Privacy Policy

Last updated: June 19, 2026

    We collect the minimum data required to operate the Service. No advertising, no selling data to third parties.
  

1. Data Controller

The data controller is Oleksii Hiria (individual), contact: [email protected] / [email protected].

2. Data We Collect

Category	Data	Purpose
Telegram identifier	user_id, username, display name	Account identification within the Service
Settings	Interface language, exam type, reminder time	Service personalisation
Learning progress	Question answers, correct count, question status	Readiness Score calculation, Error Deck algorithm
Payment data	Transaction ID, plan, date, email (if provided at checkout)	PRO access confirmation

We do not collect: card details, passport or ID data, geolocation, phone contacts, or the content of other Telegram chats.

3. Legal Basis (GDPR)

Performance of a contract (Art. 6(1)(b)) — processing is necessary to provide the Service you subscribed to
Legitimate interest (Art. 6(1)(f)) — improving Service quality and preventing abuse
Legal obligation (Art. 6(1)(c)) — retaining payment records as required by law

4. Data Retention

Learning progress data — until account deletion or upon your request
Payment records — 5 years as required by accounting regulations
After account deletion (/delete_my_data) — all data is deleted within 30 days, except payment records

5. Third-Party Data Sharing

We do not sell or share your data with third parties for marketing purposes. Data may be shared only with:

Paddle — payment platform processing PRO access payments. Paddle is an independent Merchant of Record with its own Privacy Policy
Railway — hosting platform where the Service database is stored (EU servers)
Sentry — error monitoring (anonymised technical logs only)
When required by law or court order

6. Your Rights (GDPR)

As a data subject in the EU, you have the right to:

Access — receive a copy of your data
Rectification — correct inaccurate data
Erasure — delete your data (use /delete_my_data in the bot)
Restriction — restrict processing of your data
Portability — receive your data in a structured format
Objection — object to processing based on legitimate interest

To exercise your rights, contact: [email protected]. We respond within 30 days.

You also have the right to lodge a complaint with your national data protection authority (in Poland — UODO: uodo.gov.pl).

7. Security

Data is stored in a secured PostgreSQL database on the Railway platform. Database access is restricted and protected. All data transfers use encrypted connections (TLS).

8. Cookies

The Telegram bot does not use cookies. This website uses only technically necessary resources (system fonts) and does not collect analytics.

9. Policy Updates

We will notify you through the Service of any significant changes. The current version is always available on this page.

10. Contact

Privacy enquiries: [email protected] or [email protected]