Privacy Policy for Capybarum: Shadowing Mode

Last updated: 21 June 2025

1. Introduction

This Privacy Policy explains how T3 Development Ltd (sole proprietor Teryoshyn Anton Mykhailovych, “we”) collects, uses, discloses and safeguards your information when you install or use the Capybarum application and related services.

2. What Data We Collect

Category Examples Purpose
Account Data Email, display name, authentication ID (Google / Apple) Create & maintain account
Learning Progress Completed lessons, scores, vocabulary lists Save progress, personalise content
Device Info Device model, OS version, language, IP address Diagnostics, localisation, analytics
Usage Data Feature engagement, screen flows, crash logs (via Expo & Sentry) Improve app stability & UX
Cookies / Tracking Expo‑Auth session cookies, Google Analytics web cookies Keep you signed in, measure traffic

We do not collect sensitive personal data (racial origin, health, biometrics, etc.).

3. How We Collect Data

4. Legal Bases for Processing (GDPR)

Basis When Applied
Contract (Art. 6 (1)(b)) To provide the Service you request.
Legitimate Interest (Art. 6 (1)(f)) App analytics, fraud prevention.
Consent (Art. 6 (1)(a)) Marketing emails, push notifications.

You may withdraw consent at any time via in‑app settings or by emailing us.

5. How We Use Data

6. Data Storage & Retention

Data is stored on Amazon Web Services (eu‑north‑1, Stockholm). Personal data linked to an active account is retained while the account exists. Inactive accounts are deleted after 3 years of inactivity. Back‑ups are purged within 30 days.

7. Sharing & Transfers

We share data only with:

All processors are bound by data‑processing agreements and operate in the EEA or under Standard Contractual Clauses.

We do not sell personal data.

8. Cookies & Tracking

The website uses first‑party functional cookies and Google Analytics cookies to keep you signed in and understand traffic. You can disable cookies in your browser; some features may not work.

9. Your Rights (GDPR & Ukrainian Law)

You have the right to access, rectify, erase, restrict or object to processing, and to data portability. Requests: email [email protected]. We respond within 30 days.

10. Account Deletion

You can delete your Capybarum account and permanently erase all related data in either of two ways:

If you can’t access either option, send an e-mail to [email protected] with the subject “Delete account” from the address used in the app. We respond within 30 days.

11. Children’s Privacy

The Service is not directed to children under the minimum age permitted to consent to data processing in their country (13 years globally; 16 years in the EEA unless local law allows a lower age). We do not knowingly collect data from children below that age.

12. Security

We implement industry‑standard security measures: TLS 1.3 encryption in transit, AES‑256 at rest, least‑privilege IAM roles, regular penetration testing.

13. Changes to This Policy

We review this Policy regularly and will post updates in‑app and on the website at least 7 days before they take effect.

14. Contact

For privacy questions or to exercise your rights, email: [email protected]

© 2025 T3 Development Ltd (FOP Teryoshyn A.M.) – All rights reserved.