NOEMAPrivacy Policy
This policy explains how Noema ("we") handles personal information, in line with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and issuances of the National Privacy Commission (NPC).
Who is responsible
[Your full legal name or business name], [address], is the personal information controller. Contact our Data Protection Officer at angelyntiosy@gmail.com.
What we collect
- Account details: email address, first name, chosen display name, age range (13–17 or 18+), time zone, learning goal and daily minutes (optional).
- Your learning data: your progress, saved words, settings and journal pages, stored so they can follow you across devices. Journal pages are readable only by you.
- Usage counts: which sections you use, how many exercises you complete, sign-in dates. These are counts and dates, never the content you write or say.
- Visitors without an account: a random identifier kept in your browser and which free section you opened, to understand which features lead people to join.
- Email records: which emails we sent you and whether they were delivered, bounced or marked as spam.
- Speaking practice: live captions use your browser's built-in speech recognition (in Chrome, this is processed by Google under Google's terms). Audio recordings are never sent to Noema. Any text you keep from a session is stored privately in your account, readable only by you.
Your microphone
Noema only uses your microphone when you press a record or speak button, and your browser asks your permission first. While you speak:
- Your browser turns your voice into live captions (in Chrome, Google processes this audio under Google's terms).
- Noema listens for "um" and "uh" sounds on your device only. That sound analysis never leaves your browser.
- A recording you make stays in your browser so you can play it back or download it. Noema never uploads your audio.
You can turn microphone access off anytime in your browser's site settings.
What's stored in your browser
Noema saves your progress in your browser's local storage so it works instantly, even offline. This includes your settings, saved words, practice history, journal pages and, if you're not signed in, a random visitor ID. If you have an account, this is also synced privately to your account so it follows you across devices. Clearing your browser data removes the local copy; signed-in members can get it back by signing in again. Noema doesn't use advertising or tracking cookies.
Your coach (Sofia, Mara, Theo or Gabe)
Your coach is Noema's digital coach, not a human. When you ask your coach for something (for example Get notes in the Speaking Studio, a lesson, or "Explain it"), we send the text you wrote or said, the prompt you were answering and your speaking stats (word count, pace, filler and hedge counts) to our language-service provider so your coach can write a reply. If you're signed in, we also include a short summary so your coach remembers you: your first name, your goal, your coach scores from recent sessions, your streak, and the titles of recent words and lessons. Your audio recordings and your journal are never sent. Nothing is sent unless you ask.
After Speaking Studio notes, we save your scores on the six speaking pillars, your filler count, pace and your coach's one "upgrade" focus to your account so the next session builds on it. We don't save the transcript. Premium members can hear their coach's voice: the coach's reply text (not yours) is sent to our voice provider to turn it into audio, and repeated lines are stored so they aren't made twice. Each person has a daily coaching limit. [Lawyer to confirm the providers' data-retention terms to cite here.]
Why we use it
- To create and secure your account and keep your progress in sync (to provide the service you asked for).
- To send account emails such as verification, password reset and security notices (necessary for the service).
- To send reminders and weekly summaries, only if you turn them on.
- To send updates, learning inspiration and offers, only if you tick the box to agree. You can withdraw anytime with one click.
- To improve Noema using aggregated counts.
Members aged 13–17
Noema is for people aged 13 and over. Members aged 13–17 never receive promotional emails, and the marketing option isn't shown to them. [Lawyer to confirm whether parental consent is required for your processing and how to collect it.]
Who we share it with
We don't sell personal information. We use these service providers, who process data on our instructions:
- Supabase: database and sign-in. Region: [your project region].
- Resend: sending email.
- Netlify: hosting the website.
- Anthropic: language service behind your coach's written replies, only when you ask (text only, never audio or journal).
- ElevenLabs: turns your coach's replies into speech for Premium members (your coach's words only).
- Google: live captions in Chrome (handled by your browser).
- Cloudflare Turnstile: spam protection on forms, if enabled.
Some providers store data outside the Philippines. We use providers with strong security commitments and remain accountable for your data under RA 10173.
How long we keep it
We keep your account data while your account is open. When you delete your account, your profile, progress, journal and activity are erased immediately; email delivery records are removed or de-identified, except an unsubscribe or bounce record kept only to make sure we never email that address again. [Lawyer: confirm backup retention period.]
Your rights
Under RA 10173 you have the right to be informed, to access, to object, to correct, to erasure or blocking, to data portability, to damages, and to file a complaint with the National Privacy Commission (privacy.gov.ph). In Noema you can:
- Download all your data: Account settings → Privacy → Download my data.
- Correct your details: Account settings → Profile.
- Change email preferences or unsubscribe: Email preferences, or the link in any email.
- Delete your account permanently: Account settings → Privacy → Delete account.
Security
Passwords are handled by Supabase Auth and never stored by Noema in readable form. Every database table is protected so each member can reach only their own data. The founder dashboard requires a second sign-in factor and shows counts only. If a breach affecting you ever occurs, we will notify you and the NPC as the law requires.
Changes
If we change this policy in an important way, we'll tell you by email or in the app before it takes effect.