Privacy policy

This policy explains what personal data we process, why we use it, who it may be shared with and what rights you can exercise.

1. Data controller

Controller: Carlos Hinojosa Pinto
Address: Hohle Gasse 12, Bern, Switzerland
Privacy contact: jacklyt.code@gmail.com

2. Data we may process

Account data such as email address, name, profile picture and account identifiers.
Authentication and session data needed to maintain and protect your account.
Learning preferences such as interface language and the language you are learning.
Learning and usage information such as saved vocabulary, progress, history, Premium status, credit balance and tool usage.
Content submitted to service features, such as text, images, prompts and messages sent in AI-character chats.
Technical and security data such as IP address, basic device information and logs needed to prevent abuse or troubleshoot errors.
Information related to credit purchases. The payment provider may process the information required to process payment directly.
Google Analytics data where this technology is enabled and there is a valid legal basis for its use.
AI-character chat history is stored in our Cloudflare infrastructure so that it can be associated with your account and used within the service.

3. Why we use the data

Purpose	Typical data	Legal basis
Create and manage your account and save your preferences and progress.	Account, session, preferences and learning data.	Performance of the requested service.
Show vocabulary, generate vocabulary with AI, provide reading texts and enable AI-character chats.	Preferences, prompts, text, images, messages and learning data.	Performance of the requested service.
Manage credit purchases, balances and Premium access.	Account, transactions, balance, Premium status and payment metadata.	Performance of a contract and applicable legal obligations.
Maintain security and prevent fraud or abuse.	Session data, technical logs and security information.	Legitimate interests and, where applicable, legal obligations.
Non-essential analytics used to measure and improve use of the platform.	Cookies, identifiers and similar technologies.	Consent where required.

4. Providers and recipients

We may use external providers to deliver certain features. They should access only the data needed to provide their services and must apply the safeguards required by applicable law.

Artificial intelligence: OpenAI
Hosting / infrastructure: Cloudflare
Payments: Paddle
Analytics: Google Analytics (Google)

5. International transfers

OpenAI, Cloudflare, Paddle and Google may process data using international infrastructure, which may involve transfers of data from Switzerland to other countries. Where a destination country does not provide an adequate level of protection, safeguards required by applicable law, such as recognised contractual clauses, will be used where appropriate.

6. Retention

We keep data while it is needed to provide the service and maintain the account. Afterwards, some data may be retained for the periods necessary to comply with legal obligations or handle claims.

AI-character chat history is stored in Cloudflare and retained for as long as needed to provide the history associated with the account, unless deletion is requested or retention is required by law.

Data that you can delete from the application will cease to be available according to the service's operation, subject to temporary backups or legally required retention.

7. Artificial intelligence and automated decisions

AI features automatically generate content from your instructions and learning parameters. We do not use these features to make decisions that produce legal effects concerning you or similarly significantly affect you.

8. Your rights

You may exercise the rights granted by applicable law, including where relevant access, rectification, erasure, objection, restriction and portability.

To exercise them, contact jacklyt.code@gmail.com. We may request information reasonably necessary to verify your identity.

You may also lodge a complaint with the competent data-protection authority.

9. Children

The service must be used in accordance with applicable age and parental-consent requirements. If we identify a child's data being processed without the required authorisation, we may delete it or restrict the account.

10. Security

We apply reasonable technical and organisational measures to protect data against unauthorised access, loss, alteration or improper disclosure. No Internet-connected system can guarantee absolute security.

11. Changes and contact

We may update this Privacy Policy to reflect legal, technical or functional changes.

For privacy or data-protection questions, contact jacklyt.code@gmail.com.