Mina Learning Privacy Policy

1. Introduction and Data Controller Information

Welcome to Mina Learning. We are committed to protecting your personal data, respecting your right to digital privacy, and maintaining transparency about how our technologies operate. This policy explains how we collect, process, share, and protect your information when you use our mobile application and related services.

For GDPR purposes, the Data Controller is Mina Learning Educational Technologies.

Physical EU Address: Ornek Mah, Ilgaz Sk No:4, 34630 Atasehir/Istanbul, Turkey
Privacy Contact: support@guidemina.com
Data Protection Officer (DPO): support@guidemina.com

2. The Data We Collect

We follow data minimization and only collect what is necessary to provide, secure, and improve Mina Learning.

3. Lawful Bases for Processing

We do not bundle consent. Processing activities are separated and grounded in clear GDPR lawful bases.

4. Artificial Intelligence and Algorithmic Transparency

Mina Learning uses AI and Large Language Models (LLMs) to provide tutoring and customized educational content. When you use the Mina AI Tutor, you are interacting with automated machine intelligence.

Some instructional text, generated images, and synthesized audio pronunciations may be AI-generated.

Educational prompts submitted to AI features are processed securely to generate your response. We maintain enterprise controls so personal data and textual inputs are not used by providers to train foundational models. Inputs are handled ephemerally and protected from human review.

5. Third-Party Processors and Data Sharing

We use selected processors to run the service and do not sell personal data to data brokers or advertising networks. Processors are bound by Data Processing Agreements that restrict use of your data to contracted services.

Where you consent to analytics tracking, Microsoft Clarity may process interaction data to help us understand usability issues and improve product performance. We do not use these analytics tools to intentionally capture payment card details, password fields, or microphone audio content.

• RevenueCat: Used for secure cross-platform subscription management and purchase receipt validation.
• Mixpanel: Used, subject to your consent, for aggregated behavioral telemetry and feature analysis.
• Microsoft Clarity: Used, subject to your consent, to understand user experience patterns such as page visits, taps, scrolling, navigation flows, and limited session replay data for product improvement and debugging.
• OneSignal: Used to deliver push notifications and educational reminders based on your notification permissions.
• Cloud and AI Providers: Used to host encrypted databases and securely execute generative AI requests.

6. International Data Transfers

Some infrastructure partners are headquartered in the United States. For transfers from the EEA to the U.S., we rely on the EU-U.S. Data Privacy Framework (DPF) when applicable and require Standard Contractual Clauses (SCCs) when needed.

7. Children's Privacy and Age Assurance

Mina Learning may be used by children and adolescents. We apply enhanced safeguards for minors and comply with GDPR and Digital Services Act youth protections.

The legal age of digital consent in the EU generally ranges between 13 and 16, depending on member state law.

• Age verification during onboarding uses privacy-preserving age-assurance methods to confirm legal consent age in your jurisdiction.
• If a user is below the legal age of digital consent, non-essential data processing is disabled by default.
• Minors cannot access full interactive capabilities without Verifiable Parental Consent (VPC).
• Parents and legal guardians can review data, modify account settings, revoke consent, or request account and data erasure.

For parental privacy requests, contact privacy@guidemina.com.

8. Data Retention and Security Limitations

We apply storage limitation controls and delete or anonymize data when it is no longer needed for its original purpose.

• Active Accounts: Profile data and learning progress are retained while your account remains active.
• Speech and Audio Data: Audio for pronunciation analysis is processed ephemerally and permanently purged after processing.
• Financial Records: Subscription and transaction logs may be retained for up to six (6) years for tax and accounting compliance.
• Fraud Prevention Audit Logs: After account deletion, a cryptographically hashed device identifier may be retained for up to twelve (12) months to prevent fraud and abuse.

9. Your Data Protection Rights

You can exercise privacy rights inside the app or by contacting our privacy team. Rights include:

• Right to Access
• Right to Rectification
• Right to Erasure ("Right to be Forgotten")
• Right to Data Portability (JSON or CSV)
• Right to Withdraw Consent
• Right to Object (for processing based on Legitimate Interest)

Submit requests in the app via Settings > Privacy and Data, or by emailing privacy@guidemina.com. We respond without undue delay and within one month where required by law.

You also have the right to lodge a complaint with your local supervisory data protection authority.