Privacy Policy

Last updated: July 6, 2026

This Privacy Policy explains how XLEMETY, operated by Evert González, collects, uses, and protects information when you use the Platform. It applies to Learners, Natives, and Recruiters alike, with role-specific notes where relevant.

1. Information We Collect

Category	Examples
Account information	Name, email, password (hashed), country, role (Learner / Native / Recruiter)
Learning data	Scenario completions, scores, momentum, linguistic error history, placement results
Verification data (Natives)	Country of residence, identity verification for eligible countries (US/UK/CA/AU)
Verification data (Recruiters)	Corporate email domain, business documents submitted for KYB review, tax/business ID
Payment data	Subscription plan and billing status. Card and payment details are handled directly by PayPal — XLEMETY does not store full payment credentials.
Session data	Live session duration, background transcription used for objective scoring (grammar, vocabulary detection)
Technical data	Device/browser information, IP address, general usage analytics

2. How We Use Your Information

To provide and operate the Platform, including Coach Mode, live session matching, and progress tracking.
To verify Native eligibility and Recruiter business legitimacy (KYB).
To process subscription payments and manage billing status.
To generate performance certificates and make relevant learner data visible to verified, paying Recruiters.
To maintain platform security, prevent fraud, and enforce our Terms of Service.
To send transactional communications (receipts, account notices) and, where permitted, product updates.

3. Live Session Recording and Transcription

During Real Mode, Team Challenge, and XLEMETY Live sessions, the Platform performs background transcription (via Web Speech API) for the purpose of objective scoring — grammar, vocabulary, and duration metrics. XLEMETY does not use AI-generated dialogue or synthetic voices to impersonate the Native participant; live sessions occur via WebRTC between real participants. Qualitative feedback in these modes is provided directly by the Native, not generated by XLEMETY.

4. Who We Share Information With

Recruiters — only after KYB approval and only for candidates who are visible under the Recruiter's paid access tier, subject to the monthly contact limit defined in their plan.
Service providers — including Supabase (database and authentication infrastructure), PayPal (payment processing), and Vercel (hosting) — solely to operate the Platform.
Legal authorities — where required by applicable law, court order, or to protect the rights, safety, or property of XLEMETY or its users.

XLEMETY does not sell personal information to third parties.

5. Data Retention

Account and learning data is retained for as long as your account remains active. Upon account deletion, personal data is removed within a reasonable period, except where retention is required for legal, tax, or dispute-resolution purposes (for example, business documentation submitted during KYB review).

6. Your Rights

Depending on your country of residence, you may have the right to access, correct, delete, or export your personal data, and to object to certain processing. To exercise these rights, contact us via the channels listed below. We will respond within a reasonable timeframe.

7. Data Security

XLEMETY uses industry-standard measures — including Row Level Security policies on our database (Supabase) and encrypted connections (HTTPS) — to protect your information. No system is completely secure, and we cannot guarantee absolute security of data transmitted over the internet.

8. International Data Transfers

XLEMETY operates from Colombia and uses infrastructure providers (Supabase, Vercel) that may process data in other jurisdictions, including the United States. By using the Platform, you acknowledge that your data may be processed outside your country of residence.

9. Children's Privacy

XLEMETY is intended for users 18 years of age or older. We do not knowingly collect personal information from children. If we become aware that a child's data has been collected without appropriate consent, we will take steps to delete it.

10. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated through the Platform or by email. Continued use of XLEMETY after changes take effect constitutes acceptance of the revised policy.

11. Contact

Questions about this Privacy Policy or your data can be directed via X (@xlemety) or Reddit (u/xlemety).

This document is a general-purpose Privacy Policy template adapted to XLEMETY's current data practices. It has not been reviewed by a licensed attorney or data protection specialist. Before relying on it for compliance at scale — particularly regarding GDPR (EU users), CCPA (California users), or Colombia's Habeas Data law — professional legal review is strongly recommended.