ChaTutor Privacy Policy
Version 2026-10-14.
Controller and contact
NEXT11 LLP, number OC461585, 71–75 Shelton Street, London, WC2H 9JQ, United Kingdom, is the controller for ChaTutor and its brands (FlowSoul and enjoYoga). Contact: hola@next11.co. This policy explains data use; it does not seek blanket consent for all processing.
Data and sources
You provide your email, optional name, credentials, selected country, messages, voice notes, journal and reflections. Google supplies authorized basic identity details if you choose its sign-in. We generate identifiers, enrollments, progress, conversation history, transcripts, guide memories and summaries, consent choices, privacy requests and technical usage data. Stripe provides purchase and subscription references and status; we do not store full card numbers.
Operational records may include student, creator and course identifiers, dates, errors, duration, service usage and costs. Infrastructure receives connection details such as IP and browser. Do not put passwords, banking details, diagnoses or others’ private information in the tutor or journal. Memory filters try to exclude sensitive data but can fail; what you write can remain in history and reach AI providers.
Purposes and legal bases
Necessary account, learning, conversation and purchase data are processed to perform the contract and handle your requests. Proportionate logs support security, abuse prevention and operation under legitimate interests, subject to your rights and a necessity assessment. We meet legal billing and retention duties. Optional memory personalizes the educational function, which you can disable. Sharing your basic progress with the course creator relies on our and the creator's legitimate interest in supporting your learning; you can object at any time by turning tracking off. Accepting terms does not replace consent where law requires it for optional or sensitive processing.
In the EU/EEA and UK, using tone and rhythm requires a separate choice before activation. Withdraw it in My Account → Privacy without losing the text tutor or transcription. Withdrawal does not affect the lawfulness of earlier processing. Promotional communications need the applicable legal basis or permission and you can object; necessary account emails are not advertising.
Voice notes, AI and synthetic voice
Voice note audio is sent for transcription through OpenRouter and the configured model provider. When voice emotion analysis is enabled, audio is also sent to the response-writing model to consider tone and rhythm; when disabled, that stage receives only the transcript. Transcription always requires audio processing. Adaptation is uncertain, is not a diagnosis and does not identify your inner state.
The current configuration asks for separate permission in the EU/EEA, UK or where your country is unknown. Elsewhere it enables the preference on accepting terms if no prior choice exists; you can disable it in My Account. This behavior does not replace any consent requirements under your local law.
Response text is sent to Google Gemini to generate synthetic voice. Responses and some narration are not a person speaking live. The tutor is AI, not a therapist, and does not give medical advice. We do not use it to make solely automated decisions with legal or similarly significant effects on you.
Tutor memory
Tutor memory is on by default. It stores short memories about practice preferences (for example, a morning pause), commitments, project or document labels such as “informe Atlas”, and relationship context without names, such as disagreements with a partner. Memory summaries are built from those accepted phrases, not free-form journal or conversation text. Each memory also stores its type, source-message reference, dates, estimated confidence, status and pinning. These are inferences you can correct, not verified facts. In the Library, while memory is on, we also keep your reading journey: books and chapters you opened with each chapter's editorial idea (not your own text), so the tutor can connect readings. You can view and delete it in My Account, and “Forget everything” removes it.
Memory is scoped to your account and each creator: it may be used across your courses with that creator, but does not pass to another creator's courses or get shared with the teacher or creator. Automatic extraction tries to exclude health information, diagnoses, other people's names, risk or self-harm statements, and free-form journal or conversation text; these are not intended as memories. Filters can fail. Your messages, journal and transcripts are separate from memory and may retain that content in their own history.
Memory is an optional feature: you can turn it off at any time in My account. The tutor and memory extraction use OpenRouter and the configured model providers, which may receive the message, the response and relevant memories in order to generate each reply. These providers may process data outside the European Economic Area, so we do not guarantee exclusively European data residency. The points that remain open are listed in the annex to this policy.
Automatically extracted themes receive a 60-day expiry, renewed if the same active theme is extracted again. They are purged when memory is read or updated, not necessarily on the expiry date. Other memories and summaries have no verified time-based automatic deletion and may remain until you request deletion; when the active limit is exceeded, the oldest unpinned memories are also removed. Backups and providers apply their own deletion timelines, detailed in the annex.
In My Account, select the creator to view, edit, pin, archive or delete memories, disable memory or choose “Forget everything”. Archiving excludes a memory from active use but keeps it visible. Disabling stops using and saving memory but does not erase existing data. “Forget everything” deletes memories and summaries for the selected creator in the active database; it does not delete messages, journals, weekly reflections, purchases or other creators’ data and does not disable memory. Also disable it if you do not want new memories. In My Account → Your data and account, request a copy or account deletion and check the request status; this is not an immediate download or deletion. You can also email hola@next11.co. Backups and provider retention follow their deletion processes.
Progress tracking by your creator
When you enroll, course tracking is on by default: the Owner creator can see your account email, available module, progress percentage, last activity and streak to support you. If you have made no choice, you share only these basic fields. Editors and other creators cannot access your record; your journal, conversations, memory and reflections are not shared.
You can turn tracking off in the classroom panel or My Account, and turn it back on whenever you want. Opting out hides your record immediately from the creator's next queries. Your changes are recorded for audit. If the creator turns course tracking off, those records are also unavailable.
Providers and recipients
InsForge provides authentication, database and storage; Google handles sign-in if selected. OpenRouter routes requests to configured model providers for tutoring, transcription, semantic search and memory extraction, which may include OpenAI and Google. Google Gemini generates speech from text. Stripe handles payments and subscriptions. Resend is used for operational emails and alerts. Brevo sends the newsletter only to people who confirm it through double opt-in; you can unsubscribe in every email. Hostinger hosts the web service and processes on a VPS managed with Coolify; Coolify is management software and does not itself imply another recipient of your conversations.
Each provider receives content or data needed for its function; AI requests may include messages, transcripts, course context and relevant memory. Providers such as Stripe or Google may act as independent controllers for some legal or security purposes in addition to contracted services. We do not sell your reflections or share them for behavioral advertising. Request the current list of recipients and their roles at hola@next11.co.
International transfers
Data may be processed in the UK, EEA, US or other countries depending on the provider and model route. We do not guarantee exclusively European residency. Transfers subject to EU GDPR or UK GDPR must have applicable safeguards: an adequacy decision covering the transfer or standard contractual clauses and the relevant UK instrument, with necessary additional measures. Ask hola@next11.co for destination information and copies of applicable safeguards. This policy is not consent to transfers without safeguards.
Retention and deletion
The application processes voice notes in memory and does not store them as student audio files in history; it may store the transcript and response. This does not guarantee zero retention at providers or in their technical logs. Course narration consists of separate files stored for playback.
Account, enrollment, progress, journal, messages and transcripts are kept during the service relationship or until a valid deletion request. There is no general automatic inactivity deletion. Automatic extraction assigns each memory theme a 60-day expiry; extracting the same active theme again renews that period. Editing, pinning or archiving a theme does not reset or prevent its expiry. Expired themes, including archived ones, are purged on memory access or update, not necessarily on the expiry date. Other memories and summaries do not have that expiry; archived memories of other types may remain until deletion, and the oldest unpinned items are pruned when the active limit is exceeded.
After a request, data not needed for legal obligations or claims are deleted; we will explain any exception and applicable period. Billing, consent, request and security records will be kept only as long as their purpose or legal duty requires, with restricted access. We do not promise immediate backup deletion: ask hola@next11.co for deletion scope and periods.
Access, export, deletion and other rights
In My Account → Your data and account you can request a copy or deletion and check status. These are requests recorded for processing: they do not immediately download or erase data. If unavailable, or for access, correction, portability, restriction, objection or consent withdrawal, email hola@next11.co. We may request proportionate information to verify identity or an authorized agent’s authority. Ordinary requests are free of charge.
In the EU/EEA and UK we will respond without undue delay and normally within one month; where law permits an extension for complexity or number of requests, we will notify you within that month and explain why. Other regions have their applicable local deadlines and rights. You may complain to your data protection authority, including the UK ICO or your EU/EEA national authority. Where US state laws apply, exercise the relevant rights to know, correct, delete, obtain a copy and opt out of sale or targeted advertising; we do not discriminate for exercising rights and you may request review of a denial. In LATAM we honor local rights, including access, rectification, cancellation or objection and rights under Brazil’s LGPD where applicable.
Account deletion and payment cancellation are separate: also cancel a subscription through Stripe’s portal or email. Only justified legal exceptions will be retained; we will explain any full or partial denial and available complaint routes.
Children, security and changes
The minimum independent registration age is 16, subject to local law. Under-16 access requires prior contact and verification of parental authorization and legal eligibility; we do not offer automated signup for them. If you identify a child’s data without valid authorization, email hola@next11.co so we can restrict processing and arrange deletion where required.
We apply authentication, access controls and separation by student and creator; no measure guarantees absolute security. We will notify incidents where required by law. Updates will carry a version and material changes will be notified; new choices will be obtained when necessary.