Privacy Policy

Last updated: October 15, 2026 (replaces the version of September 28, 2026). This Policy is prepared in accordance with the EU General Data Protection Regulation (GDPR, Regulation 2016/679).

Jai Tutor is an offline-first language learning app for Android and iOS. This Policy explains what personal data the app processes, for what purposes, on what legal basis, and how you can exercise your rights.

1.Who processes the data (controller)

Data controller: Roman Zatolokin, a natural person carrying out individual activity (individuali veikla) in the Republic of Lithuania; Individual Activity Certificate (Pažyma) No. 1215311. Address: Bukčių g. 4-49, LT-04127 Vilnius, Lithuania.

Contact: jaitutor.app@gmail.com.

2.Summary

3.What data we process and why

DataPurposeLegal basisWhere / retention
Learning progress, level, language pair, settings, flashcard history Running the learning features Performance of a contract (Art. 6(1)(b) GDPR) Only on your device. Deleted when you clear app data or uninstall the app
Voice (microphone) Speech recognition in exercises Performance of a contract (Art. 6(1)(b)) Processed only on your device by the offline model; not recorded, stored or transmitted
AI Conversation Partner: text of your messages (up to the last 10 messages, each up to 2,000 characters), selected language, level and topic Generating the partner's replies and feedback Performance of a contract (Art. 6(1)(b)) Sent to our server and forwarded to OpenAI for processing. Not stored on our server. OpenAI processes it under its API data terms (see section 4)
App-instance identifier (device_id) and daily message counter Applying daily message limits, protection against abuse Performance of a contract (Art. 6(1)(b)); legitimate interest in preventing abuse (Art. 6(1)(f)) Counter: about 25 hours, then deleted automatically
Purchase data: purchase token, product, platform Verifying that your subscription is active Performance of a contract (Art. 6(1)(b)) Verified with Google Play or Apple; the resulting status is cached for 12 hours
AI Conversation Partner session statistics (Premium only): language, level, topic, score, number of messages Keeping your AI Conversation Partner learning statistics Performance of a contract (Art. 6(1)(b)) 90 days, then deleted automatically
Content-update request (current content version); technical connection data such as the IP address, processed by the delivery network Delivering lesson content updates Legitimate interest (Art. 6(1)(f)): keeping content up to date We do not store it
Partner programme — partner link (Android only): the click label that Google Play passes to the app on first launch if you installed it via a partner link Attributing your first purchase to the partner who referred you Legitimate interest (Art. 6(1)(f)): correct partner reward accounting Kept on your device; sent to our partner-programme server only together with a new purchase (see the next row)
Partner programme — partner code: the code you enter in the app, platform; on entering the code, the technical IP address of the request (used only to limit the number of checks, not stored) Checking that the code exists; protection against code guessing Performance of a contract (Art. 6(1)(b)): applying the code discount you requested; legitimate interest in preventing abuse (Art. 6(1)(f)) The code is kept on your device. The IP address is not stored
Partner programme — purchase report: when you make a new purchase after installing via a partner link or entering a partner code, the app sends the purchase token, product, platform, the click label and/or the partner code, and a random app-installation identifier (UUID) created when you enter a code Verifying the purchase with Google Play and accruing the reward to the partner; protection against abuse Legitimate interest (Art. 6(1)(f)): correct reward accounting and abuse protection On our partner-programme server (Hostinger, Germany, EU): up to 24 months, then deleted or anonymised; purchase facts needed for accounting are kept as required by law (see the partner programme privacy policy)

Payments are processed by Google Play or the App Store. We never receive your payment card details.

If you did not install the app via a partner link and did not enter a partner code, no data is sent to the partner-programme server.

App versions up to and including 1.0.2: if the offline speech model has not been downloaded, voice input may use the speech-recognition service built into your device's operating system (Google or Apple). In that case audio is processed by that provider under its own privacy policy. From the next version, voice input works only with the offline model.

4.Who receives the data

We engage the following processors, each only to the extent required for its function:

We do not sell personal data and do not share it with third parties for their own marketing.

5.Transfers outside the EU/EEA

Some processors (in particular Cloudflare, OpenAI, Google and Apple) may process data outside the EU/EEA, including in the United States. Any such transfer relies on a European Commission adequacy decision (including the EU–US Data Privacy Framework) or on Standard Contractual Clauses (SCC) ensuring an adequate level of protection.

6.Advertising and tracking

The app shows no advertising and does not track you across other apps or websites. The partner-link click label and the installation identifier are used only to attribute purchases within our own partner programme.

7.How we protect the data

All data between the app and our servers is transmitted over encrypted connections (HTTPS). Purchase reports to the partner-programme server are signed, and every purchase is verified with Google Play before any reward is accrued. We keep server-side data to a minimum and delete it automatically after the periods stated above.

8.Children

The AI Conversation Partner is not intended for children under 13. We do not knowingly process personal data of children under 13 on our server. If you believe a child has used the AI Conversation Partner, contact us and we will delete the related data.

9.Your rights

In respect of your personal data you have the right to:

Data stored on your device is under your control: you can delete it at any time by clearing app data or uninstalling the app. Server-side data is deleted automatically (after about 25 hours, 12 hours, 90 days or 24 months, see section 3); you can also request earlier deletion by email.

The supervisory authority in Lithuania is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, VDAI), Vilnius. Before contacting the authority, you may write to us — we will try to resolve the matter directly.

10.Changes to this Policy

We may update this Privacy Policy from time to time. Changes are reflected by updating the "Last updated" date at the top of this page.

11.Contact us

If you have any questions about this Privacy Policy, please contact us at: jaitutor.app@gmail.com.