Privacy Policy

1. General

Pebble ("Pebble," "we," "our," or "us") is operated by FTP Software Ltd, an Australian company (ABN 83618203473). We respect your privacy and are committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Pebble websites, mobile applications, and related services (together, the "Service").

By using the Service, you consent to our handling of your personal information in accordance with this Privacy Policy and applicable privacy laws, including the Australian Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and, where applicable, the European Union General Data Protection Regulation (GDPR) and the UK GDPR.

2. Information We Collect

We may collect the following types of information when you use the Service:

• Account Information - such as your name, email address, age, and login credentials.
• Profile & User Content - details you choose to add to your profile, learning progress, achievements, and any content you submit.
• Device & Technical Data - including IP address, device type, operating system, app usage data, and browser information.
• Payment Information - processed securely through Apple App Store or Google Play (we do not store your credit card details).
• Voice & Audio Data - if you use speaking features, your audio may be sent to trusted providers (e.g., Apple, Google, or Amazon Web Services) for processing.
• Cookies & Analytics - we may use cookies and third-party analytics tools (e.g., Google Analytics, Crashlytics) to improve our Service.

2A. AI Features

Some features of Pebble are powered by artificial intelligence ("AI") technologies. These may include:

• AI-generated practice sentences, translations, or suggestions;
• AI-powered chat or conversation practice;
• AI analysis of your learning activity to personalise your experience.

When you use these features:

• Data you submit (e.g., text, audio, or other inputs) may be processed by third-party AI providers (such as OpenAI, Google, or similar service partners).
• We may record or store the AI inputs and outputs to improve the Service, train our models, or enhance your experience.
• We take steps to remove or minimise personally identifiable information before sharing with AI providers where possible.
• You should not provide sensitive personal information (such as health details, financial data, or government ID numbers) when using AI features.

Transparency on AI Content

• AI-generated content is provided to support your learning but may occasionally produce errors or inappropriate suggestions.
• We encourage you to use your judgment and let us know if you encounter incorrect or problematic content.

3. How We Use Your Information

We process personal information to:

• Provide and operate the Service;
• Personalise your learning experience;
• Improve and develop our features;
• Communicate with you (learning tips, reminders, updates, promotions);
• Process purchases and subscriptions;
• Ensure safety and compliance with our Terms;
• Comply with legal obligations.

4. Sharing Your Information

We may share your information with:

• Service providers who help us operate (e.g., cloud hosting, analytics, customer support, payment processors);
• Legal authorities when required by law or to prevent harm;
• Third-party partners for advertising or marketing, subject to your choices.

We do not sell your personal information.

5. International Transfers

Your information may be processed outside your home country, including in Australia, the EU/UK, the United States, and other countries where our service providers operate. We take steps to ensure adequate safeguards (e.g., contractual protections) are in place for international transfers.

6. Your Rights

Under the Australian Privacy Act (APPs)

If you are located in Australia, you have the right to:

• Access the personal information we hold about you;
• Request correction of your personal information;
• Make a privacy complaint to us or to the Office of the Australian Information Commissioner (OAIC) if you believe we have breached the APPs.

Under GDPR/UK GDPR

If you are located in the EU, EEA, or UK, you also have the following rights:

• Right of Access - to know what data we hold and receive a copy.
• Right to Rectification - to correct inaccurate data.
• Right to Erasure - to request deletion of your data ("right to be forgotten").
• Right to Restrict Processing - to limit how we use your data.
• Right to Data Portability - to obtain your data in a structured, machine-readable format.
• Right to Object - to certain processing, including direct marketing.
• Right to Withdraw Consent - where processing is based on consent.
• Right to Lodge a Complaint - with your local Data Protection Authority.

7. Data Retention

We retain your personal information for as long as necessary to provide the Service or comply with legal obligations. If you delete your account, we will delete or anonymise your personal data, except where retention is required by law.

8. Children's Privacy

Pebble is not directed to children under 13 years of age (or the age of digital consent in your country). We do not knowingly collect personal information from children without parental consent.

9. Security

We use reasonable technical and organisational measures to protect your information, but no method of transmission over the internet is completely secure.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice (e.g., in-app notification or website posting). The date of the last revision will always be shown at the top.

11. Data Controller & Contact

For the purposes of applicable privacy laws, the data controller is:

FTP Software Ltd
ABN: 83618203473
Email: support@pebblelearning.co

• In Australia: you may also contact the OAIC via https://www.oaic.gov.au
• In the EU/UK: you may contact your local Data Protection Authority.