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Privacy Policy | AI Voice Clone: Translator

Privacy Policy | AI Voice Clone: Translator

Effective Date: May 24, 2026

Last Updated: May 24, 2026

This Privacy Policy explains how Toon Tech Ltd ("we," "us," or "our") collects, uses, discloses, and safeguards your information when you use the AI Voice Clone: Translator mobile application (the "App"), including its WhatLingo feature and any related services (collectively, the "Services").

By accessing or using the Services, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the App.


1. Data Controller Information

Company Name: Toon Tech Ltd Company Number: 15077269 Registered Address: 128 City Road, London, United Kingdom, EC1V 2NX Email: support@toontech.uk Website: https://toontech.uk


2. Information We Collect

We collect only the data necessary to provide our voice translation and cloning features.

2.1 Information You Provide Directly

Voice Recordings: Audio you record or upload for translation, voice-to-voice communication, or to create a voice clone. Under the UK GDPR and EU GDPR, voice data used for cloning or identification is treated as Special Category Data (biometric data). Under US state laws (such as BIPA and CCPA), this is Biometric Information.

Voice Clone Models: When you choose to create a voice clone, your voice samples are processed to generate a personalized synthetic voice model.

Text Input: Text you enter for translation or speech synthesis.

Generated Audio Output: The translated or cloned audio produced for you, returned to your device.

Communication Data: Messages or feedback you send to us at support@toontech.uk.

2.2 Automatically Collected Information

Device type, operating system, and unique device identifiers.

Usage data (features used, session duration, in-app interactions).

IP address and approximate location (derived from IP, used for security and fraud prevention).

Microphone permission status (only when you grant access for voice features).

2.3 Information from Third Parties

Subscription and purchase data from RevenueCat (described in Section 4).

Shared voice notes from WhatsApp, Messenger, or other apps when you choose to share audio into our App for translation.


3. Legal Basis for Processing (UK GDPR / EU GDPR)

Explicit Consent (Art. 9(2)(a)): For the processing of voice recordings and voice biometric data used for cloning, translation, and synthesis. This consent is obtained through an in-app disclosure screen before any voice data leaves your device.

Contractual Necessity (Art. 6(1)(b)): To deliver the translation, voice cloning, and synthesis features you request.

Legitimate Interests (Art. 6(1)(f)): For security, fraud prevention, and debugging the App.


4. Third-Party AI and Service Providers

To deliver the Services, your data is shared with the following named third parties. We do not use any other third-party AI processors.

4.1 ElevenLabs, Inc. (United States)

Purpose: Voice cloning, speech synthesis, and voice translation.

Data sent:

Voice recordings (audio files you record or upload)

Voice samples used to create a voice clone

Text input for speech synthesis or translation

What ElevenLabs does with it:

Generates synthetic voice output, translated audio, or a personalized voice clone

Returns the result to the App for playback or download

Stores saved voice clone models under a reference ID tied to your account, until you delete them

Contractual protections: ElevenLabs is contractually obligated to protect your data, prohibited from using your voice data to train their general-purpose models without your explicit consent, and required to provide protections equivalent to those described in this Privacy Policy.

Privacy policy: https://elevenlabs.io/privacy

4.2 RevenueCat, Inc. (United States)

Purpose: Subscription and in-app purchase management.

Data sent:

Anonymous user ID generated by the App

Subscription status, purchase history, and receipt validation data from Apple App Store / Google Play

What RevenueCat does NOT receive: Voice recordings, voice clones, text input, or any biometric data.

Privacy policy: https://www.revenuecat.com/privacy


5. In-App Consent Before Third-Party Transmission

Before any voice recording, voice sample, or text input is sent to ElevenLabs, the App displays an in-app disclosure screen that:

Names ElevenLabs as the third-party service receiving your data

Describes exactly what data will be sent (voice recording, voice samples, text input)

Requires you to tap "I Agree and Continue" to proceed

You may decline at any time. You may also revoke this consent later from Settings → Privacy → AI Service Permissions within the App. Revoking consent will disable voice cloning, translation, and synthesis features, and will trigger deletion of any saved voice clone models from ElevenLabs' systems.


6. How We Use Your Information

We use the information we collect to:

Provide voice cloning, translation, voice-to-voice communication, and speech synthesis features.

Process and deliver WhatLingo voice note translations, including direct sharing to WhatsApp or Messenger at your direction.

Generate and apply your personalized voice clone for natural-sounding translations.

Manage your subscription and in-app purchases (through RevenueCat).

Respond to your requests, provide customer support, and send service-related communications.

Ensure security, prevent fraud, and debug the App.

Comply with legal obligations.

Important note on voice data: Your voice data is used only to deliver the feature you have requested. We do not use your voice data to train any of our own models, and ElevenLabs is contractually prohibited from using it to train their general models without your explicit consent.


7. How We Share Your Information

Beyond the named processors in Section 4, we may share your information only in these limited circumstances:

Integration Partners: When you use the WhatsApp or Messenger sharing feature, the translated voice note is shared directly with those platforms at your direction.

Legal Requirements: When required by law, court order, regulatory request, or to protect our legal rights.

Business Transfers: In the event of a merger, acquisition, or sale of assets, in which case you will be notified.

With Your Consent: For any other purpose with your explicit consent.

We do not sell your personal information or voice data. We do not share your voice data with advertisers or marketing networks.


8. Data Retention and Destruction

Voice Recordings (one-off use): Your recording is transmitted to ElevenLabs for processing and is not retained on our servers. Any temporary cached copies are destroyed within 24 hours.

Voice Clone Models: If you choose to save a voice clone, the model is stored by ElevenLabs under a reference ID tied to your account, until you delete it. You may delete saved clones at any time from within the App. Deletion triggers removal of the voice model from ElevenLabs' systems within 30 days.

Generated Audio: Translated or cloned audio is returned to your device for playback and download. We do not retain copies on our servers.

Voice Samples: Raw voice samples used to create a clone are not retained on our servers after the clone is generated.

Subscription Data: Retained by RevenueCat for as long as your subscription is active and for the period required for tax, accounting, and legal obligations.

We do not store permanent voiceprints or biometric identifiers on our own servers.


9. International Data Transfers

Your data may be transferred to and processed in countries outside your jurisdiction, including the United States, where ElevenLabs, Inc. and RevenueCat, Inc. operate.

Such transfers are made under Standard Contractual Clauses (SCCs) approved by the European Commission and the UK Information Commissioner's Office, which provide legally enforceable protections equivalent to those required under UK GDPR and EU GDPR.


10. Data Security

We implement industry-standard technical, administrative, and physical safeguards to protect your information, including:

Encryption of data in transit (TLS/HTTPS)

Access controls and authentication for our systems

Secure transmission to ElevenLabs and RevenueCat over encrypted channels

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


11. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal data:

Access: Request a copy of the personal data we hold about you.

Rectification: Correct inaccurate or incomplete data.

Erasure: Request deletion of your data ("right to be forgotten").

Withdrawal of Consent: Withdraw your consent for voice data processing at any time via Settings → Privacy → AI Service Permissions.

Objection or Restriction: Object to or restrict certain processing activities.

Data Portability: Receive your data in a portable format (where applicable).

Right to Lodge a Complaint: UK users may complain to the Information Commissioner's Office (ICO) at ico.org.uk. EU users may complain to their local Data Protection Authority.

How to Exercise Your Rights

In-App Deletion: Delete saved voice clones and revoke AI service consent from Settings → Privacy → AI Service Permissions.

Manual Request: Email support@toontech.uk with your request. We will respond within the time required by applicable law (typically 30 days under UK/EU GDPR).

Opt-Out of Data Collection: You can disable microphone access in your device settings or delete the App at any time.


12. US State Privacy Rights (BIPA / CCPA)

This section serves as your Written Release and Retention Schedule for biometric data under the Illinois Biometric Information Privacy Act (BIPA) and equivalent state laws.

We collect voice biometric data only with your explicit, in-app consent.

We do not sell, lease, trade, or otherwise profit from your biometric information.

We retain voice biometric data only as described in Section 8.

California residents have the right to know, delete, correct, and opt out of the sale or sharing of personal information under the CCPA/CPRA. To exercise these rights, contact support@toontech.uk.


13. Children's Privacy

The App is intended for users aged 18 and over. We do not knowingly collect personal information, voice recordings, or biometric data from anyone under 18. If we learn that we have collected data from a minor without verified parental consent, we will delete it promptly. If you believe we may have collected data from a minor, please contact support@toontech.uk.


14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy in the App and on our website, and updating the Last Updated date at the top. For significant changes affecting how we process your voice data, we will request your renewed consent through the in-app disclosure screen.

Your continued use of the Services after changes take effect constitutes acceptance of the updated policy.


15. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or your data, please contact us:

Email: support@toontech.uk Company: Toon Tech Ltd (Company Number 15077269) Address: 128 City Road, London, United Kingdom, EC1V 2NX Website: https://toontech.uk