Privacy policy
Effective September 26, 2026. This policy explains what the Boldly app keeps on your iPhone, what it sends to Boldly's server and to OpenAI, how long it is kept, and how to delete it. Boldly is made by Lucent Enterprises Ltd. ("we"), the seller of Boldly on the App Store.
The short version
- Your voice recordings stay on your iPhone. Boldly turns your voice into text on your iPhone.
- The text of what you say in a lesson goes to Boldly's server and to OpenAI, so your tutor can answer. Boldly's server does not keep the text.
- You do not give a name or an email. Boldly uses a random guest account number instead.
- Boldly counts which steps you use, like "lesson finished", never your words. This starts only after you agree.
- There are no ads, no advertising or analytics SDKs, and no tracking across other apps or websites. We do not sell your data.
- You can delete your data at any time in Settings → Delete my data.
What stays on your iPhone
- Voice recordings. Boldly records your answers on your iPhone to turn them into text. It keeps the first answer of a lesson so you can hear "Your voice, then and now", and for each scene it keeps only the recordings from your first and your newest lesson. Recordings are never sent to Boldly's server or to OpenAI.
- Speech recognition. Boldly uses Apple's speech recognition on your iPhone to turn your voice into text. The first time, iOS may download Apple's English speech model.
- Your lessons and progress. Your lessons, your sentences, "My sentences", your common mistakes, the scenes you made, your goal and your choices (English variety, tutor speed, weekly goal, reminder time) are saved on your iPhone.
- Word clarity. "Clear" and "not clear" come from the speech recognition on your iPhone. They are not a grade.
- Reminders. Practice and trial reminders are local notifications that your iPhone schedules. They are off until you turn them on. Boldly does not use push notifications.
Data on your iPhone may be included in your iPhone's iCloud or computer backups, as set in your iOS settings.
What goes to Boldly's server
Boldly's server runs on Cloudflare. It receives:
- A guest account number. The server makes a random number the first time you need it (for example, your first lesson). The app keeps it in the iPhone's Keychain. It is not linked to your name, email, Apple Account, or a device identifier.
- The text of your lesson. For each turn: the text of what you just said, the last few turns of the conversation (up to six), the scene, your level and the English variety you chose. The server sends this to OpenAI to get your tutor's answer, and does not store it.
- "Help me answer". When you tap it, the server receives the same recent conversation and your app language, so OpenAI can suggest a sentence and its meaning in your language. The server does not store it.
- Your tutor's voice. To speak your tutor's lines and the better sentences, the server sends that text and the English variety you chose to OpenAI, which makes the voice. The voice is made by AI; it is not a person. Cloudflare keeps the audio for up to 30 days so the same line is not made twice. The audio holds the tutor's lines and the better sentences (which are based on what you said), never your recording, and it is not linked to your account. Your own voice is never sent.
- Scenes you make. With a plan, you can describe a talk from your job, in any language. The server sends your description and your iPhone's language to OpenAI to write the scene, then sends the scene back to your iPhone. The server does not store the description or the scene. The scene is saved on your iPhone and is sent with each turn when you practise it.
- Usage events, after you agree. A short list of steps, like "lesson finished", "plans opened", "trial started", with small details such as the scene, the level, or which plan. Never your words. Each event is linked to your guest account number.
- Purchases. When you buy a plan, or when the app checks your plan, it sends Apple's signed receipt for that purchase to the server. Apple also tells the server when a plan renews, ends or is refunded. We never see your payment details or your Apple Account.
- The scene list. When the app opens, it asks the server for the list of scenes. This request has no account number.
The server keeps only this about your account:
| What | Why |
|---|---|
| Guest account number and the day it was made | So your free lessons and your plan work |
| Your plan: which plan, Apple's original transaction number, and when it ends | So your plan unlocks lessons |
| Counts of how many tutor turns and voice lines you used today and this minute | Free lesson limits and fair use |
| Which guest accounts share one plan (up to 5, for example after reinstalling) | So a plan you bought works again |
| Usage events | To see which steps work and make Boldly better |
OpenAI
OpenAI provides the AI that writes your tutor's answers, the "Help me answer" sentence and the scenes you make, and makes your tutor's voice. It receives the text described above, from Boldly's server. It does not receive your guest account number, your voice, or your iPhone's IP address.
Under OpenAI's API terms, data sent to the OpenAI API is not used to train OpenAI's models, and OpenAI may keep it for up to 30 days to check for abuse, then deletes it. See OpenAI: your data.
Other companies
- Cloudflare hosts Boldly's server and this website. Its logs of requests to the server (time, address called, result) are kept for up to 7 days. Usage events are stored in Cloudflare Workers Analytics Engine.
- Apple handles payments, subscriptions and refunds, and provides the speech recognition model. Apple's privacy policy applies to your Apple Account and payments.
We do not use any other company to process your data. The app has no advertising, analytics, or crash-reporting SDK.
How long we keep it
| Data | Kept |
|---|---|
| Recordings, lessons and progress | On your iPhone, until you delete them or the app |
| Text of your lessons, "Help me answer", scenes you make | Not kept by Boldly's server. OpenAI: up to 30 days |
| Tutor voice audio (only the tutor's words and better sentences) | Cloudflare cache: up to 30 days. OpenAI: up to 30 days |
| Guest account, plan status and counts | Until you use Delete my data |
| Usage events | 3 months |
| Server request logs | Up to 7 days |
Why we use your data
- To give you the lessons you asked for (our contract with you): the tutor's answers, "Help me answer", your scenes, your plan and free lessons.
- With your agreement (consent): the online tutor and usage events start only after you tap "Agree" in the app. You can turn the online tutor off in Settings → Use the online tutor. Without it, lessons cannot start.
- To keep Boldly working and fair (legitimate interests): turn limits, abuse prevention and request logs.
Delete your data
Open Settings → Delete my data in the app. This deletes:
- on your iPhone: your recordings, lessons, progress, sentences, scenes you made, your English variety, tutor speed and goal, and your agreement to the online tutor;
- on Boldly's server: your guest account, your plan status and your turn counts.
A few things stay:
- Some settings on your iPhone (your weekly goal, reminder time, reminders already scheduled, and short temporary recordings of single answers) stay until iOS clears them or you delete the app.
- Usage events already recorded stay for up to 3 months. They are linked only to a guest account number that no longer exists.
- OpenAI's copies are deleted within 30 days. Server request logs are deleted within 7 days.
- The server keeps a note that the account number was deleted, so it cannot be used again.
If your iPhone is offline when you delete, the app deletes its data and its account number, but the server account stays. Deleting the app without Delete my data does not delete your server account. Deleting your data does not cancel a plan: manage your plan in Settings → [your name] → Subscriptions on your iPhone.
Your rights
Depending on where you live (for example the EU, the UK, Brazil or Canada), you can ask to see, correct, delete or move your data, or object to how we use it. Most of it is on your iPhone, where you control it. For data on Boldly's server, use Delete my data, or write to us at contact@lucententerprises.com. Because Boldly has no name or email for you, we may need your guest account number or a purchase receipt to find your data.
You can also complain to your local data protection authority.
Children
Boldly is made for adults who use English at work. It is not directed to children under 13, and we do not knowingly collect data from them. If you think a child has used Boldly, write to us and we will help delete the data.
Where data is processed
Boldly's server runs on Cloudflare's global network. OpenAI processes data in the United States. Your data may be processed outside your country, with the protections of these companies' data processing terms.
Changes
If this policy changes, we will update it here and change the date at the top. For important changes, we will also tell you in the app.
Contact
Lucent Enterprises Ltd., the seller of Boldly on the App Store. Email: contact@lucententerprises.com.