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Last updated

Privacy policy

3 October 2026

Who we are

Holdly is the mobile speaking-practice app described on this site. For questions about this policy or your data, email erricofrancescospeak@gmail.com.

What Holdly does

Holdly is for speaking out loud with an AI assistant and getting a report after the session. It is not a course, it has no quizzes, and it does not offer Google, Apple, or Facebook sign-in. We use product analytics (PostHog, EU) to understand how the app is used. On the Free plan, when you open a report we may show a full-screen ad (Google AdMob). We do not use advertising IDs (IDFA) or cross-app tracking tools: we request non-personalized ads.

Data we process

Identity. Each session is tied to a user identifier. You can use the app as a guest (anonymous account) or create an account with email and password. For a registered account we process your email, email confirmation, password reset, and password change. We do not ask for a phone number, photo, date of birth, address, or advertising IDs.

Profile. After you choose a native language and a practice language we store: optional display name (max 40 characters), email if you registered, those two languages, your plan (Free or Premium), and the device time zone, used for the daily speaking limit and for the notification time windows.

Conversations. We store session metadata (languages, duration, status) and the text of turns: what you said and the assistant’s reply, with a translation into your native language on the reply. We generate a report (strengths, corrections, vocabulary) and keep progress (words, moments to review) and minutes spoken that day.

Notifications. If you enable push, we store your preferences (whether they are on and the OS permission status) and a send history (reminder type, time window, local date, outcome), so we do not send more than one notification per window on the same day.

Premium subscription. Free includes 5 minutes of speaking per day. Premium (10 minutes per day and a fuller report) is a paid auto-renewing subscription, available in-app to registered accounts via the App Store (and Google Play where available). The purchase may include a 3-day free trial offered by the store; after the trial, if you do not cancel, you are charged. Holdly does not store card numbers: Apple or Google process the payment. To activate and sync Premium we use RevenueCat, linked to your Holdly user id and store subscription events. We may also remember (via the account email) whether you have already used the store trial, so we do not offer it again.

Ads (Free only). When you open a report on the Free plan we may show an AdMob interstitial. The ad does not unlock Premium report sections. Premium users do not see these ads. Ads are disabled in local development builds.

Microphone and audio

The microphone is used only while you are speaking during a session. We do not use it in the background.

Your voice audio is sent live to OpenAI’s Realtime service (WebRTC) so the assistant can reply with voice. Holdly does not save audio files. After each turn we store only the text transcript.

Push notifications

Holdly may send practice reminders (daily habit), not third-party ads. They arrive only if you grant the system permission and keep notifications on in Settings.

At most one push per time window, two per day: 13:00–14:30 and 17:30–19:30 in your time zone. A tap opens practice in the app (Speak Lab or session resume).

You can turn them off anytime in Settings in the app or in the phone’s notification settings.

Why we use it

We use this data to run Holdly: identity and session, conversation, reports, progress, daily quota, the Premium subscription, and, if you enable them, practice reminders. We also use usage events (without email) for product analytics. On the Free plan we show non-personalized AdMob ads when opening a report. We do not sell your data or link it to cross-app advertising profiles.

Who receives it

Supabase: authentication (guest or email/password), database, and confirmation / password-reset emails.

OpenAI: live audio during a session; text to translate replies and generate reports.

PostHog (EU): product analytics. We send your Holdly user id and usage events (for example starting a session, a report, paywall, or subscription). We do not send email, audio, or conversation text.

Google AdMob: when requesting an interstitial (Free plan, opening a report), technical device/app data needed to show the ad may be exchanged under Google’s policies. We do not send AdMob your email or conversation content.

OneSignal: delivery of push notifications. We use your Holdly user id as the external ID; we do not share email or audio with OneSignal for this purpose.

RevenueCat: Premium subscription status (purchases, renewals, expirations, entitlement). It receives your Holdly user id and events from the store; it does not receive audio or conversation text.

Upstash Redis: a temporary queue to generate reports and to schedule reminders. The job holds only identifiers, not audio.

This website is hosted on Vercel. The landing page loads fonts from Google Fonts. The mobile app uses fonts bundled in the app, without that request.

Apple and Google (and their stores) process in-app purchase data and your store account under their own privacy policies. They also see what you send when you download the app. We do not use their social sign-in.

Where data goes

OpenAI is a provider based in the United States. When you speak or we generate a report, data may leave the European Economic Area. We send it only to provide the feature you are using. PostHog is hosted in the EU. Apple, Google, and RevenueCat may process subscription data outside the EEA as needed to run store billing.

How long we keep it

We do not auto-delete conversations or reports after a fixed number of months. They stay for as long as the account exists. If you delete your account, we delete server data as described on the Account deletion page.

Deletion

If you have a registered account, go to Settings and tap Delete account. That permanently deletes the account, conversations, messages, reports, progress, daily usage, push preferences and send history, and the Premium subscription data we keep on our servers.

Deleting your Holdly account does not by itself cancel an active store subscription: to stop renewals, manage or cancel the subscription in App Store (or Google Play) settings.

Sign out only closes the session on this phone: server data stays.

Guests do not have a delete button. If you use Holdly as a guest and then sign in to another account, the guest session on this phone closes but that guest identity on the server is not deleted by that action. To request deletion of a guest session, email erricofrancescospeak@gmail.com.

On your phone

On the device we keep the signed-in session in encrypted form and some local preferences: interface language, practice languages, whether you have seen onboarding, and the last report if you are a guest. Uninstalling the app removes this from the phone, not data already on the server.

This website

The landing page does not use tracking cookies or analytics. It loads fonts from Google Fonts, which may see the network address of people who open the page.

Children

Holdly is not directed at children under 13. We do not knowingly collect data from children under 13.

Your rights

Where the GDPR applies you can ask for access, correction, deletion, restriction, objection, and portability. Email erricofrancescospeak@gmail.com. You can also lodge a complaint with your country’s supervisory authority (in Italy, the Garante per la protezione dei dati personali).

Changes

If Holdly changes, we will update this page and the date at the top.

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