Privacy Policy — ForgeLingo

Last updated: 20 September 2026

The ForgeLingo website at forgelingo.com (the "Service") is provided by Light Tune Pty Ltd (ABN 20 684 152 618) ("we", "us", or "our"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

The Service is intended for users aged 18 or over.

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1. Who We Are

Entity: Light Tune Pty Ltd (ABN 20 684 152 618) Contact: info@lighttune.com.au Website: https://forgelingo.com

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2. Information We Collect

2.1 Information You Provide

Your voice recordings and the content of your practice dialogues are personal information: they capture your voice and the things you say. We handle them as personal information in full accordance with the Privacy Act.

If we add features that involve additional types of personal information, we will update this policy (section 12) before or when those features launch.

2.2 Information Collected Automatically

2.3 Sensitive Information — please read before recording

Recordings can easily capture sensitive information (as defined in the Privacy Act), such as health details, racial or ethnic origin, religious beliefs or political opinions — sometimes without you intending it. We do not seek sensitive information from you. To protect yourself:

• do not include sensitive information about yourself or anyone else in recordings or content you submit (clause 7.2 of our Terms);
• do not include other people's personal information (names, addresses or other details of third parties) in recordings or content you submit; and
• use fictional names and generic scenarios in practice dialogues wherever possible.

If content containing another person's personal information or sensitive information is submitted inadvertently, contact us at info@lighttune.com.au so we can delete it.

2.4 How we use your voice, and what we do not collect

Our assessment uses your recordings to evaluate language performance (for example, fluency, accuracy and language quality). We do not use your recordings, and we do not use any technology, to verify your identity or identify you through voice or other biometric means.

We do not collect full payment card numbers (Stripe collects and stores these under its own terms and privacy policy) or government identifiers.

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3. How We Use Your Information

The purposes for which we process personal information are described below. In the current version of the Service, personal information is used only to operate the Service for you — there are no optional or secondary data uses (see section 3.3).

• Providing the Service: processing the content, recordings and materials used in the features you use — for example, transcribing your recordings, generating AI assessments and feedback, delivering course or other learning content, and maintaining your practice and learning history
• Account management: authentication, security, and account maintenance
• Billing: subscriptions and pay-per-use purchases via Stripe; GST and accounting records
• Communication: service updates, renewal reminders for paid plans, security alerts, and support responses; and, where permitted under the Spam Act 2003 (Cth), product updates and offers
• Legal compliance: meeting our obligations under applicable laws

3.1 AI Processing Disclosure — read this section carefully

Important — How your recordings and session materials are processed:

When you complete a practice session, the following occurs:

1. Your recording and the practice materials used in the session are transmitted to AI providers (transcription, language-model and/or speech-processing services) for processing
2. The AI providers process the input and return transcriptions and assessment outputs to us
3. We display your results and feedback to you

Data handling by our AI providers (current configuration):

We configure our AI providers so that your inputs and outputs are not used by the provider to train or improve the provider's own models or products where that control is available. Inputs are processed to generate your results and retained by providers only as required for processing, safety, abuse monitoring and legal compliance. Inputs are processed on servers located outside Australia, primarily in the United States and/or other regions.

If we change AI providers or their configuration in a way that materially affects how your data is handled (for example, a provider or tier under which inputs and outputs may be used for provider product improvement or may be subject to human review), we will update this policy and notify you at least 30 days before the change takes effect.

Regardless of provider or configuration, do not include third-party personal information or sensitive information in recordings or content you submit (section 2.3) — this reduces privacy risk to you and to other people. If you are not comfortable with your recordings being processed under these conditions, please do not use the Service.

3.2 Automated and AI-assisted processing (APP 1.7 — transparency about automated decisions)

We use computer programs (including AI) to generate your practice outputs (transcripts, indicative scores and feedback) using the personal information described in section 2.1 (for example, your voice recordings and the practice materials used in the session).

• These outputs do not constitute legally binding decisions about you. We do not use automated decision-making to refuse services, set prices for you individually, or determine your rights.
• Scores are indicative practice feedback only (see section 3.2 of our Terms): they are not aligned to, endorsed by, or predictive of any supported examination result (for the CCL test, this is NAATI).
• Outputs may significantly affect your preparation decisions if you rely on them; that is why our Terms require you to verify with official sources and qualified professionals before reliance.
• You may obtain an explanation of the role of AI in your results, and request human review of any AI-related issue affecting your account, by contacting info@lighttune.com.au.

This section is provided in anticipation of the transparency obligations for automated decisions under privacy law amendments commencing 10 December 2026, and we will update it as those obligations commence.

3.3 Data we do not use

In the current version of the Service we do not use your content for any optional or secondary purpose:

• No product-improvement datasets. We do not include your transcripts, scores or outputs in any product-improvement dataset.
• No model training. We do not use your recordings or other content to train or improve any model.
• No commercial licensing or sale. We do not license or sell your practice data or personal information to any third party, and your raw audio recordings never leave the service-essential processing path (transcription, scoring, and your own access, export and deletion).

If we introduce any such use in the future, we will update this policy and, where the law requires consent, seek your consent before using your content for that purpose (section 12).

3.4 Your privacy choices

• There are no optional data uses to opt in to or out of in the current version of the Service — your content is used only to operate the Service for you (sections 3, 3.1 and 3.3).
• You may exercise your rights of access, correction, deletion and export at any time (section 8) by contacting us at info@lighttune.com.au. We keep a record of your requests so we can honour them.
• If we add optional uses in the future, this section will describe how you control them.

3.5 Aggregated and derived data

We may create aggregate or statistical information from Service use. We will assess whether it identifies an individual before treating it as non-personal information. This section does not limit rights that apply to personal information.

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4. Disclosure of Your Information

We may disclose your personal information to the following parties:

4.1 Service Providers

We may add or replace providers from time to time; material changes to how your data is handled are subject to the 30-day notice in section 3.1.

4.2 Other Disclosures

We may also disclose your information:

• Legal requirements: when required by law, regulation, or legal process
• Protection of rights: to protect our rights, privacy, safety, or property
• Business transfers: in connection with a merger, acquisition, financing, due diligence, or sale of all or part of our assets, your information (including your preference settings as recorded at the time of processing) may be disclosed to prospective counterparties under confidentiality and transferred to the acquiring or successor entity, which will honour this policy
• With your consent: when you direct us to share your information

We do not sell or license your personal information to third parties.

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5. Overseas Disclosure (APP 8)

Some of our service providers are located outside Australia. When we disclose your personal information overseas, we take reasonable steps to ensure that the overseas recipient handles your information in accordance with the Australian Privacy Principles.

Current overseas disclosures:

By using the Service, you acknowledge that your personal information may be disclosed overseas as described above.

Mainland China (reserved): If you are located in mainland China, disclosure of your personal information outside China may require separate express consent under the Personal Information Protection Law of the PRC. Such transfers are off by default and would only occur after separate opt-in consent from you (see our Terms, clause 17).

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6. Data Security (APP 11)

We take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Our security measures include:

• Encryption in transit: all data transmitted using TLS/SSL encryption
• Encryption at rest: stored data encrypted using industry-standard algorithms
• Authentication: secure authentication protocols
• Access controls: strict access controls limiting who can view your data
• Operational access: our engineering personnel may access and export practice data (including recordings, transcripts and scores) only to the extent necessary to troubleshoot problems and keep the Service running, and any exported copies are deleted once the issue is resolved
• Data minimisation: we ask you not to include sensitive or third-party information in recordings or content you submit (section 2.3), which reduces privacy risk to you
• Regular security assessments: periodic review of our security practices

However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

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7. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by law.

7.1 Retention and deletion cycles

When your personal information is no longer needed, we will take reasonable steps to destroy or de-identify it. Deletion requests are actioned in active systems immediately; residual copies in encrypted backups are overwritten on the rolling backup cycle (no later than 30 days). Your raw audio recordings are personal information and are deleted in line with the retention table above.

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8. Your Rights

Under the Privacy Act, you have the right to:

8.1 Access (APP 12)

Request access to the personal information we hold about you. We will respond within 30 days.

8.2 Correction (APP 13)

Request correction of any personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading.

8.3 Deletion

Request deletion of your account and associated personal information (including your voice recordings, transcripts and scores). Deletion takes effect in active systems immediately, with residual copies in encrypted backups overwritten within 30 days; information we must retain for legal or accounting reasons is retained only for that period and purpose (see section 7). Data we exported before your request (for example, troubleshooting exports made under section 6) is not subject to retrospective deletion, but any copies we hold are handled in line with the retention table in section 7.

8.4 Data Export

Export your practice history (recordings, transcripts and scores) in a machine-readable format.

8.5 Your Privacy Choices

• There are no optional data uses to opt in to or out of in the current version of the Service (see sections 3.3 and 3.4)
• You may exercise your rights of access, correction, deletion and export at any time by contacting us at info@lighttune.com.au (see section 8) — we respond within 30 days
• Unsubscribe from marketing communications at any time. We send product updates and offers only where permitted under the Spam Act 2003 (Cth) (including where we have an existing relationship with you), and every marketing email includes an unsubscribe link

8.6 Explanation of AI processing

Ask us to explain the role of AI in your results or raise a concern about an AI-generated output affecting you (see section 3.2).

To exercise any of these rights, contact us at info@lighttune.com.au. We may need to verify your identity before processing your request. We will not charge you for making a request and will respond within 30 days. If we refuse your request, we will provide reasons and inform you of your right to complain.

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9. Cookies and Tracking Technologies

We use cookies and similar technologies for:

You can control cookies through your browser settings. Note that disabling certain cookies may affect Service functionality.

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10. Children's Privacy

ForgeLingo is not intended for individuals under 18 years of age, and our Terms require users to be 18 or older. We do not knowingly collect personal information from people under 18. If we become aware that we have collected personal information from someone under 18, we will take steps to delete it.

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11. Complaints

If you believe we have breached the Australian Privacy Principles, you may:

1. Contact us first: email info@lighttune.com.au with details of your complaint

2. Our response: we will acknowledge your complaint within 5 business days and aim to resolve it within 30 days

3. External review: if you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

   Online: www.oaic.gov.au/privacy/privacy-complaints Phone: 1300 363 992 For other contact details (including postal address), see the OAIC website: www.oaic.gov.au/contact-us

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12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• sending an email to the email address registered to your account
• posting the updated policy on this page with a new "Last updated" date
• posting a notice in the Service, including in the Service's changelog
• where a change relates to how our AI providers or their configuration handle your data, giving you at least 30 days' notice before the change takes effect (see section 3.1 and our Terms, clause 12.1)

Continued use of the Service after changes are posted constitutes acceptance of the updated policy. Where a change introduces a new purpose or processing that requires your consent, we will ask for that consent before using or disclosing your information for that purpose, and continued use alone will not replace an express choice where law requires one.

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13. Contact Us

For privacy-related enquiries, requests, or complaints:

Email: info@lighttune.com.au

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This policy was last updated on 20 September 2026.