1. INFORMATION WE COLLECT

We categorize data based on the source of its collection:

1.1. Data You Provide to Us:

• Account: We use a reliable authentication provider for registration and login. We receive only basic identifiers (email, internal user ID). We do not receive or store your passwords.

• AI Interaction: Text inputs you enter for learning purposes are processed by our algorithms and partner models. This data is used exclusively for generating responses.

1.2. Automatically Collected Data:

• Technical Diagnostics: To ensure the stable operation of the App, we use crash reporting tools. In the event of an App failure, we may receive a report containing information about the device type, OS version, and the state of the application at the time of the error. This data does not allow for the identification of your person.

• Notifications: To send service messages (push notifications), we may process your device's technical token.

• Usage Data: We collect anonymized statistics on how you use the App's features to improve the interface.

• Server Logs: For security purposes and fraud protection (e.g., DDoS attacks), our servers may temporarily record your IP address in technical logs.

1.3. Payment Information: All transactions are processed directly through the Apple App Store or Google Play Store. We only receive the status of your subscription (active/inactive) and its expiration date. We do not have access to your payment card data.

2. HOW WE USE YOUR DATA

We use the collected information to:

• Provide access to the App's functionality (language learning, AI chat).

• Process your subscriptions and purchases.

• Detect and rectify technical errors.

• Prevent fraud and ensure infrastructure security.

3. DATA TRANSFER TO THIRD PARTIES

We do not sell your personal data. To ensure the operation of the App, we engage verified technical partners (Data Processors):

• Cloud Infrastructure Providers: For secure database hosting.

• Authentication Services: For secure system login.

• AI Model Providers: For processing requests within learning features. Data is transferred in an anonymized form.

• Analytical and Technical Services: For monitoring the stability of the App and analyzing failures.

4. INTERNATIONAL TRANSFER AND SECURITY

• Storage Location: Main user data is stored on secure servers within the European Union (in accordance with GDPR standards).

• Security Measures: We use encryption at rest and secure communication channels (TLS/SSL). Access to the administrative panel is restricted exclusively to authorized developers.

5. YOUR RIGHTS AND CONTROL

You have the right to access, rectify, delete, and transfer your data.

CCPA Notice (Special Notice for California Residents):

• Right to Know: You have the right to know what categories of personal data we have collected over the past 12 months.

• Do Not Sell My Personal Information: We do not sell (as defined by the CCPA) your personal information to third parties.

• Right to Delete: You may request the deletion of your personal information, subject to certain exceptions provided by law (e.g., to complete a transaction or detect security incidents).

6. DATA RETENTION

We retain your data while your account is active.

• Account Deletion: If you initiate account deletion through the App settings, your personal data (name, email) will be removed from our active databases within 30 days.

• Exceptions: We may retain anonymized transaction data (without a link to your identity) for the period necessary for tax reporting and fulfilling obligations to app stores.

• Inactivity: If an account remains inactive for more than 3 years, we reserve the right to delete it automatically.

7. CHILDREN'S PRIVACY

The App is intended for a general audience. We do not knowingly collect personal data from children under the age of 13 (or the relevant age of consent in your jurisdiction) without parental consent.

8. CONTACTS

If you have questions regarding this Policy or wish to exercise your rights (e.g., delete data), please contact us:

Email: support@balabo.app