Privacy Policy - Hospitality English Upgrade

At Hospitality English Upgrade, we are committed to protecting your personal data and being transparent about how we collect, use, store and protect it.

This Privacy Policy explains how Chittoo Technologies India Private Limited ("Hospitality English Upgrade", "we", "us", or "our") collects and processes personal information when you:

• visit or use our website, www.chittoo.com;

• download or use the Hospitality English Upgrade mobile application;

• create a Hospitality English Upgrade account;

• use Hospitality English Upgrade's learning, speaking or conversation features;

• participate in our campaigns, surveys or other activities; or

• otherwise interact with Hospitality English Upgrade.

Please read this Privacy Policy together with our Terms and Conditions.

1. Who We Are

Chittoo Technologies India Private Limited is an India-based technology company providing English-language learning and communication practice services.

Registered Office: Bengaluru, Karnataka, India – 560095
Email: privacy@chittoo.com
Website: www.chittoo.com

For the purposes of applicable data-protection laws, Hospitality English Upgrade may act as the entity responsible for determining the purposes and means of processing your personal data in connection with our services.

2. What Personal Information We Collect

"Personal Information" means information that relates to an identifiable individual, either directly or when combined with other information reasonably available to us.

Depending on how you use Hospitality English Upgrade, we may collect the following categories of information.

2.1 Information You Provide

When you create an account, contact us or use our services, we may collect information such as:

• name;

• email address;

• mobile number, where provided;

• country or region;

• account credentials or authentication information;

• information you provide in your profile;

• subscription or purchase information;

• communications you send to us;

• feedback, survey responses and support requests; and

• other information you voluntarily provide to us.

We do not require you to provide information that is not necessary for the particular feature or service you are using.

2.2 Learning and Practice Information

When you use Hospitality English Upgrade, we may collect information about your learning activity, such as:

• lessons and exercises completed;

• vocabulary and grammar practice;

• conversation activity;

• learning preferences;

• practice history;

• progress information;

• responses to learning activities;

• topics selected for practice; and

• other information generated through your use of Hospitality English Upgrade.

This information helps us provide and improve your learning experience.

2.3 Voice and Speech Information

Certain Hospitality English Upgrade features allow you to practise speaking using your device's microphone.

When you use these features, we may process information such as:

• voice recordings that you choose to submit;

• speech-to-text transcriptions;

• pronunciation-related information;

• speaking patterns and other speech-related measurements;

• responses generated from your speech; and

• feedback relating to your English-language practice.

Voice and speech information is processed to provide features such as speaking practice, conversation, pronunciation feedback, language correction and progress insights.

We do not use voice recordings for purposes unrelated to providing, maintaining, securing or improving Hospitality English Upgrade unless we have an appropriate legal basis or your consent where required.

Please refer to the relevant feature information and our Privacy Policy for details about how voice information is handled.

2.4 Information Collected Automatically

When you access our website or use our application, we may automatically collect certain technical and usage information, such as:

• IP address;

• device type;

• operating system;

• browser type;

• application version;

• language and regional settings;

• approximate location derived from technical information, where permitted;

• pages or screens viewed;

• features used;

• session information;

• crash and diagnostic information;

• referral information; and

• other technical information necessary to operate and secure the service.

We use this information primarily to operate, secure, troubleshoot and improve Hospitality English Upgrade.

2.5 Cookies and Similar Technologies

Our website may use cookies and similar technologies to provide functionality, understand website usage, remember preferences, measure performance and, where applicable, support marketing activities.

Please see our Cookie Policy for more information.

3. How We Use Your Personal Information

We may use personal information for the following purposes:

Providing Hospitality English Upgrade

We use information to:

• create and manage your account;

• provide access to Hospitality English Upgrade;

• provide learning and speaking features;

• process your requests;

• provide AI-powered conversations and feedback;

• provide pronunciation and language-related feedback;

• maintain your learning history and progress;

• process subscriptions and purchases; and

• provide customer and technical support.

Improving Hospitality English Upgrade

We may use information to:

• understand how users interact with Hospitality English Upgrade;

• identify technical problems;

• troubleshoot errors;

• improve the usability and performance of the application;

• develop and improve learning features;

• improve the quality of our AI-powered features;

• understand feature usage and engagement; and

• develop new products and services.

Where appropriate, we use aggregated or de-identified information for analytics and product improvement.

Communications

We may use your contact information to:

• respond to your questions;

• provide customer support;

• send service-related notifications;

• communicate important changes to the service; and

• send marketing or promotional communications where permitted by applicable law and based on your applicable communication preferences.

You can opt out of promotional communications by using the unsubscribe mechanism included in the communication or by contacting us.

Security and Fraud Prevention

We may process information to:

• protect Hospitality English Upgrade and our users;

• detect and prevent fraud;

• detect misuse or unauthorised access;

• investigate security incidents;

• enforce our Terms and Conditions; and

• comply with applicable law.

Legal Compliance

We may process or disclose information where necessary to comply with applicable laws, regulations, legal proceedings, court orders or lawful requests from government authorities.

4. Legal Basis for Processing

Depending on the circumstances and applicable law, Hospitality English Upgrade may process personal information:

• to provide a service you have requested;

• to perform or take steps in connection with a contract with you;

• based on your consent where consent is required;

• to comply with legal obligations;

• to protect the security and integrity of our services; or

• where otherwise permitted under applicable law.

Where we rely on consent, you may withdraw that consent subject to applicable law. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

Where a particular service requires certain information to function, refusing to provide that information may mean that we cannot provide that feature or service.

5. AI-Powered Features

Hospitality English Upgrade uses AI and automated technologies in certain features, including conversation practice, language correction, speech analysis and learning feedback.

When you interact with these features, the information you submit may be processed by Hospitality English Upgrade and, where necessary, by technology or service providers that help us operate these features.

AI-generated responses and assessments may not always be accurate or appropriate.

We use AI-generated outputs primarily to provide the learning and practice experience you request and to operate and improve Hospitality English Upgrade in accordance with applicable law.

6. How We Share Personal Information

Hospitality English Upgrade does not sell your personal information to third parties for their own direct marketing purposes.

We may share personal information in the following circumstances.

Service Providers

We may share information with trusted service providers that help us operate Hospitality English Upgrade.

These may include providers of:

• cloud hosting;

• data storage;

• analytics;

• customer support;

• payment processing;

• authentication;

• communications;

• security;

• speech-to-text or speech-processing technology;

• AI and language-processing technology; and

• other infrastructure or technical services.

These service providers may process personal information only as necessary to provide services to Hospitality English Upgrade and subject to appropriate contractual or legal protections.

Payment Providers and App Stores

If you purchase Hospitality English Upgrade through an app store or third-party payment provider, relevant information may be processed by that provider in accordance with its own privacy policy and terms.

Legal and Regulatory Authorities

We may disclose information where required or permitted by applicable law, including in response to valid legal processes, government requests or regulatory requirements.

We may also disclose information where reasonably necessary to protect the rights, safety, security or property of Hospitality English Upgrade, our users or others.

Business Transfers

If Hospitality English Upgrade is involved in a merger, acquisition, restructuring, financing, sale of assets or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

7. International Data Transfers

Some of our technology and service providers may process personal information in countries outside India.

Where personal information is transferred or processed outside India, Hospitality English Upgrade will take steps required by applicable law to ensure that the transfer and processing are appropriately protected.

8. Children's Privacy

Hospitality English Upgrade is intended to be used in accordance with the applicable age requirements in the user's jurisdiction.

Where applicable law requires parental or guardian consent before processing a child's personal information, we will seek the required consent and apply the protections required by law.

We do not knowingly collect or process children's personal information in a manner prohibited by applicable law.

If you believe that a child has provided personal information to Hospitality English Upgrade without the required parental or guardian consent, please contact us at:

privacy@chittoo.com

We will take appropriate steps as required by applicable law.

9. Cookies

Hospitality English Upgrade uses cookies and similar technologies on its website.

These technologies may be used to:

• keep the website functioning;

• remember preferences;

• understand website traffic;

• analyse website performance;

• improve user experience; and

• support permitted marketing and measurement activities.

For more information, please see our:

Cookie Policy

10. Data Security

Hospitality English Upgrade takes reasonable technical and organisational measures designed to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.

These measures may include appropriate administrative, technical and physical safeguards.

However, no method of transmission over the internet or electronic storage system can be guaranteed to be completely secure.

You are also responsible for protecting your account credentials and device from unauthorised access.

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing our services, maintaining business and transaction records, resolving disputes, enforcing agreements, maintaining security and complying with legal obligations.

When personal information is no longer required for the relevant purpose and there is no legal or legitimate reason to retain it, we will take appropriate steps to delete, anonymise or otherwise dispose of it in accordance with applicable law.

Different categories of information may have different retention periods.

For example, information associated with an active account may be retained while the account is active, while certain transaction or legal records may need to be retained for longer periods where required by law.

12. Your Privacy Rights

Subject to applicable law, you may have rights relating to your personal information, including the right to:

• request access to information about the personal data we process about you;

• request correction of inaccurate or incomplete personal information;

• request deletion of personal information where applicable;

• withdraw consent where processing is based on consent;

• request information about how your personal information is processed;

• raise a grievance regarding our processing of your personal information; and

• exercise any other rights available to you under applicable law.

The availability and scope of these rights may depend on the applicable law and circumstances of the processing.

To exercise your rights or raise a privacy-related concern, contact us at:

privacy@chittoo.com

We may need to verify your identity before responding to certain requests.

We will respond to valid requests within the time period required by applicable law.

13. Withdrawal of Consent

Where we process your personal information based on your consent, you may withdraw that consent using the mechanism provided by Hospitality English Upgrade or by contacting us.

Where technically and legally feasible, the process for withdrawing consent will be reasonably accessible and comparable to the process through which consent was provided.

Withdrawing consent may affect our ability to provide certain Hospitality English Upgrade features or services that depend on that information.

Withdrawal of consent does not affect processing that occurred lawfully before the withdrawal.

14. Do Not Track

Some web browsers provide a "Do Not Track" setting.

There is currently no universally adopted technical standard that requires websites to respond to all Do Not Track signals in the same manner.

Accordingly, Hospitality English Upgrade may not respond to all browser-based Do Not Track signals.

15. Third-Party Websites and Services

Hospitality English Upgrade may contain links to third-party websites, applications or services.

These third parties operate independently from Hospitality English Upgrade and may have their own privacy policies and terms.

Hospitality English Upgrade is not responsible for the privacy practices, security or content of third-party websites or services.

We encourage you to review the privacy policy of any third-party service before providing it with personal information.

16. Marketing Communications

We may send you service-related communications that are necessary for operating your account or providing Hospitality English Upgrade.

Where permitted by applicable law, we may also send promotional communications about Hospitality English Upgrade.

You can unsubscribe from promotional emails by using the unsubscribe option included in the communication or by contacting us at:

privacy@chittoo.com

Unsubscribing from promotional communications will not prevent us from sending essential service-related communications.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

• our products and services;

• our data-processing practices;

• technology;

• applicable laws and regulations; or

• our privacy and security practices.

When we make material changes, we will provide appropriate notice where required by law.

The updated Privacy Policy will be published on this page with a revised "Last Updated" date.

We encourage you to review this Privacy Policy periodically.

18. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or the way we process your personal information, please contact us:

Chittoo Technologies India Private Limited

Registered Office:
Bengaluru, Karnataka, India – 560095

Email: privacy@chittoo.com

Website: www.chittoo.com

19. Grievance Redressal

If you have a concern or complaint regarding the processing of your personal information, please contact us at:

privacy@chittoo.com

Please include sufficient information to help us understand and investigate your concern.

We will handle privacy complaints and requests in accordance with applicable law and the timelines prescribed under applicable law.

Last Updated: 30 September 2026