Privacy Policy

1. Who We Are

BIY, LLC is the data controller responsible for the collection and use of your personal information under this Privacy Policy. Our contact details can be found in Section 13 below.

2. Information We Collect

We collect personal data to deliver, maintain, and enhance our Services. The categories of personal data we collect include:

• Account Information: Name, email address, username, password, timezone.
• Profile Data: Profile photo, biography, learning goals.
• Usage Data: IP address, device and browser type, app activity, pages visited.
• Audio & Speech Data: Recordings submitted for accent training purposes.
• Contact Information: If you opt in to the Contact Sync feature, encrypted hashes of your phone contacts may be collected.
• Transactional Data: Purchase history, subscription details, payment processor identifiers.
• Cookies & Tracking Technologies: Data collected through cookies, pixels, and similar technologies (see Section 8).

We do not knowingly collect personal data from children under 15. If we become aware of such collection, we will delete the data immediately.

3. How We Use Your Information

We use your personal data for the following purposes:

• To register and manage your account.
• To provide and personalize Services, including AI-powered feedback and lessons.
• To process transactions and manage subscriptions.
• To send service-related and marketing communications (subject to your consent).
• To analyze and improve the functionality and quality of our Services.
• To detect fraud, enforce legal terms, and comply with legal obligations.

Our legal bases for processing personal data include your consent, contractual necessity, compliance with legal obligations, and our legitimate interests.

Where required under the LGPD or other applicable laws, we rely on consent or legitimate interest in accordance with the defined legal bases under those laws.

4. Sharing Your Data

We may share your information with:

• Service Providers: Cloud infrastructure (e.g., AWS), analytics providers (e.g., Google), payment processors, AI service providers.
• Educational Institutions: If you participate in Accentize for Schools, your teacher may access your profile and progress.
• Legal Authorities: Where required to comply with applicable laws, court orders, or lawful government requests.
• Third Parties in a Business Transfer: In the event of a merger, acquisition, or asset sale.

When we transfer personal data to third-party service providers, we ensure they commit to appropriate data protection obligations, including DPF-level protection, Standard Contractual Clauses (SCCs), or appropriate contractual safeguards required under local laws such as the LGPD.

If you choose to make purchases through the Service, payments are processed via third-party platforms, such as the Apple App Store or Google Play. These platforms collect and process your payment information, including credit card details or other financial data, pursuant to their own privacy policies and terms of service. Accentize does not store or directly access your payment credentials. Please refer to the respective privacy policies of Apple (https://www.apple.com/legal/privacy/) and Google (https://policies.google.com/privacy) for more information on their data processing practices.

By making a purchase, you acknowledge and agree that your financial information will be handled exclusively by the Apple App Store or Google Play Store, as applicable, and that Accentize bears no responsibility for payment processing or associated security obligations.

Notwithstanding anything to the contrary, we remain responsible and liable under the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, if third-party agents that we engage to process the personal data on our behalf do so in inconsistent with the Principles unless we prove that we are not responsible for the event giving rise to the damage.

5. International Data Transfers

BIY LLC is based in the United States. We rely on the following mechanisms to lawfully transfer personal data from the EU, UK, or other jurisdictions:

• EU-U.S. Data Privacy Framework and UK Extension: BIY, LLC complies with these frameworks as set forth by the U.S. Department of Commerce. BIY, LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with respect to personal data transferred from the EU and to the UK Extension to the EU-U.S. DPF Principles with respect to personal data transferred from the UK. If there is any conflict between this policy and the DPF Principles, the Principles shall govern. To learn more, visit https://www.dataprivacyframework.gov.
• Other Transfer Mechanisms: Where DPF is not applicable, we may use SCCs, binding corporate rules, or obtain your explicit consent. We also comply with local international transfer rules, including those set forth under Brazil's LGPD.

6. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Access to your personal data.
• Correction of inaccurate or incomplete data.
• Deletion of your data ("right to be forgotten").
• Restriction of processing.
• Data portability.
• Objection to certain processing activities.
• Withdrawal of previously granted consent.

Under the LGPD, Brazilian data subjects also have the right to: be informed about public and private entities with which your data has been shared; and information about the possibility of denying consent and the consequences of such refusal.

You may exercise these rights via your account settings or by contacting us at privacy@accentize.app. We may verify your identity before processing your request.

For California residents, please refer to Section 15 below for additional disclosures and rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

7. Your Choices

You can manage your preferences in the app settings, including:

• Opting in/out of marketing communications.
• Controlling personalized ad preferences.
• Managing cookies (see Section 8).

If personal data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Policy, BIY LLC will provide you with an opportunity to choose whether to have your personal data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to us as specified in the "Contact Information" section below.

Certain personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered "Sensitive Information."

BIY LLC remains responsible and liable under the EU-U.S. DPF Principles, the UK extension to the EU-U.S. DPF, if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles unless BIY LLC proves that it is not responsible for the event giving rise to the damage.

BIY LLC will not use Sensitive Personal for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless BIY LLC has received your affirmative and explicit consent (opt-in).

For EU/UK/Brazilian users, we do not process data for behavioral advertising without opt-in consent.

If personal data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Policy, you have an opportunity to choose whether to have your personal data so used or disclosed. Requests to opt out of such uses or disclosures of personal data will be sent to us automatically if you change your preferences in the app settings.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Authenticate users.
• Maintain sessions.
• Personalize content.
• Analyze usage.

You can manage cookie preferences in your browser settings. Some features of the Services may not function properly if cookies are disabled.

9. Retention of Data

We retain your personal data only as long as necessary for the purposes for which it was collected, including to:

• Provide the Services.
• Comply with legal obligations.
• Resolve disputes.
• Enforce agreements.

When data is no longer necessary, we securely delete or anonymize it in accordance with applicable data protection regulations, including the LGPD.

10. Security

We implement technical and organizational safeguards to protect your data, including encryption, access controls, and secure hosting environments. However, no system is completely secure; we encourage you to use strong passwords and safeguard your login credentials.

11. Data Privacy Framework Rights & Independent Recourse Mechanism (IRM)

In compliance with the EU-U.S. DPF and UK Extension, BIY, LLC commits to resolve complaints regarding our collection and use of personal data. EU and UK individuals with inquiries or complaints should first contact us at privacy@accentize.app.

Unresolved privacy complaints under the DPF will be referred to BBB National Programs, our designated independent recourse mechanism, available free of charge to EU/UK individuals. For more information, visit: https://bbbprograms.org/programs/all-programs/dpf-consumers.

BIY, LLC is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). Under certain conditions, individuals may invoke binding arbitration for unresolved complaints as described in Annex I of the DPF Principles.

To learn more about binding arbitration under the DPF, see: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

BIY, LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. BIY, LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov.

12. Children's Privacy

Our Services are not directed to children under the age of 15, and we do not knowingly collect their data. If you believe a child under 15 has provided personal data to us, please contact us at privacy@accentize.app, and we will take appropriate action.

13. Contact Information

BIY, LLC 5900 Balcones Drive #28242 Austin, TX, 78731, USA United States of America Email: privacy@accentize.app Phone: +1(281) 473-1886

For GDPR-related inquiries, you may also contact our Data Protection Officer at dpo@accentize.app.

For LGPD purposes, our designated data protection contact is reachable at privacy@accentize.app.

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, technology, or business practices. When we do, we will revise the "Last Revised" date above and, if material changes are made, we will provide notice as required by applicable law.

15. California Privacy Rights (CCPA/CPRA Notice)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the purposes for collecting or selling it, and the categories of third parties with whom we share it.
• Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.
• Right to Correct: You have the right to request that inaccurate personal information we maintain about you be corrected.
• Right to Opt-Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your personal information. We do not sell your personal information in the conventional sense but may share it for cross-context behavioral advertising purposes, subject to your opt-out rights.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit the use and disclosure of your sensitive personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise your California privacy rights, you may: email us at privacy@accentize.app with "California Privacy Request" in the subject line, or access your account settings (if applicable).

We will verify your identity before processing your request and respond within the timeframes required by law. Authorized agents may submit requests on your behalf with written permission.

Thank you for trusting Accentize with your data. We are committed to protecting your privacy and providing a transparent user experience.