This Privacy Policy explains how Learny ("we," "us," or "our") collects, uses, stores, and protects your personal data when you use our AI Czech language tutoring service ("Service").
We are committed to protecting your privacy and handling your data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).
2. Data Controller
The data controller responsible for your personal data is:
We collect the following categories of data when you use the Service:
3.1 Telegram Account Data
Telegram user ID (numeric identifier)
Username (if set)
Display name (first name and last name, if provided)
Language preference settings
3.2 Conversation Data
Text messages you send to the bot
Voice messages and their transcriptions
Bot responses and conversation history
3.3 Learning Data
Language level assessment results
Error correction history
Learning progress and topic preferences
3.4 Usage Data
Message counts and frequency
Daily streak information
Feature usage statistics
Dates and times of interactions
3.5 Payment Data
Payment processing is handled by Tribute.tg. We do not collect, store, or have access to your credit card numbers, bank account details, or other financial information. Tribute.tg may share with us:
Subscription status (active, cancelled, expired)
Payment confirmation and transaction IDs
Email address (if provided during checkout)
4. How We Use Your Data
We use your personal data for the following purposes:
Service delivery: To provide AI-powered Czech language tutoring, process your messages, and generate personalized responses
Personalization: To assess your language level, adapt content difficulty, and track your learning progress
Error correction: To analyze your messages for language errors and provide helpful corrections
Service improvement: To understand usage patterns and improve the quality of our AI tutoring
Communication: To send you important service updates, billing notifications, and respond to support requests
Abuse prevention: To detect and prevent misuse of the Service
5. Legal Basis for Processing
We process your personal data based on the following legal grounds under the GDPR:
Performance of a contract (Art. 6(1)(b)): Processing necessary to deliver the Service you have subscribed to
Consent (Art. 6(1)(a)): Where you have given explicit consent, such as starting the bot and sending messages
Legitimate interest (Art. 6(1)(f)): For service improvement, analytics, and abuse prevention, balanced against your rights and freedoms
Legal obligation (Art. 6(1)(c)): Where we are required to retain data by law
6. Third-Party Processors
We share your data with the following third-party service providers, who process it on our behalf or as part of delivering the Service:
6.1 OpenAI
Purpose: AI text generation (GPT-4o-mini) and speech-to-text transcription (Whisper)
Conversation history: Retained while your account is active, deleted within 30 days of account deletion request
Learning progress data: Retained while your account is active
Voice messages: Processed in real-time for transcription and not stored after processing
Usage statistics: Retained in aggregated, anonymized form indefinitely for service improvement
Billing records: Retained as required by applicable tax and accounting laws (typically up to 10 years)
When you request account deletion, we will delete or anonymize your personal data within 30 days, except where retention is required by law.
8. Your Rights
Under the GDPR and applicable data protection laws, you have the following rights:
Right of access: Request a copy of the personal data we hold about you
Right to rectification: Request correction of inaccurate or incomplete data
Right to erasure: Request deletion of your personal data ("right to be forgotten")
Right to data portability: Request your data in a structured, machine-readable format
Right to restrict processing: Request that we limit how we use your data
Right to object: Object to processing based on legitimate interest
Right to withdraw consent: Withdraw consent at any time where processing is based on consent
To exercise any of these rights, please contact us at support@learny.cz. We will respond to your request within 30 days.
You also have the right to lodge a complaint with a supervisory authority, such as the Czech Office for Personal Data Protection (UOOU).
9. International Data Transfers
Some of our third-party processors (OpenAI, Tribute.tg, Railway) are located in the United States. When your data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including:
EU-U.S. Data Privacy Framework certification
Standard Contractual Clauses (SCCs) approved by the European Commission
10. Children's Privacy
The Service is not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware that we have collected data from a child under 16, we will take steps to delete that information promptly.
If you are a parent or guardian and believe your child has provided us with personal data, please contact us at support@learny.cz.
11. Cookies
Our website (learny.cz) uses minimal cookies:
Essential cookies: Required for basic website functionality (e.g., navigation, security)
We do not use tracking cookies, advertising cookies, or third-party analytics cookies on our website. The Telegram bot does not use cookies.
12. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes:
We will update the "Last updated" date at the top of this page
We will notify you through the Telegram bot or via email
We encourage you to review this policy periodically. Continued use of the Service after changes constitutes acceptance of the updated policy.
13. Contact Information
For any questions, concerns, or requests related to your privacy or this policy, please contact us: