Privacy Policy (International version for app stores)

This version applies to users who access Speakylex via app stores (e.g. Google Play, App Store) or other distribution platforms in the European Union, European Economic Area, and other countries outside the CIS. It describes how we process your personal data in line with the EU General Data Protection Regulation (GDPR) and applicable national laws. For users in the CIS, the standard Privacy Policy (RU/EN) may apply.

1. Data Controller
The data controller responsible for your personal data in relation to the Speakylex application is:
Sole Proprietor LATAREVICH YAUHENI IOSIFOVICH, UNP 591378924.
Contact: contact@speakylex.com.

2. What Data We Process and Why
2.1. We process personal data necessary to provide the Speakylex service: identification, personalisation of learning content, analysis of progress, provision of paid features, support and improvement of the service.
2.2. Categories of data: name, email address, learning progress and created materials, technical data (e.g. IP address, device identifiers, cookies, Android Advertising ID (GAID) where available), and where applicable identifiers from the distribution platform (e.g. Google Play).
2.3. Cookies and similar technologies: We use cookies and local storage for authentication, preferences, analytics and service improvement. You can restrict or disable them in your browser or device; some features may then be unavailable.
2.4. We do not transfer your personal data to external AI providers or third-party AI services. Any AI-based processing (e.g. recommendations) is done within our own systems.

3. Legal Basis (GDPR Art. 6)
We process your data on the following bases:
— Contract: performance of our agreement with you (account, learning features, paid services).
— Consent: where you have given clear consent (e.g. marketing, optional features). You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
— Legitimate interests: improving the service, security, fraud prevention, where not overridden by your rights.
— Legal obligation: where required by applicable law (e.g. tax, accounting).

4. Your Rights (GDPR)
You have the right to:
— Access (Art. 15): obtain confirmation as to whether we process your data and a copy of that data.
— Rectification (Art. 16): have inaccurate data corrected.
— Erasure (Art. 17): request deletion of your data in the cases set out in the GDPR (e.g. consent withdrawn, no longer necessary, unlawful processing).
— Restriction of processing (Art. 18): in certain situations, limit how we use your data.
— Data portability (Art. 20): receive your data in a structured, commonly used format where the processing is based on contract or consent and is carried out by automated means.
— Object (Art. 21): object to processing based on legitimate interests or to processing for direct marketing.
— Withdraw consent at any time where processing is based on consent.
— Lodge a complaint with a supervisory authority in your country (e.g. in the EU, the data protection authority of your member state).
To exercise these rights, contact us at contact@speakylex.com (e.g. subject: "Privacy – Data request" or "Account Deletion"). We will respond within one month, extendable where necessary.

5. Data Retention
We keep your data only as long as needed for the purposes above or as required by law. After you delete your account or withdraw consent, we erase or anonymise your data within 30 calendar days, except where we must retain it for legal obligations (e.g. tax, accounting). Data used only for the service (e.g. progress, your content) is deleted with your account.

6. Sharing and Transfers
6.1. We do not sell your personal data. We may share data with: (a) service providers who process data on our instructions (e.g. hosting, payment platforms, analytics and application reliability monitoring), under contracts that ensure appropriate safeguards; (b) authorities when required by law. The myTracker SDK may be used for analytics and monitoring.
6.2. If we transfer data outside the European Economic Area, we do so only where the European Commission has decided that the country ensures an adequate level of protection, or with appropriate safeguards (e.g. standard contractual clauses) and enforceable rights.

7. Minors
The service is aimed at users aged 16 or over. If you are under 16 (or the higher age of consent in your country), we process your data only with consent from a parent or guardian (e.g. sent to contact@speakylex.com with the minor’s identifier and the parent’s contact details). If we discover an account of a user below the minimum age without such consent, we delete that user’s data within 24 hours.

8. Security and Breaches
We implement appropriate technical and organisational measures to protect your data. If a breach is likely to result in a high risk to your rights, we will inform you and the competent supervisory authority as required by applicable law.

9. Updates and Contact
We may update this Policy. The current version is published at: https://speakylex.com/core/policies/playmarket/privacy-policy/en. For any questions about your personal data, contact us at contact@speakylex.com.