Privacy Policy

Data Controller

KeelAI is operated by E-com solutions OÜ.

E-com solutions OÜ Registry code: 16662128 Address: Ida-Viru maakond, Lüganuse vald, Oandu kula, Allika, 42314, Estonia Privacy email: privacy@keelai.ai

Supervisory Authority

If you believe your data protection rights have been violated, you may complain to Andmekaitse Inspektsioon in Estonia.

Andmekaitse Inspektsioon Väike-Ameerika 19, 10129 Tallinn, Estonia Website: https://www.aki.ee Email: info@aki.ee

Website, iOS and Android Apps, and Telegram Mini App

This Privacy Policy applies to the KeelAI public website, the KeelAI iOS application distributed through the Apple App Store, the Android application distributed through Google Play, Telegram bots, and the Telegram Mini App. Apple, Google, and Telegram provide their respective distribution and platform services, while personal data you provide directly to KeelAI is processed by E-com solutions OÜ under this Privacy Policy.

The website and mobile applications use necessary local storage and, with consent where required, analytics technologies. The iOS and Android applications and Telegram Mini App may store learning settings and progress in your KeelAI account and synchronize them between devices.

Data We Process

Depending on how you use KeelAI, we may process the following categories of data:

- Account and identity information, such as email address, Google account identity used to sign in, and Telegram ID, username and profile name where applicable - Learning language and level - Learning progress, streaks, saved words, flashcards, quiz results and level tests - Reader progress and uploaded text metadata - Messages with the AI teacher, including transcripts derived from voice messages - Uploaded texts, books and files used in the reader experience - Subscription and transaction records for Apple in-app purchases, Google Play Billing, Stripe, Telegram Stars, TON and local card flows - Technical data such as IP address, browser, device, operating system, cookies, local storage state and analytics events

Purposes of Processing

We process personal data to:

- Provide language learning features, including the reader, dictionary, flashcards, quizzes and progress tracking - Personalize exercises and AI teacher responses - Process subscriptions, payments and billing support - Provide voice recognition, voice generation and related tutoring workflows - Maintain product security, prevent abuse and debug technical issues - Respond to support requests - Improve the service through analytics where consent is required

Legal Bases

We rely on the following GDPR Article 6 legal bases:

- Performance of contract for delivering the service and subscription you request - Legitimate interest for security, fraud prevention, debugging and limited operational analytics - Consent for optional analytics, marketing communications and non-essential cookies or tracking technologies - Legal obligation for accounting, tax and similar mandatory records

Processors and Sub-processors

We use service providers that process data on our behalf or as independent payment platforms where applicable.

Apple: distribution of the iOS application and in-app purchase processing; data categories may include app installation information, transaction identifiers, subscription status, and purchase verification data. Apple processes payment credentials under its own terms and privacy policy. Google: distribution of the Android application, Google account sign-in where selected, and Google Play Billing; data categories may include Google account identity, app installation information, purchase tokens, subscription status and transaction identifiers. Google processes payment credentials under its own terms and privacy policy. Telegram: platform delivery for bots and Mini App; data categories include Telegram account identifiers, messages and payment context; region varies by Telegram infrastructure. Stripe: card payment processing and subscription billing; data categories include billing identifiers, transaction data and email; region may include the EEA and other countries supported by Stripe. OpenAI: AI response generation; data categories may include prompts, messages and language-learning context; processing may occur outside the EEA with contractual safeguards. ElevenLabs: speech and voice features where enabled; data categories may include voice-related text and generated audio metadata; processing may occur outside the EEA with contractual safeguards. Cloudflare: hosting, CDN, security and edge delivery; data categories include IP address, request logs and cached site assets. Analytics providers: analytics scripts or tags that load only when you consent; data categories include cookie identifiers, page views and event data. Other infrastructure or messaging providers may be added as needed, and we will update this policy when material changes occur.

International Transfers

Some providers may process data outside the EEA. Where that happens, we rely on appropriate safeguards such as data processing agreements, Standard Contractual Clauses, or another lawful transfer mechanism.

Retention

We retain data for different periods depending on the feature:

- Account identifiers, language settings and preferences: while the account remains active - Chat history and transcripts: until deletion by the user or expiry of the applicable inactivity period - Raw voice files: deleted after processing or within 30 days unless a shorter period applies operationally - Uploaded files and extracted text: deleted after processing unless the user keeps them in their library - Learning progress, favorites, flashcards and quiz results: while the account remains active - Analytics events: typically 12 to 24 months, preferably pseudonymized where possible - Support correspondence: up to 24 months - Payment and accounting records: retained for the period required by applicable law

Your Rights

You have the right to access, rectify, erase, restrict, port and object to the processing of your personal data, as well as the right to withdraw consent where processing is based on consent.

In the KeelAI iOS and Android applications and Telegram Mini App, KeelAI provides controls to export your data, delete your account, delete chat history, delete uploaded files, manage marketing preferences and review legal documents. You may also contact privacy@keelai.ai.

Payments

Purchases of digital subscriptions in the KeelAI iOS application are processed by Apple and purchases in the Android application are processed through Google Play Billing. KeelAI receives transaction or purchase identifiers, subscription status, plan, and verification information needed to provide access, but does not receive or store full payment card or bank account details used in the App Store or Google Play. KeelAI may also support Stripe, Telegram Stars, TON, and local card flows where configured outside the mobile store applications.

If you delete your account, we delete learning and usage data associated with your account. Some payment and accounting records may be retained where required by law and may be minimized or de-linked from your learning profile where feasible.

Contact

For privacy requests, deletion requests or data protection questions, contact privacy@keelai.ai.

E-com solutions OÜ Privacy: privacy@keelai.ai Support: support@keelai.ai