Privacy Policy

Last Updated: 26/05/25

1. Introduction

Welcome to Tiwtor ("we," "our," or "us"). We are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our language learning platform, including our mobile application and website (collectively, the "Service").

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use our Service.

Contact Information:

• Company: MT FORD LTD
• Address: 25-29 Sandy Way Yeadon, Leeds, England, LS19 7EW
• Email: [email protected]

2. Information We Collect

2.1 Personal Information You Provide

• Account Information: Name, email address, username, password
• Profile Information: Language preferences, learning goals, progress data
• User-Generated Content: Content you upload to create language lessons, practice materials, recordings, and other educational content
• Communications: Messages you send to us, feedback, and support requests

2.2 Automatically Collected Information

• Usage Data: How you interact with our Service, features used, time spent, lesson completion rates, learning patterns
• Device Information: Device type, operating system, browser type, IP address, device identifiers
• Location Data: General geographic location based on IP address (we do not collect precise GPS location)
• Cookies and Tracking Technologies: Session data, preferences, analytics information

2.3 Third-Party Information

• Payment Information: For in-app purchases, Apple and Google may share transaction confirmations and payment status with us. If website purchases are offered in the future, Stripe may share transaction confirmations and payment status with us.
• Analytics Data: Information from third-party analytics services about your usage patterns

3. How We Use Your Information

3.1 Primary Purposes

• Service Delivery: Provide, maintain, and improve our language learning platform
• Personalization: Create customized learning experiences and lesson recommendations
• AI-Powered Features: Use artificial intelligence and machine learning to:
  • Generate personalized language lessons
  • Analyze learning patterns and progress
  • Improve lesson quality and effectiveness
  • Provide intelligent content recommendations
• Content Generation: Process your uploaded content to create language learning materials
• Account Management: Manage your account, authenticate users, and provide customer support

3.2 Communication

• Send service-related notifications and updates
• Respond to your inquiries and provide customer support
• Send educational content and learning tips (with your consent)

3.3 Platform Improvement

• Analyze usage patterns to improve our Service
• Conduct research and development for new features
• Monitor and analyze trends and usage statistics

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA) and UK, our legal bases for processing include:

• Contract Performance: Processing necessary to provide our Service
• Legitimate Interests: Improving our Service, security, and customer support
• Consent: Marketing communications and optional features (where obtained)
• Legal Obligation: Compliance with applicable laws and regulations

5. Information Sharing and Disclosure

5.1 Third-Party Service Providers

We share information with trusted third parties who assist us in operating our Service:

• Payment Processing: Stripe (for payment processing and billing)
• Analytics Services: Google Analytics and similar services (for usage analysis)
• Cloud Infrastructure: Cloud hosting and storage providers
• Customer Support: Support ticket and communication platforms
• AI/ML Services: Third-party AI and machine learning service providers

5.2 User-Generated Content

• Content you upload may be used to generate lessons for your personal use
• In the future, some user-generated content may become publicly available as part of our community features (we will obtain explicit consent before making any content public)

5.3 Legal Requirements

We may disclose your information when required by law, regulation, legal process, or governmental request, or to protect our rights, property, or safety.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication measures
• Employee training on data protection

However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Service and maintain your account
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Improve our Service through AI/ML analysis

Specifically:

• Account Data: Retained while your account is active and for 1 year after account closure
• Usage Data: Retained for 2 years for analysis and service improvement
• User-Generated Content: Retained as long as you maintain your account, unless you specifically delete it

8. Your Rights and Choices

8.1 Account Information

You can access, update, or delete your account information through your account settings.

8.2 GDPR Rights (for EEA and UK users)

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to certain exceptions)
• Portability: Receive your data in a portable format
• Restriction: Request limitation of processing
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for consent-based processing

8.3 Communication Preferences

You can opt out of marketing communications at any time by following the unsubscribe instructions in our emails or contacting us directly.

8.4 Cookies and Tracking

You can control cookies through your browser settings, though this may affect the functionality of our Service.

9. International Data Transfers

As we serve users worldwide and use international service providers, your information may be transferred to and processed in countries outside your country of residence. We ensure appropriate safeguards are in place for such transfers, including:

• Standard Contractual Clauses approved by relevant authorities
• Adequacy decisions by relevant data protection authorities
• Other lawful transfer mechanisms as required

10. Children's Privacy

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information.

11. Third-Party Links

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

12. Cookies and Tracking Technologies

We use various tracking technologies including:

• Essential Cookies: Required for basic Service functionality
• Analytics Cookies: Help us understand how you use our Service
• Functional Cookies: Remember your preferences and settings
• Performance Cookies: Collect information about Service performance

You can manage your cookie preferences through your browser settings.

13. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected and how it's used
• Right to delete personal information
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising your privacy rights

14. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending you an email notification
• Providing notice through our Service

Your continued use of our Service after such modifications constitutes acceptance of the updated Privacy Policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: [email protected] Address: 25-29 Sandy Way Yeadon, Leeds, England, LS19 7EW

For GDPR-related inquiries, you may also contact our Data Protection Officer at: [email protected]

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) or your local data protection authority if you believe we have not handled your personal information in accordance with applicable law.

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This Privacy Policy is effective as of 25/5/2025 and applies to all users of our Service.