Banter Privacy Policy

Effective Date: 02/26/26

At Banter, your privacy and data security are our priority. This Privacy Policy explains how Refond, Inc. ("Banter", "we", "our", or "us") collects, uses, transmits, and protects your personal information when you use our website, mobile app, and related services (collectively, the "Service").

By using Banter, you consent to the data practices described in this policy.

1. Information We Collect

We collect the following categories of information:

1.1 Personal Information

Information you provide directly, including:

• Name, email address, and account credentials

• Profile information such as username, bio, native language, and learning preferences

• Payment and billing information (processed securely by third-party payment processors)

• Information received from third-party login providers (such as Apple or Google), including name and email address

1.2 Usage Data

Information automatically collected when you use the Service, including:

• IP address and approximate location

• Device identifiers and device information

• Operating system, browser type, and app version

• Feature usage, session duration, and interaction events

• Language learning progress and activity

This information helps us improve performance, reliability, and user experience.

1.3 User Content and Conversation Data

We collect content you provide when using Banter, including:

• Messages sent to AI partners

• Voice recordings and audio inputs

• Conversation responses and corrections

• Feedback and communications sent to Banter

This data is necessary to provide conversational AI features.

2. How We Use Your Information

We use your information to:

• Provide AI conversation practice and generate responses

• Personalize your learning experience

• Maintain conversation memory and context

• Process transactions and manage subscriptions

• Improve Banter’s features, performance, and reliability

• Provide customer support

• Ensure platform security and prevent abuse

• Comply with legal obligations

We do not sell your personal information.

3. AI Processing and Third-Party AI Service Providers

To provide Banter’s core conversational features, we transmit certain user data to trusted third-party AI service providers that process data on our behalf.

These providers may include:

• OpenAI – text generation and conversational AI

• ElevenLabs – voice synthesis

• Deepgram, Google Cloud, or Microsoft Azure – speech recognition and transcription

• Google Cloud and Firebase – infrastructure and secure data storage

Data transmitted may include:

• Messages you send

• Voice recordings and audio inputs

• Conversation context and memory

• Language preferences and profile information

This data is transmitted securely and used solely to provide Banter’s functionality.

These providers:

• Act as service providers processing data on our behalf

• Are contractually obligated to protect user data

• Are required to provide equal or greater data protection standards

• Are not permitted to sell your personal data

• Do not use your data to identify you independently

We only transmit data necessary to provide the Service.

4. Legal Basis and User Consent for AI Processing

By using Banter’s AI conversation features, you consent to the transmission and processing of your messages, audio recordings, and related data by our AI service providers as described in this policy.

Banter requests user permission before enabling AI conversation features.

You may stop using AI features at any time by discontinuing use of the Service or deleting your account.

5. Sharing Your Information

We may share your information only in the following circumstances:

Service Providers

With trusted service providers who help operate Banter, including:

• AI providers (OpenAI, ElevenLabs, Deepgram, Google Cloud, Microsoft Azure)

• Hosting and infrastructure providers (Google Cloud, Firebase)

• Payment processors

• Analytics providers

These providers may only use your data to provide services on our behalf.

Legal Requirements

If required by law, regulation, or legal process.

Protection and Safety

To protect Banter, users, or others from fraud, abuse, or security threats.

Business Transfers

In connection with a merger, acquisition, financing, or sale of assets.

We do not sell personal information.

6. Data Storage and Security

We use industry-standard technical and organizational safeguards to protect your data, including:

• Encryption in transit using TLS

• Secure cloud infrastructure

• Access controls and authentication

• Limited internal access to personal data

No system is completely secure, but we take reasonable steps to protect your information.

7. Data Retention

We retain personal data only as long as necessary to:

• Provide the Service

• Maintain conversation memory and account functionality

• Comply with legal obligations

• Resolve disputes and enforce agreements

You may delete your account at any time through Settings.

Upon deletion, your personal data will be deleted or anonymized, except where retention is legally required.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain login sessions

• Improve performance

• Analyze usage

• Provide features and functionality

You may disable cookies through your device or browser settings.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

• Access your personal data

• Correct inaccurate data

• Request deletion of your data

• Restrict or object to processing

• Withdraw consent

• Request data portability

You may exercise these rights by contacting:

support@talktojojo.com

10. Children’s Privacy

Banter is not intended for children under 13 years old.

We do not knowingly collect personal data from children under 13.

If we discover such data has been collected, we will delete it promptly.

11. Third-Party Services

Our Service may link to third-party services.

We are not responsible for their privacy practices.

Please review their privacy policies separately.

12. International Data Transfers

Your information may be transferred to and processed in countries outside your jurisdiction, including the United States.

We ensure appropriate safeguards are in place to protect your data.

13. Changes to This Policy

We may update this Privacy Policy from time to time.

We will update the effective date and notify users where required.

Continued use of the Service constitutes acceptance of the updated policy.

14. Contact Us

If you have questions, contact:

support@talktojojo.com
Refond, Inc.