Privacy Policy

Last updated: [DATE] Effective Date: [DATE]

Your Privacy Matters

[SERVICE NAME] ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, share, and safeguard your information when you use our AI-powered language learning service.

Quick Summary: We collect your messages, conversations, usage data, and contact information to provide our AI language service, save your progress, and send you service updates and promotional content (with your consent). Russian users' data is stored in Russia in compliance with Federal Law 152-FZ. You have full control over your data and can access, modify, or delete it at any time.

Language Note: This Privacy Policy is available in multiple languages. For Russian users, the Russian version governs in case of conflicts.

1. Information We Collect

1.1 Information You Provide Directly

Account Information:

Email address (required)
Name and profile information (optional)
Account preferences (native language, interface settings)
Password and authentication credentials

Learning Content:

Chat conversations and messages with our AI service
Text submitted for translation and saved translations
Language learning exercises and responses
Test results and assessment scores (when available)
Saved phrases, vocabulary, and learning materials

Communication Data:

Support requests and correspondence
Feedback and survey responses
Marketing communication preferences

Payment Information:

Subscription billing details (processed securely by third-party payment providers)
We do not store complete payment card information

1.2 Information We Collect Automatically

Usage Analytics:

Features used and interaction patterns
Session duration and frequency of use
Learning progress and performance metrics
User interface preferences and customizations

Technical Information:

Device type, operating system, and browser information
IP address and general location (country/region level)
Device identifiers and system performance data
Error logs and technical diagnostics

Cookies and Similar Technologies:

Authentication cookies for login sessions
Preference cookies for settings and customizations
Analytics cookies for service improvement (with consent)
Security cookies for fraud prevention

2. Legal Basis for Processing Your Information

We process your personal information based on the following legal grounds:

2.1 Contract Performance

Providing our AI language learning service
Managing your subscription and account
Processing payments and billing
Delivering customer support

2.2 Explicit Consent

Sending marketing and promotional emails
Using analytics cookies and tracking
Processing data for service improvement research
Sharing data with specific third-party integrations

2.3 Legitimate Interests

Improving service quality and user experience
Ensuring platform security and preventing fraud
Analyzing usage patterns for product development
Providing technical support and troubleshooting

2.4 Legal Obligations

Complying with applicable data protection laws
Responding to law enforcement requests
Maintaining records for tax and accounting purposes

3. How We Use Your Information

3.1 Core Service Provision

AI Language Processing: Generating responses to your messages and questions
Progress Tracking: Saving your learning history, translations, and achievements
Personalization: Customizing content and recommendations based on your learning patterns
Account Management: Managing registration, authentication, and subscription services

3.2 Service Improvement

Performance Analytics: Understanding how users interact with our service
Error Detection: Identifying and fixing technical issues
Feature Development: Developing new features based on user needs
Quality Assurance: Monitoring service quality and user satisfaction

3.3 Communication

Service Notifications: Important account and service updates
Customer Support: Responding to your questions and technical issues
Marketing Communications: Promotional emails about new features (only with your explicit consent)
Legal Notices: Privacy policy updates and terms of service changes

3.4 Security and Compliance

Fraud Prevention: Detecting and preventing abuse of our service
Security Monitoring: Protecting against unauthorized access
Legal Compliance: Meeting obligations under applicable privacy laws
Rights Protection: Protecting our intellectual property and user rights

4. How We Share Your Information

4.1 We Do NOT Sell Your Personal Information

We never sell, rent, or trade your personal information to third parties for marketing or commercial purposes.

4.2 Service Providers (Data Processors)

We share information with trusted service providers who help operate our service:

AI Language Models:

OpenAI/Anthropic: For AI-powered conversation processing (subject to their privacy policies)
Data shared: Your messages and prompts (processed securely)

Infrastructure Providers:

Cloud Hosting: Secure servers for data storage and processing
Russian Users: Data stored exclusively on Russian Federation servers
Email Services: For sending service and marketing communications

Analytics and Support:

Analytics Providers: For usage statistics and service improvement
Customer Support Platforms: For managing support tickets and inquiries

4.3 Legal Requirements

We may disclose information when required by law or to:

Comply with legal processes, subpoenas, or court orders
Respond to government requests or law enforcement
Protect our rights, property, or safety
Prevent fraud, abuse, or violations of our terms
Enforce our Terms of Service and other policies

4.4 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction, subject to equivalent privacy protections.

5. International Data Transfers and Localization

5.1 Russian Federation Users

Data Localization Compliance: In accordance with Federal Law No. 152-FZ "On Personal Data," all personal data of Russian citizens is:

Stored: On servers physically located within the Russian Federation
Processed: Using databases located in Russian territory
Protected: According to Russian data protection standards

Cross-Border Transfers: While your primary data copy remains in Russia, limited data may be transferred internationally for:

AI processing by approved providers
Technical support and maintenance
Service improvement analytics

All international transfers comply with Russian law requirements and include appropriate safeguards.

5.2 Other Countries

For users outside Russia, data may be processed internationally with appropriate safeguards:

Standard Contractual Clauses: Legal agreements ensuring data protection
Adequacy Decisions: Transfers to countries with adequate privacy protections
Technical Safeguards: Encryption and security measures during transfer

6. Data Security

6.1 Technical Safeguards

Encryption: Data encrypted in transit (HTTPS/TLS) and at rest (AES-256)
Access Controls: Multi-factor authentication and role-based access
Infrastructure Security: Secure cloud infrastructure with regular updates
Network Protection: Firewalls, intrusion detection, and monitoring systems

6.2 Organizational Measures

Staff Training: Regular security and privacy training for all employees
Access Limitation: Strict need-to-know basis for accessing personal data
Regular Audits: Periodic security assessments and vulnerability testing
Incident Response: Procedures for detecting and responding to data breaches

6.3 Data Breach Notification

In the event of a data breach affecting your personal information, we will:

Immediate Response: Contain and assess the breach within 24 hours
Authority Notification: Report to relevant authorities within 72 hours
User Notification: Inform affected users promptly with breach details
Remedial Action: Implement measures to prevent similar incidents

7. Your Privacy Rights

7.1 Universal Rights (All Users)

Access Rights:

Request information about what personal data we collect and process
Receive a copy of your personal data in a readable format
Understand how and why we process your information

Control Rights:

Rectification: Correct inaccurate or incomplete personal data
Deletion: Request deletion of your personal data ("right to be forgotten")
Restriction: Limit how we process your personal data
Portability: Receive your data in a structured, machine-readable format
Objection: Object to processing for direct marketing or legitimate interests

7.2 Regional-Specific Rights

Russian Federation Users (Federal Law 152-FZ):

Right to information about data processing purposes and legal basis
Right to withdraw consent at any time
Right to demand cessation of processing for direct marketing
Right to compensation for damages caused by violations
Contact Authority: Roskomnadzor (rkn.gov.ru, +7 (495) 987-67-67)

Brazilian Users (LGPD):

Right to confirmation of data processing
Right to access personal data and processing information
Right to correction of incomplete or inaccurate data
Right not to be subject to automated decision-making
Contact Authority: ANPD (anpd.gov.br)

Argentine Users (Personal Data Protection Law):

"Habeas Data" rights for access, rectification, and deletion
Right to information about data processing
Right to object to processing
Contact Authority: AAIP (argentina.gob.ar/aaip)

Mexican Users (LFPDPPP):

ARCO Rights: Access, Rectification, Cancellation, Opposition
Right to limit use and disclosure of personal data
Right to withdraw consent
Contact Authority: INAI (inai.org.mx)

7.3 How to Exercise Your Rights

Self-Service Options:

Account Settings: Access privacy controls in your user dashboard
Download Data: Export your data directly from account settings
Delete Account: Initiate account deletion through settings

Contact Methods:

Email: [privacy@yourservice.com]
Online Form: [Privacy Request Form URL]
Written Request: [Business mailing address]

Response Times:

Acknowledgment: Within 5 business days
Completion: Within 30 days (or as required by local law)
Complex Requests: May require up to 60 days with notification

8. Marketing Communications and Consent

8.1 Email Marketing Consent

Opt-In Requirements: We only send promotional emails to users who have provided explicit consent by:

Checking the marketing consent checkbox during registration (unchecked by default)
Opting in through account settings
Confirming subscription via double opt-in email verification

What We Send:

New feature announcements and product updates
Educational content and learning tips
Special offers and promotions
Service news and company updates

8.2 Withdrawal of Consent

You can withdraw marketing consent at any time through:

Unsubscribe Links: Click unsubscribe in any marketing email
Account Settings: Modify email preferences in your dashboard
Direct Contact: Email us at [support@yourservice.com]

Processing Time: Unsubscribe requests processed within 5 business days.

8.3 Transactional Communications

Some communications are necessary for service operation and cannot be opted out of:

Account security alerts and password resets
Subscription billing and payment notifications
Critical service updates and maintenance notices
Terms of Service or Privacy Policy changes

9. Cookies and Tracking Technologies

9.1 Types of Cookies We Use

Essential Cookies (Always Active):

User authentication and login sessions
Account preferences and settings
Security and fraud prevention
Basic functionality and navigation

Analytics Cookies (With Consent):

Usage statistics and performance metrics
Feature usage and user interaction patterns
Error tracking and technical diagnostics
Service improvement insights

Preference Cookies (With Consent):

Language and interface customizations
Saved preferences and personalizations
Learning progress and achievements

9.2 Third-Party Cookies

Analytics Services: [Google Analytics] for usage insights
Support Services: Customer support chat functionality
Payment Processing: Secure payment form functionality

9.3 Managing Cookies

Browser Controls:

Configure cookie settings through your browser preferences
Block or delete cookies at any time
Opt out of tracking through browser settings

Our Controls:

Cookie preference center (where available)
Granular consent options during first visit
Account settings for ongoing preference management

10. Data Retention

10.1 Active Accounts

We retain your personal information while your account is active and for the duration necessary to provide our services.

Specific Retention Periods:

Account Information: While account is active + 30 days after deletion
Conversation History: While account is active + 30 days after deletion
Usage Analytics: 2 years from collection (anonymized after 1 year)
Support Communications: 3 years for quality assurance purposes
Payment Records: As required by tax and accounting laws (typically 7 years)

10.2 Account Deletion

When you delete your account:

Immediate: Account access disabled and deletion process initiated
30 Days: Personal data permanently deleted from active systems
90 Days: Data removed from backups and archives
Legal Retention: Some data may be retained longer for legal compliance

10.3 Inactive Accounts

Accounts inactive for 3+ years may be automatically deleted after:

Email notification 60 days before deletion
Final warning 30 days before deletion
Opportunity to reactivate account and retain data

11. Children's Privacy

11.1 Age Restrictions

Our service is intended for users aged 13 and older. We do not knowingly collect personal information from children under 13.

11.2 Parental Rights

If you believe your child under 13 has provided us with personal information:

Contact us immediately at [privacy@yourservice.com]
Provide verification of parental relationship
We will delete the information within 30 days of verification

11.3 Teen Privacy (13-17)

Users between 13-17 should:

Have parental consent before using our service
Review this policy with a parent or guardian
Understand their privacy rights and data collection practices

12. Third-Party Integrations

12.1 AI Language Providers

OpenAI/Anthropic Claude:

Data Shared: Your messages and prompts for AI processing
Purpose: Generating language learning responses
Their Policy: Subject to their respective privacy policies
Retention: Processed according to their data retention policies

12.2 Translation Services

[Translation Provider]:

Data Shared: Text submitted for translation
Purpose: Providing translation functionality
Retention: Not stored permanently by translation provider

12.3 Analytics and Support

Analytics Providers:

Anonymized usage data for service improvement
No personally identifiable information shared

Customer Support:

Support ticket content and correspondence
Used solely for providing technical assistance

13. Updates to This Privacy Policy

13.1 Policy Changes

We may update this Privacy Policy to reflect:

Changes in our service or business practices
New legal requirements or regulatory changes
Enhanced privacy protections or user controls
User feedback and service improvements

13.2 Notification Process

Material Changes:

Email notification to all registered users
Prominent notice on our website and in-app
30-day advance notice before changes take effect

Minor Changes:

Updated "Last Modified" date
Notification through our service
Continued use constitutes acceptance

13.3 Version Control

Previous versions available upon request
Record of when users accepted each version
Clear changelog of modifications made

14. Regional Compliance Information

14.1 Russian Federation

Governing Law: Federal Law No. 152-FZ "On Personal Data" Data Localization: All Russian user data stored within Russian Federation Authority: Roskomnadzor Local Representative: [To be appointed]

14.2 Brazil

Governing Law: Lei Geral de Proteção de Dados (LGPD) Authority: Autoridade Nacional de Proteção de Dados (ANPD) DPO: [Data Protection Officer contact]

14.3 Argentina

Governing Law: Personal Data Protection Law No. 25,326 Authority: Agencia de Acceso a la Información Pública (AAIP)

14.4 Mexico

Governing Law: Ley Federal de Protección de Datos Personales (LFPDPPP) Authority: Instituto Nacional de Transparencia (INAI)

15. Contact Information

15.1 General Inquiries

Email: [hello@yourservice.com] Support: [support@yourservice.com] Address: [Business Address]

15.2 Privacy-Specific Contacts

Privacy Officer: [privacy@yourservice.com] Data Protection Officer: [dpo@yourservice.com] (if applicable) Russian Representative: [russia@yourservice.com] (when established)

15.3 Regulatory Authorities

If you have concerns about our privacy practices, you may also contact:

Russia: Roskomnadzor (rkn.gov.ru) Brazil: ANPD (anpd.gov.br) Argentina: AAIP (argentina.gob.ar/aaip) Mexico: INAI (inai.org.mx)

15.4 Response Commitments

Privacy Inquiries: Response within 5 business days
Rights Requests: Completion within 30 days
Urgent Matters: Response within 24 hours
Complex Requests: Up to 60 days with progress updates

Language Versions: This Privacy Policy is available in multiple languages. In case of conflicts between language versions, the version in your local language (Russian for Russian users, Spanish/Portuguese for Latin American users) shall govern.

Effective Date: This Privacy Policy is effective as of [DATE] and was last updated on [DATE].

By using our service, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy.