Charly

Privacy Policy

How Charly handles personal information

Charly AI Pty Ltd · ACN 699 334 560 · ABN 40 699 334 560 · callcharly.io

This Privacy Policy explains how Charly AI Pty Ltd ("Charly", "we", "us") collects, uses, stores, and protects personal information in connection with the Charly platform.

Charly is an AI-powered English conversation practice platform provided to schools and education providers ("Schools"). Students use the Charly app to practise spoken English, and teachers review transcripts, recordings, and feedback through the Charly teacher portal.

This policy is addressed primarily to Schools as our customers, but it describes how we handle the personal information of everyone whose data passes through the platform, including students and teachers. We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. Information We Collect

We collect the following categories of personal information:

We do not deliberately collect sensitive information (such as health, racial, or religious information). Students may, however, mention personal details during free conversation. Because conversations are recorded and transcribed, students should avoid sharing sensitive personal details during practice.

2. How We Collect It

Students register themselves directly through the Charly app using an invite code provided by their School. When a student registers, they provide their own account information (name and email) and actively agree to the recording and processing of their practice calls before they can use the platform. Teachers set each student's learning settings (topics, grammar focus, and level) through the teacher portal. Schools provide their own staff account details and manage enrolment using their invite code.

Voice recordings, transcripts, usage data, and feedback are generated automatically when a student uses the Charly app to make a call.

3. Voice Recordings and AI Processing

A core part of the Charly service involves recording students' spoken conversations with the Charly AI and processing them using automated AI systems. Each call is recorded, transcribed into text, and analysed by an AI language model to generate feedback and progress summaries. Recordings and transcripts are stored securely and made available to authorised staff of the relevant School through the teacher portal.

Students are informed at the point of registration that their practice calls are recorded and processed to generate feedback, and they must actively agree to this before they can use the platform. We retain a record of this consent.

4. Why We Collect and Use It

We collect and use personal information to:

We may use anonymised, aggregated data derived from platform usage to improve our services, provided that no individual student can be identified from it.

We do not use personal information for advertising, and we do not sell personal information to anyone.

5. Students Must Be Adults (18+)

The Charly platform is for use by students aged 18 years and over only. Schools are responsible for ensuring that only students aged 18 or over use the platform.

Charly does not enrol students directly. Students register themselves using their School's invite code, and the School manages and approves student access through the teacher portal.

6. Third-Party Service Providers

To deliver the platform, we share limited information with trusted third-party providers who process data on our behalf:

These providers are engaged to process data only for the purposes of delivering the Charly service and are subject to their own security and confidentiality obligations. Some of these providers may store or process data outside Australia. Where that occurs, we protect the information by using only established providers that maintain their own recognised security practices, engaging them solely to deliver the Charly service, and relying on the security and confidentiality terms in their service terms.

7. Storage and Security

Data is stored securely with reputable cloud providers. We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These steps include:

No method of transmission or storage is completely secure. While we take the steps described above to protect personal information, we cannot guarantee absolute security.

8. Data Retention and Deletion

When a student is removed from a School, their personal data — including recordings, transcripts, and feedback — is permanently deleted within 14 days. When a School ceases using the platform, the associated student data is deleted on the same basis.

We may retain anonymised, aggregated data that does not identify any individual for the purpose of improving our services.

9. Data Breaches

In the event of a data breach that is likely to result in serious harm to any individual, we will notify the affected parties and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

10. Access, Correction, and Complaints

Individuals, or Schools on their behalf, may request access to or correction of personal information we hold, or request that data be deleted, by contacting us at joe@callcharly.io. We will respond to access requests within 30 days, action corrections within a few days, and action deletion requests within 14 days. We will acknowledge complaints promptly and work to resolve them.

If you have a privacy concern or complaint, please contact us first at joe@callcharly.io. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (oaic.gov.au).

11. Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be available at callcharly.io/privacy. Material changes affecting Schools will be communicated to the School's nominated contact.

12. Contact

For any questions about this Privacy Policy or how we handle personal information, contact us at joe@callcharly.io.