Privacy Policy — Fluency Write

Operated by Noble Fluency LLC Last updated: [PUBLISH DATE]

DRAFT — not legal advice. Serviceable starting point grounded in a code audit of what Fluency Write actually collects. Before publishing, confirm: (1) the production data regions for Supabase and Vercel — see [CONFIRM: prod region] markers; (2) whether PostHog autocapture is enabled — see the subprocessor table note. Recommend human legal review (item C1d), prioritizing the “Sensitive content” section. NOTE (Jun 18): the wellbeing-detection section has been removed to match the decision to drop the wellbeing_flag from the product. The “Sensitive content” disclosure is retained — it stays true regardless, because user writing still goes to Anthropic. Do not re-add wellbeing-detection wording unless/until a real, defined wellbeing feature is actually built.

Who we are

Fluency Write is a web-based writing-feedback tool for language learners, operated by Noble Fluency LLC (“we,” “us”), a Washington State limited liability company. You can reach us at hello@fluencywrite.com.

This policy explains what personal data we collect, why, who processes it on our behalf, and your rights over it.

The short version

• We collect your account details, the writing you submit, and the feedback our system generates about it.
• Your writing is sent to a third-party AI provider (Anthropic) to generate corrections. Because you write freely, your submissions may contain sensitive personal information — please keep that in mind.
• We do not sell your personal data.
• You can request a copy of your data or its deletion at any time by emailing hello@fluencywrite.com.

What we collect

Account and identity. Display name; email address (used for sign-in; during the invite-only beta an account may exist with only an invite code); your sign-in method (magic link, Google, or Apple); account creation dates; account flags (such as whether drills are enabled, your subscription status, and free-tier usage counts); and, once you subscribe, a Stripe customer reference and subscription status.

Your writing and the feedback on it. This is the core of the service and the most substantive personal data we hold:

• The full text you submit, the prompt you responded to, a record of which parts you typed versus pasted, and word count and time spent.
• In-progress drafts.
• The corrected version of your text, an estimated CEFR proficiency level and the reasoning for it, individual error corrections, noted strengths and areas for growth, focus phrases and suggestions, and the underlying AI response.
• Phrases, corrections, and notes you save to your notebook.
• A model of your skills built from your writing — a vocabulary fingerprint, grammar structures you use well or struggle with, and an estimated proficiency level.
• Practice drills, your attempts, and scores.
• Any content reports you submit, including your notes and a snapshot of the flagged item.
• Your language targets and requests, planned and shown prompts, and streak activity.

Cross-product links. If you connect Fluency Write to our other apps (such as Fluency Streak or our chorusing app), we store the link between your accounts, a device identifier for the paired device, pairing codes, device tokens (stored only as cryptographic hashes, never in plain text), and summaries of activity pushed from those apps (such as language, duration, and an activity label).

Technical and usage data. A session cookie keeps you signed in. We process your IP address and device/browser information through our hosting and analytics providers (described below); this is not stored in our own database. We also record cost, token, and latency information for each AI evaluation, for operational purposes.

Sensitive content — please read

Because Fluency Write lets you write freely on any topic, your submissions may include sensitive personal information — for example about your health, beliefs, relationships, or other private matters. All text you submit is sent to our AI provider (Anthropic) to generate feedback. If you do not want particular information processed in this way, please do not include it in your writing.

Who processes your data (subprocessors)

We use the following providers to operate Fluency Write. Each receives only the data needed for its role.

Where your data is processed

Several of our providers process data in the United States, including Anthropic and PostHog (us.i.posthog.com). Our database and hosting are operated by Supabase and Vercel in [CONFIRM: prod region]. If you are located outside the United States, your data will be transferred to and processed in the United States and other countries where our providers operate.

Why we process your data and our lawful bases

We process your data to provide the service (performance of our contract with you): creating your account, generating and storing feedback, and managing your subscription. We process usage analytics and maintain the service on the basis of our legitimate interests in operating and improving Fluency Write. We send marketing email only with your consent, which you can withdraw at any time.

Your rights

Depending on where you live, you may have the right to access, correct, export, or delete your personal data, to object to or restrict certain processing, and to withdraw consent. To exercise any of these, email hello@fluencywrite.com. We provide a way to export your data and to delete your account; deletion removes your personal data from our systems, subject to limited retention required for legal or accounting purposes (such as billing records).

Data retention

We keep your account and writing data for as long as your account is active. If you delete your account, we delete your associated personal data, except records we are required to retain (for example, transaction records held for tax and accounting purposes).

Children

Fluency Write is not directed to children under 16, and we do not knowingly collect their data. If you believe a child has provided us personal data, contact hello@fluencywrite.com.

Changes to this policy

We may update this policy. Material changes will be reflected in the “last updated” date above and, where appropriate, communicated to you.

Contact

Questions or requests: hello@fluencywrite.com, Noble Fluency LLC.