Privacy Policy

1. Data controller

Dexaro kj OÜ (registry code 17547926), registered in Estonia with its registered address at Hooldekodu tee 23a-48, 13914 Tallinn, Harju maakond, Estonia, is the data controller responsible for your personal data. For any privacy request, email privacy@say-it.online.

2. What we collect

Account data (email, password hash, and when you accepted our terms); your answers about each conversation, the recordings and text you submit, and the results we generate; your credit ledger and purchase records (amount, currency, date, status and the payment reference); requests you send to our coaches and what they deliver; messages you send through the contact form; and basic technical logs needed to run the service. If you apply to be a coach, we also collect the information described under "If you apply to be a coach" below.

If you link Telegram, we store your Telegram chat id, the step you are at in the bot, and the note and voice notes you send it (voice notes are saved to our file storage like any other recording).

When you visit, our hosting provider tells us which country your IP address is in. We use it only to refuse access from the countries named in our Terms of Service, and we do not store it.

We collect this information directly from you when you create an account, upload a recording, buy credits, use the Telegram bot or contact us, and automatically (for example log data) when you use the service.

3. Legal bases

We rely on the following legal bases under the EU General Data Protection Regulation (GDPR) and the Estonian Personal Data Protection Act: performance of our contract with you (to provide the service and process your purchases); our legitimate interests (to secure, maintain and improve the service and prevent abuse); your consent, where we ask for it; and compliance with legal obligations (such as legal and accounting records). Where we rely on consent, you can withdraw it at any time.

4. Why we use it

To run the core practice loop, process your credit purchases, keep your history available, secure the service, and meet legal obligations. We do not sell your personal data, and we do not use your content to train AI models.

5. Recordings and voice data

Recordings and transcripts you upload are used only to produce the analysis and results you ask for, and to keep your history available to you. If a recording includes another person's voice, you are responsible for having any consent required from them before uploading it.

Recordings, and the audio and images we generate for you, are kept in our cloud file storage at long, unguessable links that are not published or listed anywhere. Anyone who has a link can open that file, so do not share links you want to keep private.

Deleting a conversation removes its answers, notes, recordings and results, including the stored files. Deleting your account does the same for everything in it.

6. When you hire a conversation coach

If you send a request to one of our coaches, the coach who accepts it sees your note, the times you offered for a live session, and — if you attached one — the practice conversation you chose, including its recordings. Coaches see this only for the requests they accept, may use it only to do that work, and are bound by confidentiality under our Specialist Terms, which forbid keeping it after the job. Recording links work the way described under "Recordings and voice data", so a coach who saved a link could still open it; deleting the conversation deletes the file. Coaches do not see your email address, payment details or other conversations.

We keep the request, the delivery and the related credit records with your account history, under the same retention rules as the rest of your account.

7. If you apply to be a coach

When you apply to work as a coach we collect your name, country of residence, languages, experience, bio, any profile links you give us, your bank details for payouts (account holder, IBAN, BIC/SWIFT and bank country), your acceptance of the Specialist Terms, and a copy of a government ID.

We use the ID only to verify your identity and eligibility: a member of our team checks it by hand before we approve you, and we may look at it again to confirm who we are paying before a withdrawal is paid. It is stored privately in our database, never on a public link, and only our staff can view it through an authenticated page. We rely on our legitimate interests and our legal obligations (knowing who we pay, and complying with sanctions law) for this processing.

If your application is declined, we delete the ID document 90 days after the decision. Uploads that were never submitted with an application are deleted within a day. If you are approved, we keep the ID while your account exists and delete it when you delete your account (which you can do once your earnings have been paid out). Your earnings and withdrawal records are kept as long as accounting rules require, as described under "Retention".

Customers see only your display name, languages and bio. Your approved coach profile, your deliveries and your earnings records are kept for as long as you work with us and as the law requires afterwards.

8. AI processing

To generate results we may send your submitted content to AI model providers acting as our processors. They process it only to return a result and under contractual confidentiality terms. An up-to-date list of the AI subprocessors we use is available on request — email privacy@say-it.online.

9. Payment data

When you buy credits by card, your card details pass over an encrypted connection through our server to our payment processor, which makes the charge. We do not store your card number or security code. We keep the amount, currency, date, status and payment reference of each purchase.

10. Sub-processors

We use a small number of vetted service providers, each bound by a data-processing agreement and permitted to process your data only on our instructions. By category, these are: cloud hosting, database and file storage; AI model providers; email delivery; and payment processing. We do not use analytics or advertising providers. If you link Telegram, messages between you and our bot also pass through Telegram, an independent service under its own privacy policy. We share only what each provider needs to perform its function.

11. International transfers

Some of our providers may process data in another country. Where that happens, we rely on appropriate safeguards so that your data keeps the same protection.

12. How we protect your data

We use technical and organisational measures to protect your data, including encryption in transit, hashed passwords, access controls, and limiting staff access to what is needed. No online service can be guaranteed completely secure, but we work to keep your data safe and will notify you and the relevant authority of a personal-data breach where the law requires it.

13. Retention

We keep your account and history until you delete them. Deleting your account removes it, its content and its stored files straight away. We keep your purchase and credit-transaction records (amounts, currency, dates and references) and, if you were a coach, your earnings and withdrawal records (amounts, status, dates and the bank-transfer reference), without your email, name or bank details, for as long as accounting law requires.

To stop the free welcome credits being claimed twice, we keep a one-way fingerprint (hash) of each email address that has received them; for accounts created before 3 October 2026 we kept the address itself. This is not linked to your account and stays after you delete it.

Contact-form messages are deleted 12 months after they are sent.

14. Your rights

You can access, correct or delete your data, get a copy of it, and object to or restrict certain processing. Use Settings to delete conversations or your account; for a copy of your data or anything else, email privacy@say-it.online and we will reply within one month, as the GDPR requires. You may also complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), our lead supervisory authority (www.aki.ee), or to the data-protection authority in the EU country where you live or work.

15. Cookies

We use only essential storage: a sign-in cookie and a note of your cookie-banner answer, as described in our Cookie Policy. We do not use analytics or advertising cookies.

16. Children

The service is not directed at children and is intended for users aged 18 and over. We do not knowingly collect data from children. If you believe a child has provided us data, contact us and we will delete it.

17. Changes to this policy

We may update this policy from time to time; the effective date above changes when we do. Where changes are significant we will take reasonable steps to let you know.

18. Contact

Questions about this policy? Email privacy@say-it.online.