Elixir Lab ("we", "us", "our") operates the Elixir mobile application (the "App"). This Privacy Policy explains how we collect, use, share, store and protect your personal data when you use the App. By using the App, you agree to the collection and processing of information in accordance with this Privacy Policy.

1. WHAT INFORMATION WE COLLECT1.1. Account data
When you create an account, we collect:
  • your name and email address (provided through Sign in with Google or Sign in with Apple);
  • a unique user identifier;
  • your native language and the language(s) you are learning;
  • your answers during initial setup: why you are learning the language, what stops you from speaking, your preferred learning mode.
1.2. Usage data
We automatically collect information about how you interact with the App, including:
  • lesson progress and completion data;
  • speech diagnostic results and lesson reports (score, strengths and weak spots, phrases to fix);
  • words saved to your dictionary and learning statistics;
  • your conversation history with the AI tutor;
  • how you use the App's features and screens (screen views, taps, app launches, session length);
  • key events: onboarding completed, first lesson completed, paywall opened, trial started, purchase made;
  • your subscription status (Free or Premium).
1.3. Device information and identifiers
We may collect the following information:
  • device type, operating system and its version, device language and region;
  • the installed version of the App;
  • push notification tokens (Firebase Cloud Messaging on Android, Apple Push Notification service on iOS);
  • a device identifier generated by our analytics provider, AppMetrica. It is not an advertising identifier and is used to tell one installation from another;
  • on Android — the Google Advertising ID (GAID). It is collected by the Meta SDK to measure the effectiveness of our advertising campaigns (see section 10.3). You can reset or delete it in your Android settings;
  • on iOS — we do not collect Apple's advertising identifier (IDFA) and do not request App Tracking Transparency permission. The App does not track you across other companies' apps and websites.
1.4. Crash and performance data
To find and fix bugs we receive crash reports and technical data about how the App runs: the error type, the App's state at the moment of the crash, device model, OS and App version. On Android this data is collected by AppMetrica. On iOS, crash reports come from Apple only if you have allowed sharing them with developers in your device settings. This data does not contain the content of your lessons or conversations.
1.5. Audio data
When you use voice features:
  • voice recordings are sent to our servers and processed by our own speech recognition system (Speech-to-Text, STT) hosted on infrastructure under our control;
  • text-to-speech uses our own speech synthesis system (Text-to-Speech, TTS);
  • audio is processed in real time solely to perform the requested function and is not stored on our servers after STT/TTS processing;
  • we do not send voice recordings to OpenAI or any other third-party AI provider for speech recognition or synthesis;
  • microphone access is requested only when you start a spoken answer and is used for that purpose only.
1.6. Payment information
We do not collect or store your card details. All payments are processed through:
  • Apple App Store (for iOS users);
  • Google Play Store (for Android users).
From these platforms we receive a transaction confirmation and subscription details: the purchased plan, start and end dates, and status (trial, active, expired, cancelled). These details are verified on our servers and are needed to unlock paid features for you.
We send the fact that a trial started or a purchase was made, together with the amount and currency, to our analytics and ad measurement providers (see section 10). Card details, payer name and billing address are never sent to these providers and are not available to us.
2. HOW WE USE YOUR INFORMATION
We use the collected data to:
  • provide, maintain and improve the App;
  • create personalised AI-powered language lessons based on your level and progress;
  • track your learning progress and automatically adapt lesson difficulty;
  • manage your dictionary and vocabulary statistics;
  • process and verify subscription status;
  • send push notifications and practice reminders (with your consent);
  • analyse how the App is used in order to improve the user experience;
  • measure the effectiveness of our advertising campaigns: understand how many installs and purchases our ads bring;
  • find and fix crashes and errors;
  • inform you about updates and changes to the service;
  • detect and prevent fraud and abuse.
3. AI PROCESSING AND THIRD-PARTY AI SERVICES3.1. Third-party AI provider
To power AI features we use OpenAI (OpenAI, L.L.C. and its affiliates). The mobile App does not connect to OpenAI directly. Data is transferred only through our servers and only after you have seen the corresponding notice in the App and given your consent as described in section 3.5.
3.2. What data may be sent to OpenAI
When you use AI-based features, we may send to OpenAI only the data required for the selected feature to work. This includes:
  • the text you type in the chat (including daily lessons, practice tasks and other conversations);
  • the text produced by our STT system from your voice recording, if you send a voice message;
  • the learning context required for the AI to work correctly, including:
  • the language you are learning;
  • your native language;
  • the lesson topic;
  • your progress within the lesson;
  • the most recent messages of the current conversation;
  • your name or display name (when needed so that the AI can address you personally while building a learning plan or running lessons);
  • words and expressions you ask to be explained in the dictionary;
  • the content of messages used for grammar checking, word analysis or building a learning plan.
We do not send to OpenAI:
  • your email address;
  • your Apple or Google account identifiers;
  • card details or payment information;
  • advertising or device identifiers.
Your name is sent only when it is needed to personalise the conversation. For features that do not require personalisation (for example grammar checking or word descriptions), your name is not sent.
3.3. How we collect and use AI-related data
Collection. You provide text and voice data yourself when using:
  • chats;
  • lessons;
  • the dictionary;
  • voice features.
Information about your learning language and progress is taken from your account settings and the data stored on our servers.
Use. This data is used to:
  • generate the AI tutor's responses;
  • generate learning materials;
  • translate text;
  • check grammar;
  • explain words;
  • improve learning quality.
OpenAI processes this data solely to produce the model's response, which is returned to our App. Chat and lesson history is stored on our servers in accordance with section 6.
3.4. OpenAI's data processing practices
OpenAI provides a level of personal data protection comparable to the one described in this Privacy Policy. We use the OpenAI API, under which data sent through the API:
  • is not used to train or improve OpenAI's models;
  • is processed solely to produce a response to our request.
For international data transfers we rely on appropriate contractual safeguards, including Standard Contractual Clauses (SCC). OpenAI processes data in accordance with its own Privacy Policy and Terms of Use. We also choose service providers that apply appropriate technical and organisational measures to protect personal data.
3.5. Your consent before data is sent to OpenAI
Before any of the data listed in section 3.2 is sent for the first time, the App shows a separate notice stating:
  • which categories of data will be sent;
  • that the recipient is OpenAI;
  • how this data is used to power AI features.
Data transfer starts only after you tap "I agree". If you choose "Not now", no data is sent to OpenAI, and features that require OpenAI are unavailable. You can withdraw your consent at any time in Settings by turning off data sharing with OpenAI. After withdrawal, AI features remain unavailable until you give consent again. Accepting the Terms of Use or this Privacy Policy when signing in does not by itself constitute consent to sending data to OpenAI.
3.6. Use of anonymised data
We may use AI outputs, as well as aggregated and anonymised statistics that cannot identify a specific user, to improve lesson quality and develop the App further.
4. SHARING AND DISCLOSURE4.1. Sale of personal data
We do not sell your personal data to third parties.
4.2. Sharing with service providers
We may share your information with the following categories of service providers, only to the extent necessary to provide the corresponding features:
  • Authentication providers — Google and Apple (for signing in).
  • Cloud infrastructure — to host the App's backend, database and storage.
  • Third-party AI provider — OpenAI (to generate learning materials, AI tutor responses, grammar checks, word analysis and dictionary descriptions), only after you have given consent in the App as described in section 3.5.
  • Speech processing — our own speech recognition (STT) and speech synthesis (TTS) systems running on GPU servers we own. Voice data is not sent to OpenAI for speech recognition or synthesis.
  • Analytics — AppMetrica (to analyse App usage and collect crash reports), see section 10.2.
  • Ad measurement — Meta Platforms (the Meta SDK, to measure the effectiveness of advertising campaigns), see section 10.3.
  • Push notification services — Firebase Cloud Messaging (Google) and Apple Push Notification service.
  • Payment platforms — Apple App Store and Google Play (processing purchases and subscriptions).
4.3. Disclosure required by law
We may disclose your information when required by:
  • law;
  • regulation;
  • a court order;
  • an official request from a public authority;
  • other legally mandated procedures.
4.4. Business transfers
In the event of a merger, acquisition or sale of assets, your data may be transferred to the organisation that becomes the successor of the relevant assets or service.
5. DATA STORAGE AND SECURITY5.1. Storage security
Your data is stored on secure servers. We use current industry-standard safeguards, including:
  • encryption of all data in transit over HTTPS/TLS;
  • secured database connections;
  • server access by SSH keys only;
  • network perimeter protection with a firewall;
  • JWT-based user authentication.
5.2. Storage of learning history
Lesson progress and your conversation history with the AI tutor are stored in our database. Automatic backups are made regularly to prevent data loss.
5.3. Limitation of guarantees
Although we apply modern information security methods, no method of transmission over the Internet or electronic storage can guarantee absolute security. Therefore we cannot guarantee complete protection of information against every possible threat.
6. DATA RETENTION AND DELETION6.1. Retention period
We keep your personal data for as long as your account remains active or as long as it is necessary to provide our services to you.
6.2. Learning history
Conversation history and lesson data are kept in order to:
  • maintain your learning progress;
  • preserve the context of previous sessions;
  • provide a personalised continuation of your learning.
6.3. Account deletion
You can delete your account at any time in one of two ways:
  1. In the App: Settings → Delete account → confirm. The request is executed immediately; no additional email confirmation is required.
  2. By email: write to social@elixirlab.io from the email address linked to your account with the subject "Account deletion". We will complete the request within 30 days.
What is deleted: account data (name, email address, user identifier), onboarding answers, speech profile, learning progress and lesson reports, dictionary, conversation history with the AI tutor, notification settings and push tokens, and subscription records linked to the account.
What is kept: aggregated and anonymised analytics data that cannot be linked to you (section 6.4), and records we are legally required to retain (for example, payment records to the extent required by tax and accounting law).
Timing: data is removed from the production database immediately after confirmation and disappears from backups within 30 days.
Important: deleting your account does not cancel your subscription. The subscription is managed by the store where it was purchased: App Store (Apple ID settings → Subscriptions) or Google Play (Payments & subscriptions → Subscriptions). Cancel it before deleting your account to avoid further charges.
6.4. Anonymised data
Aggregated and fully anonymised data may be kept indefinitely and used solely for analytics and improving the App.
7. YOUR RIGHTS
Depending on the laws of your country of residence, you may have the following rights.
7.1. Right of access
You may request a copy of all personal data we hold about you.
7.2. Right to rectification
You may request correction of inaccurate or incomplete personal data.
7.3. Right to erasure
You may request deletion of your personal data (the "right to be forgotten"), see section 6.3.
7.4. Right to data portability
You may request your data in a structured, commonly used and machine-readable format.
7.5. Right to object
You may object to certain ways of processing your personal data where applicable law provides for it.
7.6. Withdrawing consent and opting out of optional processing
At any time you can:
  • turn off push notifications in the App or device settings;
  • withdraw consent to sharing data with OpenAI in the App's Settings;
  • on Android — reset or delete your advertising ID (Settings → Google → Ads, or Settings → Privacy → Ads). Once the identifier is deleted, the Meta SDK can no longer link App events to your advertising activity;
  • manage how Meta uses data received from apps in your Meta account settings ("Activity off Meta technologies");
  • ask us to exclude your data from analytics by writing to social@elixirlab.io.
How to contact us. To exercise any of these rights, email us at social@elixirlab.io
8. CHILDREN'S PRIVACY
8.1. The App is not intended for children under 13.
8.2. We do not knowingly collect personal data from children under 13. If we learn that we have received personal data from a child under 13 without the consent of a parent or legal guardian, we will promptly take steps to delete that information.
9. PUSH NOTIFICATIONS
9.1. With your consent we may send push notifications, including:
  • practice reminders at the time you choose;
  • important notifications related to the operation of the App.
9.2. You can change your push notification settings or turn them off completely at any time:
  • in the notification settings inside the App;
  • in your device's system settings.
10. ANALYTICS, AD MEASUREMENT AND CRASH REPORTS10.1. Cookies
The mobile App itself does not use cookies.
10.2. AppMetrica
We use AppMetrica to analyse how the App is used. The service collects:
  • screen views, taps and other interactions with App features;
  • app launches and session length;
  • key learning and subscription events (see section 1.2);
  • user properties: the language you are learning, subscription status, your Elixir user identifier;
  • device, OS and App version details, and country derived from the IP address;
  • on Android — crash reports.
AppMetrica assigns its own device identifier to each installation. Advertising identifiers (IDFA, GAID) are not sent to AppMetrica. This data helps us understand how the App is used, find bugs and improve its functionality.
10.3. Meta (advertising measurement)
We promote the App with ads on Meta services (Facebook, Instagram). To understand which campaigns bring users, the App includes the Meta SDK (Meta Platforms, Inc. and Meta Platforms Ireland Ltd.). The App does not display ads.
The following is sent to Meta:
  • the fact that the App was installed and launched;
  • trial start and purchase events, with amount and currency;
  • technical details about the device and App version.
We do not send Meta your name, email address, lesson or conversation content, voice recordings or dictionary.
On Android, the Meta SDK receives the Google Advertising ID (GAID) to match an installation with an ad shown earlier. You can reset or delete it in your device settings (see section 7.6).
On iOS, the advertising identifier (IDFA) is not collected and tracking permission is not requested. Ad effectiveness is measured through SKAdNetwork, Apple's mechanism that passes only aggregated conversion statistics to the ad network without identifying an individual user.
Meta processes the data it receives in accordance with its Privacy Policy (https://www.facebook.com/privacy/policy) and may also use it for its own purposes as an independent data controller.
10.4. Crash reports
On Android, crash reports are collected by AppMetrica (section 10.2). On iOS, we receive crash reports from Apple only if you have allowed sharing them with developers (Settings → Privacy & Security → Analytics & Improvements).
10.5. Opting out of analytics and ad measurement
The available options are described in section 7.6.
11. INTERNATIONAL DATA TRANSFERS
Your personal data may be transferred to and processed in countries other than your country of residence. In particular, OpenAI and Meta Platforms process data in the United States, and our cloud infrastructure and analytics providers may host servers in various countries. In all such cases we ensure appropriate safeguards for personal data in accordance with applicable data protection law, including Standard Contractual Clauses where required.
12. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. If the changes are material, we will notify you in one or more of the following ways:
  • by posting the updated Privacy Policy in the App;
  • by updating the "Last updated" date at the top of this document.
By continuing to use the App after the changes take effect, you confirm your acceptance of the updated Privacy Policy.
13. CONTACT US
If you have questions, suggestions or requests regarding this Privacy Policy or the processing of your personal data, you can contact us:
Email: social@elixirlab.io
Website: https://elixirlab.io/feedback_form
Terms of Use: https://elixirlab.io/term_of_use
Privacy Policy
Last update: 5 September 2026 г.
5. DATA STORAGE AND SECURITY5.1. Storage security
Your data is stored on secure servers. We use current industry-standard safeguards, including:
  • encryption of all data in transit over HTTPS/TLS;
  • secured database connections;
  • server access by SSH keys only;
  • network perimeter protection with a firewall;
  • JWT-based user authentication.
5.2. Storage of learning history
Lesson progress and your conversation history with the AI tutor are stored in our database. Automatic backups are made regularly to prevent data loss.
5.3. Limitation of guarantees
Although we apply modern information security methods, no method of transmission over the Internet or electronic storage can guarantee absolute security. Therefore we cannot guarantee complete protection of information against every possible threat.
6. DATA RETENTION AND DELETION6.1. Retention period
We keep your personal data for as long as your account remains active or as long as it is necessary to provide our services to you.
6.2. Learning history
Conversation history and lesson data are kept in order to:
  • maintain your learning progress;
  • preserve the context of previous sessions;
  • provide a personalised continuation of your learning.
6.3. Account deletion
You can delete your account at any time in one of two ways:
  1. In the App: Settings → Delete account → confirm. The request is executed immediately; no additional email confirmation is required.
  2. By email: write to social@elixirlab.io from the email address linked to your account with the subject "Account deletion". We will complete the request within 30 days.
What is deleted: account data (name, email address, user identifier), onboarding answers, speech profile, learning progress and lesson reports, dictionary, conversation history with the AI tutor, notification settings and push tokens, and subscription records linked to the account.
What is kept: aggregated and anonymised analytics data that cannot be linked to you (section 6.4), and records we are legally required to retain (for example, payment records to the extent required by tax and accounting law).
Timing: data is removed from the production database immediately after confirmation and disappears from backups within 30 days.
Important: deleting your account does not cancel your subscription. The subscription is managed by the store where it was purchased: App Store (Apple ID settings → Subscriptions) or Google Play (Payments & subscriptions → Subscriptions). Cancel it before deleting your account to avoid further charges.
6.4. Anonymised data
Aggregated and fully anonymised data may be kept indefinitely and used solely for analytics and improving the App.
7. YOUR RIGHTS
Depending on the laws of your country of residence, you may have the following rights.
7.1. Right of access
You may request a copy of all personal data we hold about you.
7.2. Right to rectification
You may request correction of inaccurate or incomplete personal data.
7.3. Right to erasure
You may request deletion of your personal data (the "right to be forgotten"), see section 6.3.
7.4. Right to data portability
You may request your data in a structured, commonly used and machine-readable format.
7.5. Right to object
You may object to certain ways of processing your personal data where applicable law provides for it.
7.6. Withdrawing consent and opting out of optional processing
At any time you can:
  • turn off push notifications in the App or device settings;
  • withdraw consent to sharing data with OpenAI in the App's Settings;
  • on Android — reset or delete your advertising ID (Settings → Google → Ads, or Settings → Privacy → Ads). Once the identifier is deleted, the Meta SDK can no longer link App events to your advertising activity;
  • manage how Meta uses data received from apps in your Meta account settings ("Activity off Meta technologies");
  • ask us to exclude your data from analytics by writing to social@elixirlab.io.
How to contact us. To exercise any of these rights, email us at social@elixirlab.io
8. CHILDREN'S PRIVACY
8.1. The App is not intended for children under 13.
8.2. We do not knowingly collect personal data from children under 13. If we learn that we have received personal data from a child under 13 without the consent of a parent or legal guardian, we will promptly take steps to delete that information.
9. PUSH NOTIFICATIONS
9.1. With your consent we may send push notifications, including:
  • practice reminders at the time you choose;
  • important notifications related to the operation of the App.
9.2. You can change your push notification settings or turn them off completely at any time:
  • in the notification settings inside the App;
  • in your device's system settings.
10. ANALYTICS, AD MEASUREMENT AND CRASH REPORTS10.1. Cookies
The mobile App itself does not use cookies.
10.2. AppMetrica
We use AppMetrica to analyse how the App is used. The service collects:
  • screen views, taps and other interactions with App features;
  • app launches and session length;
  • key learning and subscription events (see section 1.2);
  • user properties: the language you are learning, subscription status, your Elixir user identifier;
  • device, OS and App version details, and country derived from the IP address;
  • on Android — crash reports.
AppMetrica assigns its own device identifier to each installation. Advertising identifiers (IDFA, GAID) are not sent to AppMetrica. This data helps us understand how the App is used, find bugs and improve its functionality.
10.3. Meta (advertising measurement)
We promote the App with ads on Meta services (Facebook, Instagram). To understand which campaigns bring users, the App includes the Meta SDK (Meta Platforms, Inc. and Meta Platforms Ireland Ltd.). The App does not display ads.
The following is sent to Meta:
  • the fact that the App was installed and launched;
  • trial start and purchase events, with amount and currency;
  • technical details about the device and App version.
We do not send Meta your name, email address, lesson or conversation content, voice recordings or dictionary.
On Android, the Meta SDK receives the Google Advertising ID (GAID) to match an installation with an ad shown earlier. You can reset or delete it in your device settings (see section 7.6).
On iOS, the advertising identifier (IDFA) is not collected and tracking permission is not requested. Ad effectiveness is measured through SKAdNetwork, Apple's mechanism that passes only aggregated conversion statistics to the ad network without identifying an individual user.
Meta processes the data it receives in accordance with its Privacy Policy (https://www.facebook.com/privacy/policy) and may also use it for its own purposes as an independent data controller.
10.4. Crash reports
On Android, crash reports are collected by AppMetrica (section 10.2). On iOS, we receive crash reports from Apple only if you have allowed sharing them with developers (Settings → Privacy & Security → Analytics & Improvements).
10.5. Opting out of analytics and ad measurement
The available options are described in section 7.6.
11. INTERNATIONAL DATA TRANSFERS
Your personal data may be transferred to and processed in countries other than your country of residence. In particular, OpenAI and Meta Platforms process data in the United States, and our cloud infrastructure and analytics providers may host servers in various countries. In all such cases we ensure appropriate safeguards for personal data in accordance with applicable data protection law, including Standard Contractual Clauses where required.
12. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. If the changes are material, we will notify you in one or more of the following ways:
  • by posting the updated Privacy Policy in the App;
  • by updating the "Last updated" date at the top of this document.
By continuing to use the App after the changes take effect, you confirm your acceptance of the updated Privacy Policy.
13. CONTACT US
If you have questions, suggestions or requests regarding this Privacy Policy or the processing of your personal data, you can contact us:
Email: social@elixirlab.io
Website: https://elixirlab.io/feedback_form
Terms of Use: https://elixirlab.io/term_of_use
Elixir Lab ("we", "us", "our") operates the Elixir mobile application (the "App"). This Privacy Policy explains how we collect, use, share, store and protect your personal data when you use the App. By using the App, you agree to the collection and processing of information in accordance with this Privacy Policy.

1. WHAT INFORMATION WE COLLECT1.1. Account data
When you create an account, we collect:
  • your name and email address (provided through Sign in with Google or Sign in with Apple);
  • a unique user identifier;
  • your native language and the language(s) you are learning;
  • your answers during initial setup: why you are learning the language, what stops you from speaking, your preferred learning mode.
1.2. Usage data
We automatically collect information about how you interact with the App, including:
  • lesson progress and completion data;
  • speech diagnostic results and lesson reports (score, strengths and weak spots, phrases to fix);
  • words saved to your dictionary and learning statistics;
  • your conversation history with the AI tutor;
  • how you use the App's features and screens (screen views, taps, app launches, session length);
  • key events: onboarding completed, first lesson completed, paywall opened, trial started, purchase made;
  • your subscription status (Free or Premium).
1.3. Device information and identifiers
We may collect the following information:
  • device type, operating system and its version, device language and region;
  • the installed version of the App;
  • push notification tokens (Firebase Cloud Messaging on Android, Apple Push Notification service on iOS);
  • a device identifier generated by our analytics provider, AppMetrica. It is not an advertising identifier and is used to tell one installation from another;
  • on Android — the Google Advertising ID (GAID). It is collected by the Meta SDK to measure the effectiveness of our advertising campaigns (see section 10.3). You can reset or delete it in your Android settings;
  • on iOS — we do not collect Apple's advertising identifier (IDFA) and do not request App Tracking Transparency permission. The App does not track you across other companies' apps and websites.
1.4. Crash and performance data
To find and fix bugs we receive crash reports and technical data about how the App runs: the error type, the App's state at the moment of the crash, device model, OS and App version. On Android this data is collected by AppMetrica. On iOS, crash reports come from Apple only if you have allowed sharing them with developers in your device settings. This data does not contain the content of your lessons or conversations.
1.5. Audio data
When you use voice features:
  • voice recordings are sent to our servers and processed by our own speech recognition system (Speech-to-Text, STT) hosted on infrastructure under our control;
  • text-to-speech uses our own speech synthesis system (Text-to-Speech, TTS);
  • audio is processed in real time solely to perform the requested function and is not stored on our servers after STT/TTS processing;
  • we do not send voice recordings to OpenAI or any other third-party AI provider for speech recognition or synthesis;
  • microphone access is requested only when you start a spoken answer and is used for that purpose only.
1.6. Payment information
We do not collect or store your card details. All payments are processed through:
  • Apple App Store (for iOS users);
  • Google Play Store (for Android users).
From these platforms we receive a transaction confirmation and subscription details: the purchased plan, start and end dates, and status (trial, active, expired, cancelled). These details are verified on our servers and are needed to unlock paid features for you.
We send the fact that a trial started or a purchase was made, together with the amount and currency, to our analytics and ad measurement providers (see section 10). Card details, payer name and billing address are never sent to these providers and are not available to us.
2. HOW WE USE YOUR INFORMATION
We use the collected data to:
  • provide, maintain and improve the App;
  • create personalised AI-powered language lessons based on your level and progress;
  • track your learning progress and automatically adapt lesson difficulty;
  • manage your dictionary and vocabulary statistics;
  • process and verify subscription status;
  • send push notifications and practice reminders (with your consent);
  • analyse how the App is used in order to improve the user experience;
  • measure the effectiveness of our advertising campaigns: understand how many installs and purchases our ads bring;
  • find and fix crashes and errors;
  • inform you about updates and changes to the service;
  • detect and prevent fraud and abuse.
3. AI PROCESSING AND THIRD-PARTY AI SERVICES3.1. Third-party AI provider
To power AI features we use OpenAI (OpenAI, L.L.C. and its affiliates). The mobile App does not connect to OpenAI directly. Data is transferred only through our servers and only after you have seen the corresponding notice in the App and given your consent as described in section 3.5.
3.2. What data may be sent to OpenAI
When you use AI-based features, we may send to OpenAI only the data required for the selected feature to work. This includes:
  • the text you type in the chat (including daily lessons, practice tasks and other conversations);
  • the text produced by our STT system from your voice recording, if you send a voice message;
  • the learning context required for the AI to work correctly, including:
  • the language you are learning;
  • your native language;
  • the lesson topic;
  • your progress within the lesson;
  • the most recent messages of the current conversation;
  • your name or display name (when needed so that the AI can address you personally while building a learning plan or running lessons);
  • words and expressions you ask to be explained in the dictionary;
  • the content of messages used for grammar checking, word analysis or building a learning plan.
We do not send to OpenAI:
  • your email address;
  • your Apple or Google account identifiers;
  • card details or payment information;
  • advertising or device identifiers.
Your name is sent only when it is needed to personalise the conversation. For features that do not require personalisation (for example grammar checking or word descriptions), your name is not sent.
3.3. How we collect and use AI-related data
Collection. You provide text and voice data yourself when using:
  • chats;
  • lessons;
  • the dictionary;
  • voice features.
Information about your learning language and progress is taken from your account settings and the data stored on our servers.
Use. This data is used to:
  • generate the AI tutor's responses;
  • generate learning materials;
  • translate text;
  • check grammar;
  • explain words;
  • improve learning quality.
OpenAI processes this data solely to produce the model's response, which is returned to our App. Chat and lesson history is stored on our servers in accordance with section 6.
3.4. OpenAI's data processing practices
OpenAI provides a level of personal data protection comparable to the one described in this Privacy Policy. We use the OpenAI API, under which data sent through the API:
  • is not used to train or improve OpenAI's models;
  • is processed solely to produce a response to our request.
For international data transfers we rely on appropriate contractual safeguards, including Standard Contractual Clauses (SCC). OpenAI processes data in accordance with its own Privacy Policy and Terms of Use. We also choose service providers that apply appropriate technical and organisational measures to protect personal data.
3.5. Your consent before data is sent to OpenAI
Before any of the data listed in section 3.2 is sent for the first time, the App shows a separate notice stating:
  • which categories of data will be sent;
  • that the recipient is OpenAI;
  • how this data is used to power AI features.
Data transfer starts only after you tap "I agree". If you choose "Not now", no data is sent to OpenAI, and features that require OpenAI are unavailable. You can withdraw your consent at any time in Settings by turning off data sharing with OpenAI. After withdrawal, AI features remain unavailable until you give consent again. Accepting the Terms of Use or this Privacy Policy when signing in does not by itself constitute consent to sending data to OpenAI.
3.6. Use of anonymised data
We may use AI outputs, as well as aggregated and anonymised statistics that cannot identify a specific user, to improve lesson quality and develop the App further.
4. SHARING AND DISCLOSURE4.1. Sale of personal data
We do not sell your personal data to third parties.
4.2. Sharing with service providers
We may share your information with the following categories of service providers, only to the extent necessary to provide the corresponding features:
  • Authentication providers — Google and Apple (for signing in).
  • Cloud infrastructure — to host the App's backend, database and storage.
  • Third-party AI provider — OpenAI (to generate learning materials, AI tutor responses, grammar checks, word analysis and dictionary descriptions), only after you have given consent in the App as described in section 3.5.
  • Speech processing — our own speech recognition (STT) and speech synthesis (TTS) systems running on GPU servers we own. Voice data is not sent to OpenAI for speech recognition or synthesis.
  • Analytics — AppMetrica (to analyse App usage and collect crash reports), see section 10.2.
  • Ad measurement — Meta Platforms (the Meta SDK, to measure the effectiveness of advertising campaigns), see section 10.3.
  • Push notification services — Firebase Cloud Messaging (Google) and Apple Push Notification service.
  • Payment platforms — Apple App Store and Google Play (processing purchases and subscriptions).
4.3. Disclosure required by law
We may disclose your information when required by:
  • law;
  • regulation;
  • a court order;
  • an official request from a public authority;
  • other legally mandated procedures.
4.4. Business transfers
In the event of a merger, acquisition or sale of assets, your data may be transferred to the organisation that becomes the successor of the relevant assets or service.
Privacy Policy
Last update: 5 September 2026 г.
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