1. Introduction
This Privacy Policy explains how AtoC.ai collects, uses, stores, and protects your personal data. It applies to all users regardless of location and incorporates requirements under GDPR (EU), CCPA (California, USA), LGPD (Brazil), KVKK (Türkiye), and Russian Federal Law 152-FZ.
2. Data Controller
Maksim Golitsyn
Türkiye
3. Information We Collect
- Account data: email address, display name, username, profile photo, birthday.
- Learning data: vocabulary progress, grammar completion, XP, streaks, training history, achievements.
- Device data: device type, OS version, push tokens, IP address (hashed), device fingerprint.
- Payment data: subscription status, plan type, transaction identifiers (processed by Apple, Google, or RevenueCat; we do not store full payment card data).
- Communication data: feedback submissions, support requests, email correspondence.
4. Legal Bases for Processing
We process personal data on the following legal bases:
- Performance of a contract — to provide the language learning service you signed up for.
- Consent — for newsletters, optional analytics, and marketing communications.
- Legitimate interests — for fraud prevention, security, service improvement, and analytics.
- Legal obligation — to comply with applicable laws and regulations.
5. Your Rights
Depending on your jurisdiction, you may have the right to:
- Access the personal data we hold about you.
- Request correction or deletion of your data.
- Object to or restrict certain processing activities.
- Request data portability in a machine-readable format.
- Withdraw consent at any time (without affecting prior lawful processing).
- Lodge a complaint with your local data protection authority.
To exercise these rights, please use the in-app support channel.
6. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. When you delete your account, we initiate a secure deletion process in accordance with our data retention schedule.
7. International Transfers
Your data may be stored and processed in jurisdictions other than your own. When transferring data internationally, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs) or adequacy decisions to ensure compliance with GDPR and other applicable frameworks.
8. Cookies and Tracking Technologies
We use cookies and similar technologies to operate the service, analyze usage, and improve user experience. For more details, see our Cookie Policy.
9. Children’s Privacy
AtoC.ai is not intended for children under 13. We do not knowingly collect data from children under 13. If you believe we have collected data from a child under 13, contact us immediately.
10. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version will be indicated by a revised date. Continued use of the service after changes constitutes acceptance of the revised policy.