better, in short notes that you can see, change or delete in Profile › “What your coach remembers about you”, where you can also turn memory off.
- In pronunciation practice in Your path, your iPhone turns what you say into text and the audio never leaves your iPhone. That text, and the sentence you write in the real-life mission, are checked and not stored.
- If you give us permission (“Will you help us improve Chercha?”), we make a session replay to improve the app: we see Chercha’s screens and where you tap. Anything that may be personal (what you type, your messages with your coach, what your coach remembers about you, your ideas, your alias or your email) is masked on your iPhone before anything is sent, and the most personal screens are never replayed. Without your permission it does not happen, and you can change your answer at any time in Settings › Privacy and data › “Help us improve Chercha” (section 3).
- We do not store your IP address in our database or in analytics, and we do not use your iPhone’s location (GPS). From the IP we only derive an approximate location, the network and an encrypted abuse-prevention hash (section 3), and we never infer your country of origin or immigration status from it.
- We do not sell your data. We do not use your data for advertising without your separate permission.
3. What data we process, why and for how long
| Data | Purpose | Legal basis | Recipients | Retention |
|---|---|---|---|---|
| Account: pseudonymous ID and link to Apple (Sign in with Apple and, if you share it, your email or Apple’s private relay email) | Running the service and restoring your progress | Contract | Hosting and database provider (London); Apple | While the account exists |
| Email for trial-ending and renewal reminders (the one on your Apple account, which may be Apple’s private relay email) and, only if you separately agree, news. For each reminder we keep the type, the charge date, the date sent, the language, the subject and the price it stated, without the address | Reminding you before your trial ends, before each annual renewal and, on the monthly plan, every 6 months, and being able to prove we did; news with your consent | Legal obligation and contract; news: consent | Hosting and database provider; email provider | While the account exists; news consent can be withdrawn with one tap |
| Profile: Spanish variety, interface language, time zone, age confirmation, sign-up method, pace and vulgar/offensive filter | Personalising your learning | Contract | Hosting and database provider | While the account exists; deleted automatically 12 months after your access ends |
| Regions and their weight, sector and difficult situations | Choosing each day’s expressions | Contract | Hosting and database provider | Same as profile |
| Your English goal (from a fixed list, never the details) and, if you say it, in how many months | Preparing expressions for your goal and showing its path in Your progress | Contract | Hosting and database provider | Same as profile |
| Learning data: expressions seen, saved, practised with your coach and “I know it”, review answers, activity days, streak and streak protectors, and upcoming daily plan | Spaced review, feed, streak and progress | Contract | Hosting and database provider | Same as profile |
| Your path: coaches and units unlocked, activities and the steps you completed (the expressions in each activity and your listening and review answers) and what your conversations contributed to each lesson (which steps you met, which are missing and a sentence explaining it). In pronunciation, your iPhone turns what you say into text (the audio never leaves your iPhone) and the server compares that text with the sentence without storing it; in the real-life mission, the sentence you write is checked and not stored | Showing your progress, completing activities and unlocking the next coaches | Contract | Hosting and database provider; to check the steps in your conversations and in “Write to your coach”, our network and web hosting provider (AI model), which receives the text of the conversation; we only keep the result | While the account exists |
| Your answers to “Have you heard it here?” and “Is the explanation clear?” for each expression, your likes, the expressions you share and the status of your reports (whether what you reported was fixed or removed) | Ordering your feed and what native reviewers check, learning which expressions are most useful and telling you what happened to your report. Your answers never remove an expression; reports from several people do remove it until we review it | Contract and legitimate interests | Hosting and database provider | While the account exists; if you delete it, your answers, likes and shares are kept with no link to you so the counts are not lost |
| Welcome call, what we keep at Chercha: country and region where you live, city, relationship with the place, level, offer outcome and objection (fixed lists), duration and drop-off minute | Preparing your plan and aggregated research to improve the product | Contract (plan) and legitimate interests (research) | Hosting and database provider | 12 months; then only anonymous aggregates |
| Conversations with the AI, what our AI voice provider keeps: the recording of calls (welcome call, sessions with your coach, daily call, and ideas and problems), the text of each conversation, including the chat, and its analysis (topics, tone, evaluation criteria, session score, notes for your coach and, in the welcome call, interest and moment of hesitation) | Answering you, giving you your session score, preparing what your coach remembers, finding problems and complaints, and improving the script, the content and the offer; aggregated analysis | Consent: you give it before each type of conversation and it is a condition of that conversation; in the welcome call, without it you answer in writing | Our AI voice provider (section 4) | 30 days; then deleted |
| Sessions with your coach (by call, with the video of your illustrated coach or in the daily call): scene, coach, path unit, duration, minutes used, whether it was a video call or you did not answer, scores from 1 to 5 (fluency, pronunciation, comprehension and local expressions), estimated level and, for 30 days, the reasons for each score, up to 3 improvements quoting what you said and a short summary | Giving you your score, showing your progress and level, unlocking the next coaches and counting your practice minutes | Contract | Hosting and database provider | The reasons, improvements, summary and the link to the conversation: 30 days; scores, level and minutes: while the account exists |
| Chat with your coach: your messages and your coach’s, per coach, and a sentence summarising each chat | Letting you see your conversation and your coach pick it up again | Contract | Hosting and database provider; our AI voice provider | 30 days; you can delete it at any time from the chat or in Settings |
| What your coach remembers about you: short notes, never transcripts, about your goals, your situations, the context you choose to share, who you speak English with (no names), your progress, your frequent mistakes, what you find hard, your preferences, your milestones and the last session, with the date you said it. Never your origin, nationality, accent, immigration status, health, religion, political opinions, sexuality, payment details or other people’s data | Letting your coach remember you and personalise each conversation: when a chat or session starts, your coach receives a short summary with your profile, these notes and your recent conversations (30 days) | Contract (personalising your practice); you can see, change, delete or turn it off in Profile › “What your coach remembers about you” | Hosting and database provider; our AI voice provider, as part of each conversation | While the account exists or until you delete it; with memory off, nothing new is saved |
| Technical summary of each conversation with the AI: identifiers, duration, how it ended, cost and fixed-list results, never the text or the audio | Finding problems and keeping the cost of the service under control | Legitimate interests | Hosting and database provider | Linked to your account: 30 days; unlinked, deleted after 90 days |
| Daily call (if you turn it on): time, days, time zone, quiet hours and the day of the last call | Calling you at the time you choose | Contract | Hosting and database provider; Apple (call notification) | While the account exists; you can change it or turn it off at any time |
| Notifications and calls on your iPhone: the identifiers Apple gives your iPhone to receive Chercha notifications and calls, with their environment and the iPhone fingerprint | Sending you “My ideas” notifications and, if you turn it on, the daily call | Contract | Hosting and database provider; Apple | 12 months after it was last updated; sooner if it stops being valid or you delete your account |
| Device fingerprints (encrypted hash of an iPhone identifier): the one for the device you talk to the AI on and the ones for each account, with first and last seen | Abuse prevention: one welcome call per device, daily limits on conversations with the AI and an alert if an account uses too many devices | Legitimate interests | Hosting and database provider | Your account’s, while it exists; the welcome call one, 12 months after it was last used; the one for other conversations, 30 days |
| Network log: per account and day, an irreversible encrypted hash of your IP address (the IP is not stored), the IP’s country, the network organisation and the network type (mobile, residential, university, business or public body, hosting or VPN) | Abuse prevention: detecting shared accounts, use from many countries or networks, VPNs or hosting. Alerts are reviewed by a person; there are no automated decisions | Legitimate interests | Hosting and database provider (London); network and web hosting provider (receives the IP only to report the network and country, without storing it) | 30 days; sooner if you delete your account |
| Consents: type, text version and date | Proving you gave permission | Legal and contractual obligation | Hosting and database provider | Pseudonymised log of each permission for conversations with the AI: 5 years even if you delete your account (required by our AI voice provider’s terms) |
| Subscription: plan, status, trial and renewal dates, founder price, environment and your plan’s price in your currency; and practice minute purchases (pack, minutes, purchase identifier, date and refund) | Giving you access and your practice minutes, and reminding you about charges | Contract | Hosting and database provider; subscription management provider (US); Apple | While the account exists; deleted automatically 12 months after your access ends |
| What you write: personal dictionary, content reports and support messages | The features you use | Contract | Hosting and database provider | While the account exists |
| Your own audio in My dictionary (optional): what you record yourself, up to 15 seconds, of how an expression you heard sounds. Only you can hear it; it is not sent to any AI or third party | Letting you hear how what you heard sounded | Contract | Hosting and database provider (London), in a private space in your account | Until you remove it or delete the expression; at most, while the account exists |
| Ideas and problems: the text of your idea or of the problem you tell us about and, for a problem, the steps and how serious it is. If you dictate it, your iPhone turns it into text and the audio never leaves your iPhone; if you tell us in a call with the AI, we keep the AI’s summary and the name of the screen and of the element you point to (never screenshots). Also the language, whether you started by speaking or typing, the status and the team’s reply, votes and, only if you allow it, your alias | Improving the product with your suggestions and fixing what goes wrong, telling you where they stand and giving you the price of one month of your plan towards your subscription if your idea launches | Contract; alias: consent | Hosting and database provider | Ideas: up to 24 months or until you delete the idea or your account; problems: while the account exists |
| Contact us: topic, message, reply email, interface language and, only if you tick the box, app and iOS version, iPhone model and environment | Replying in your language and solving the problem | Contract | Hosting and database provider; email provider (forwarding to the support inbox) | While the account exists |
| Referrals: the referrer’s offer code, who redeemed it, the invitee’s first payment date and the reward granted or the reason it was cancelled. Never your contacts | Giving you the price of one month of your plan towards your subscription, keeping to the yearly cap and preventing fraud | Contract | Hosting and database provider | For as long as the programme runs and 24 months afterwards |
| Friends: your alias (created by Chercha, never your name), its initials and colour, your friend code, your invitations (only an encrypted hash of the link), requests, friendships, blocks and the streak protectors you give or receive, with their reaction. Only your friends and people who receive your invitation or request can see your alias | Letting you connect with your friends and give each other streak protectors | Contract | Hosting and database provider | While the account exists; invitations, 30 days after they are used or expire |
| Data export log: the date of each export, without the file (the file is created on your iPhone) | Limiting exports to 10 a day (abuse prevention) | Legitimate interests | Hosting and database provider | While the account exists |
| App usage events (no free text), with the screen name and the identifier of the element you tap (for example, the button or option you choose; never what you type), the region you declare and your App Store country (codes only); your network type, number (ASN) and organisation, looked up with our network provider when you open the app; and the approximate location our analytics provider derives from your IP (country, region, city, postcode, approximate coordinates and time zone). The analytics provider discards the IP. Never your iPhone’s location (GPS) | Improving the product and learning experience, and aggregated analysis | Legitimate interests | Analytics provider in the EU (Frankfurt), pseudonymous ID only | 12 months |
| Session replay, in every version of the app (the App Store version and test versions): Chercha’s screens as they look (buttons, titles, catalogue expressions and your path) and where you tap. On your iPhone, before anything is sent, anything that may be personal is masked: everything you type, your messages with your coach, what your coach remembers about you, your ideas, what you said in a session, protected views and your name, alias, email or photo if they appear. No audio and no network data or logs. Never in calls and sessions with the AI or their score, the chat, the voice and chat permissions, what your coach remembers about you, My dictionary, the ideas box, “Write to us”, exporting your data or deleting your account, and never before you confirm you are 18 or over. Only if you say “Yes, I’ll help” when we ask (at the end of sign-up or, if you already had the app, once); you change your answer in Settings › Privacy and data › “Help us improve Chercha” and, if you withdraw it, it stops straight away (the setting is kept on that iPhone) | Seeing where people get stuck when using the app (confusing screens, abandoned steps, bugs) and fixing it | Consent; you can withdraw it at any time with the switch | Analytics provider in the EU (Frankfurt), pseudonymous ID only | 30 days |
| App and widget errors and crashes, with your pseudonymous account ID (never your name, email or IP address) | Fixing bugs | Legitimate interests | Error monitoring provider (EU) | Up to 90 days |
| Website waiting list: email, platform (iPhone or Android), website language, country as reported by our network provider (never the IP), the version of the text you accepted and the dates the confirmation email was sent and confirmed | Telling you when we launch on the platform you choose and measuring demand by platform and country | Consent (unticked box and email double opt-in) | Hosting and database provider; email provider (confirmation email) | Unconfirmed: 30 days; confirmed: until we notify you or until you unsubscribe with the link in the email |
| Native reviewers: name, email, regions and verdicts | Reviewing content (they have their own contributor terms) | Contract | Hosting and database provider | While they contribute |
Automatic deletion: 12 months after your access ends, your account is deleted automatically, just as if you deleted it yourself in Settings. Only the pseudonymised proof of your permissions for conversations with the AI (5 years) and the welcome call device fingerprint, with no link to the account, remain. Encrypted backups may keep deleted data for up to 12 more months.
4. Conversations with the AI
- Chercha has several conversations with AI: the welcome call, sessions with your coach (by call, with the video of your illustrated coach or in the daily call), the written chat with your coach and the calls to tell us an idea or a problem. Before each type of conversation we ask for your explicit permission and tell you that you are talking to an AI. Your voice or what you type is sent in real time to our AI voice provider and the language model it uses, so it can understand and answer you.
- Calls are recorded. The recording, the text of the conversation (including the chat) and its analysis are kept for 30 days by our AI voice provider to answer you, give you your score, find problems and improve Chercha, then deleted. They are not used to train models.
- Keeping it is a condition of each conversation. In the welcome call, if you would rather it is not kept, you use the written form instead; the other conversations are optional.
- To prepare each session, your coach receives your area, your level, your goal, your sector and some of your Chercha expressions. With memory on, it also receives what it remembers about you and your recent conversations; with memory off, it does not.
- At Chercha we keep only the fixed-list answers from the welcome call, which you see and can change at the end; your score from sessions; chat messages for 30 days; and what your coach remembers about you (section 3). The AI does not ask about your immigration status, your health or your country of origin; if you mention them, they do not go into your profile or into what your coach remembers, although they remain in the conversation until it is deleted.
- To work out which steps of a lesson you completed in a session or in “Write to your coach”, the text of that conversation goes through an AI model from our network and web hosting provider. We only keep which steps you met and a sentence explaining it.
- We keep proof of each permission (type, text version and date, without your name) for 5 years.
5. Who we share data with
With processors acting on our behalf under data processing agreements, and with Apple. These are the categories of recipients, where they process data and the safeguard used: hosting and database provider (database, accounts and files; London, UK, no transfer); our AI voice provider (real-time voice and chat, recording, text and analysis of conversations with the AI, kept for 30 days; US, EU or Singapore, under the UK extension to the Data Privacy Framework and the ICO Addendum); subscription management provider (subscription status and minute purchases; US, under a data processing agreement with the safeguards in section 6); Apple (download, sign-in, payment, and notifications and calls on your iPhone); analytics provider (usage analytics and session replay, kept for 30 days; EU, Frankfurt, covered by an adequacy decision); error monitoring provider (errors and crashes; EU, covered by an adequacy decision); email provider (email delivery; US, sending from Ireland, under a data processing agreement with the safeguards in section 6); and network and web hosting provider (the getchercha.com website, network organisation lookups, the AI model that checks the steps in Your path and encrypted backups; the provider’s global network, backups in the EU, under a data processing agreement with the safeguards in section 6). You can ask us for the list of providers at support@getchercha.com. We may also disclose data where the law requires it, and to a buyer if the company is sold, with the same safeguards.
6. International transfers
Where a provider processes data outside the UK or the European Economic Area, we rely on the safeguards the law allows: adequacy regulations (for example, the UK Extension to the Data Privacy Framework), the ICO Addendum to the standard contractual clauses or the International Data Transfer Agreement (IDTA).
7. Advertising
Chercha does not currently use your data for advertising or track you across apps. If we measure campaigns in the future (for example, on social media), we will only send app events (install, paywall, subscription) for people who allow it in Apple’s tracking prompt and give separate consent, never your profile or what you learn. We will update this policy first.
8. Children
Chercha is not intended for anyone under 18, and we do not knowingly process their data. If you believe a minor has given us their data, email support@getchercha.com and we will delete it. Sessions with your coach, the chat and session replay do not start until you confirm you are 18 or over, and they never run if you say you are under 18.
9. Your rights
- Access and portability: in the app, Settings > Export my data.
- Rectification: change your profile and regions in the app or email us. You can see, change, delete or turn off what your coach remembers about you in Profile › “What your coach remembers about you”, and delete your conversation with your coach from the chat or in Settings.
- Erasure: delete your account in the app. We delete your data except what the law requires us to keep (for example, proof of consent).
- Objection: you can object to processing based on legitimate interests, such as product research or analytics.
- Withdraw consent at any time, without affecting earlier processing. For session replay, just turn off “Help us improve Chercha” in Settings › Privacy and data: it stops straight away and does not start again on that iPhone.
- Restriction of processing where the law provides for it.
To exercise them, use the app or email support@getchercha.com. We reply within one month. We do not make automated decisions with legal effects about you: the price is the same for everyone in the same situation. Your session scores and the steps in Your path are worked out by an AI only to support your learning.
10. Complaints
If you are unhappy, please contact us first. You can also complain to the Information Commissioner’s Office (ICO), ico.org.uk, or to the data protection authority in your country.
11. Security
We encrypt data in transit and at rest, restrict database access per user, use short-lived sessions and log access.
12. Website cookies
getchercha.com only uses what is strictly necessary. See the cookie policy.
13. Changes
If we make important changes to this policy, we will tell you in the app before they apply. Previous versions are at getchercha.com/legal/history.