Privacy Policy

1. About this policy

This policy explains what personal information Elqo collects, why we collect it, who we share it with, where it goes, how long we keep it, and what you can do about it.

Elqo is operated by ELQO PTY LTD (ABN 30694675459), an Australian company registered in New South Wales. We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

2. Where a school or employer provides your access

If you use Elqo through a school, employer or other organisation, that organisation decides what data is collected about you and why. In privacy terms, the organisation is the controller and we act on its instructions.

That organisation's own privacy policy applies to its use of your information alongside this one. Where we have a separate written agreement with the organisation, that agreement governs how we handle its data.

3. What we collect

Account information

• Name
• Email address
• Timezone
• Authentication identifiers
• Plan and subscription status

Session data

• Audio recorded during a practice session
• Transcripts of what you said
• AI-generated feedback and the structured feedback record
• Performance metrics and scores, such as pace, word counts and clarity measures
• Session duration and practice history
• The prompt, lesson or scenario you practised, and its category

Camera and visual analysis (optional)

• Individual video frames captured during a session, where you have turned visual analysis on

Technical and usage data

• Usage analytics, including which features you use and how often
• Device and browser information, and IP address

Billing

• Subscription status and transaction records. We do not store your card details.

We do not collect your date of birth, home address, government identifiers, health information or any other sensitive information as defined in the Privacy Act.

4. Recording and consent

You choose when to record. Starting a session is your consent for us to capture, upload, transcribe and analyse audio in order to generate feedback. You can stop a session at any time.

Visual analysis is off by default. It runs only if you turn it on, and your school or organisation can disable it entirely. Where it runs, individual video frames are analysed and then deleted immediately. No video and no still image is retained.

You are responsible for making sure you have the right to record any other person whose voice or image is captured.

5. How we use your information

We use your information to:

• Create and manage your account
• Deliver practice sessions and generate feedback
• Track your progress over time and provide learning context
• Provide reporting to your school or employer where they have deployed Elqo
• Process payments and manage subscriptions
• Monitor and improve the performance, quality and safety of the service
• Send you service messages about the platform
• Meet our legal obligations

6. AI processing and model training

Elqo uses third party AI models to transcribe your speech and generate feedback and analysis.

Your recordings, transcripts and video frames are processed only to generate results for you.

We do not use your content to train AI models, and our AI providers are contractually prohibited from using it to train or improve theirs. They are also contractually required not to retain it after processing.

Feedback shown in Elqo is generated by AI. It is a practice aid, not an assessment, and it can be wrong.

7. Where your data is stored

Our application database and our backups are hosted in Sydney, Australia.

Your account information, transcripts, feedback and performance records are stored in Australia and do not leave Australia at rest.

8. Overseas disclosure

Some processing happens outside Australia.

Audio, transcripts and, where you have enabled it, video frames are sent to AI models in the USA for processing. That data carries only an internal user identifier. Your name and email address are not sent.

This is the only routine disclosure of personal information outside Australia. All other processing and all storage happens in Australia.

Before disclosing personal information overseas we take reasonable steps under Australian Privacy Principle 8, including contractual terms that prohibit training on your data and require deletion after processing, encryption of data in transit, and limiting what is sent to what the task requires.

9. How long we keep it

• Audio and video. Deleted immediately once analysis is complete. Audio and video are never written to permanent storage.
• Transcripts, feedback and performance records. Kept while your account is active.
• Account information. Kept while your account is active.
• Deletion requests. When you delete a recording, delete your account, or ask us to delete your data, we remove it from live systems within 30 days and instruct our providers to do the same.
• Backups. Backups are purged on a rolling 90 day cycle. Deleted data may remain in encrypted backups until they expire, so full erasure completes within 90 days. Backups are not accessible through the app and are restored only in a disaster recovery event.
• Billing records. Retained for as long as tax and financial record keeping law requires.

Where a school or employer provides your access, their agreement with us may set a different retention and deletion cycle.

10. Security

• All data in transit is encrypted using TLS.
• Data at rest is encrypted by our infrastructure provider.
• Access to production systems is restricted to a small number of named individuals, protected by multi-factor authentication, and logged and monitored.
• Administrative actions in the platform are recorded in an audit log.
• Access controls separate what administrators, sub-administrators and our own team can see and do.

No system is completely secure, but we take reasonable steps to protect your information from misuse, loss, and unauthorised access, modification or disclosure.

11. Children and young people

You must be at least 16 to create an Elqo account yourself.

Users under 16 access Elqo only through a school or organisation that has authorised their use. That school or organisation is responsible for obtaining any parental or guardian consent required under its own privacy, child safety and duty of care obligations.

In school deployments we apply additional controls by default, including monitoring for inappropriate language with immediate notification to the supervising teacher, no student-to-student messaging, and no peer-visible results unless the school opts in to leaderboards.

If you believe a child has provided us with personal information without the required authorisation, contact us at info@elqo.app and we will delete it.

12. Analytics and cookies

We use cookies and similar browser storage to keep you signed in, remember your preferences, and support session functionality. We do not use advertising or third party tracking cookies.

We record usage activity in our own database to understand how Elqo is used and to improve it. This covers things like session activity, practice frequency and performance trends. Analytics used for product development are aggregated and de-identified. We do not send this data to a third party analytics provider.

You can control cookies through your browser settings. Blocking some cookies will stop parts of Elqo working.

13. Marketing

We send service messages about your account and the platform. These are part of the service and you cannot opt out of them while your account is active.

We only send marketing email if you have opted in, and you can unsubscribe at any time using the link in the email or by contacting us.

14. Your rights

You can:

• Access the personal information we hold about you
• Ask us to correct information that is inaccurate or out of date
• Ask us to delete your information
• Export your data
• Withdraw consent to optional processing, including visual analysis
• Opt out of marketing

You can delete recordings and close your account in the app. For anything else, contact us at info@elqo.app. We will respond within 30 days.

If you use Elqo through a school or employer, some requests need to go to them, and we will tell you if that is the case.

15. Making a complaint

If you think we have handled your personal information incorrectly, contact us at info@elqo.app. Tell us what happened and what outcome you are looking for.

We will acknowledge your complaint within 5 business days and respond within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.

16. Data breaches

We maintain procedures for identifying, containing and responding to data breaches.

If a breach is likely to result in serious harm, we will notify you and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.

Where a breach affects a school or employer's data, we notify that organisation within 12 hours of confirming the breach.

17. Changes to this policy

We may update this policy as the product changes. The date at the top shows when it was last updated. Where a change is material, we will tell you in the app or by email before it takes effect.

18. Contact

ELQO PTY LTD info@elqo.app

Last Updated: August 19th, 2026