Privacy Policy

1Who we are & scope

Zmany is a language-learning app that teaches eleven languages — English, German, French, Spanish, Russian, Turkish, Persian, Mandarin and three varieties of Arabic — with every lesson explained in Kurdish (Sorani & Kurmanji). It is operated by CLEVAITE LLC, a Wyoming limited liability company (entity #2026-002006499), 5830 E 2nd St, Ste 7000 #36415, Casper, Wyoming 82609, United States. This policy applies to everyone who uses the Zmany app (iOS and Android) or visits zmany.app.

If you have questions about this policy or how your data is handled, contact us at admin@clevaite.com.

2Data we collect

We follow a data-minimization approach: we only collect what's needed to run and improve the Service.

Information you provide

• Account information — email address (if you create an account) and a username you choose.
• Learning preferences — the language pair and course you select, and your placement/goal choices.
• Support requests — anything you send us via email or in-app support.

Information collected automatically

• Learning activity — lesson progress, streaks, accuracy, and time spent studying (tracked via app usage, not passive background tracking).
• Device & app info — device type, operating system, app version, and device locale/language setting.
• Anonymized analytics — aggregated usage patterns that help us understand which lessons work and where users get stuck.
• Approximate country — inferred from your device's IP address when you use the app, so we can show country leaderboards and region-appropriate payment options. You can override it at any time in Settings.
• Subscription status — whether you have an active trial or subscription, and its renewal date (billing itself is handled by Apple/Google — see Sharing & third parties).

To show country leaderboards and region-appropriate payment options, we infer your country (never your precise location) from your device's IP address when you use the app. The app does not ask for or use GPS or device location permissions. You can change your country at any time in Settings. IP addresses are processed transiently for this purpose and are not stored with your profile. Country inference uses GeoLite2 data created by MaxMind, available from https://www.maxmind.com.

3How we collect it

• Directly from you — when you create an account, choose a course, or contact support.
• Automatically — through your use of the app (e.g. completing a lesson, maintaining a streak).
• From third parties — Apple and Google share limited purchase/subscription status information with us when you buy a subscription through their stores.

4How & why we use it

We use your data to:

• Provide, operate, and personalize your learning experience (e.g. adapting lesson difficulty, tracking streaks) — necessary to perform our contract with you.
• Process subscriptions and entitlements via Apple App Store / Google Play — necessary to perform our contract with you.
• Send transactional emails such as sign-in codes, receipts, or account notices — necessary to perform our contract with you.
• Show country leaderboards and offer the payment options that are actually available where you are — our legitimate interest in running fair regional rankings and a working checkout.
• Maintain and improve the Service, fix bugs, and understand aggregate learning outcomes — our legitimate interest in improving the product.
• Detect, prevent, and address fraud, abuse, or security issues — our legitimate interest and legal obligation.
• Comply with legal obligations and respond to lawful requests.

We do not use your personal data to make any automated decision that produces a legal or similarly significant effect on you.

5AI-generated content

Some of the audio narration, illustrations, and course imagery inside Zmany lessons are generated using third-party AI cloud providers (for example, text-to-speech and image-generation services). This content is generated from our own course scripts and prompts — your personal data or learning activity is never sent to these providers or used to train external AI models. Where relevant regulation requires it, AI-generated media is machine-marked or otherwise identifiable as such.

6Sharing & third parties

We do not sell or rent your personal data. We share limited data only with trusted service providers who process it on our behalf, under contract, and only for the purposes described below:

We may also disclose data if required by law, to protect our rights, or in connection with a merger, acquisition, or sale of assets — in which case this policy would continue to apply to your data.

7International transfers

Because our service providers operate globally, your data may be processed in countries other than where you live, including outside the European Economic Area or the United Kingdom. Where this happens, we rely on appropriate safeguards, such as standard contractual clauses or providers' adequacy certifications, to protect your data.

8Data retention

We keep your personal data for as long as your account is active. If you delete your account, we delete or anonymize your personal data within a reasonable period, except where we must retain limited records to comply with legal, tax, or security obligations (for example, fraud-prevention logs).

9Your rights

If you're in the EU, UK, or a similar jurisdiction (GDPR / UK GDPR)

You have the right to access, correct, delete, restrict, or port your personal data, to object to certain processing, to withdraw consent at any time, and to lodge a complaint with your local data protection authority.

If you're a California resident (CCPA / CPRA)

You have the right to know what personal information we collect, to request deletion or correction of it, to opt out of the sale or sharing of personal information, and to limit the use of sensitive personal information. We do not sell or share your personal information for cross-context behavioral advertising, so there is no "Do Not Sell or Share" action needed — you can still contact us to confirm this at any time. We do not discriminate against you for exercising any of these rights.

Everyone else

Regardless of where you live, you can request access to, correction of, or deletion of your data by contacting us, or by using the account deletion option inside the app (Settings → Account → Delete Account). You can also request a copy of your data in a portable (JSON) format.

10Children's privacy

Zmany is intended for users aged 13 and older. We do not knowingly collect personal data from children under 13. If you believe a child under 13 has provided us with personal data, contact us and we will delete it.

11Security

We encrypt data in transit (HTTPS/TLS) and at rest, restrict access to personal data on a need-to-know basis, and avoid storing sensitive personal identifiers in logs. No method of transmission or storage is 100% secure, so we cannot guarantee absolute security, but we work to protect your data using industry-standard practices.

12Cookies & similar tech

Our marketing website does not currently use analytics or advertising cookies — only, if applicable, strictly necessary cookies required for the site to function (for example, remembering your language choice). If this changes, we will update this policy and add a cookie consent banner where required by law.

13Regional notices

Some regions have additional or slightly different requirements. In all cases, we aim to honor the substance of these rights for every user, regardless of location:

• Middle East (PDPL — Saudi Arabia, UAE, Bahrain): we apply the same data-minimization and security practices described above.
• Turkey (KVKK): contact us for a Turkish-language summary of this policy on request.
• Brazil (LGPD): Brazilian users have the same access, correction, and deletion rights described in Your rights.

14Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you in the app or by email before the changes take effect. The "Last updated" date at the top of this page always reflects the most recent version.

15Contact us

Questions, requests, or complaints about this policy or your data can be sent to admin@clevaite.com, or by post to CLEVAITE LLC, 5830 E 2nd St, Ste 7000 #36415, Casper, Wyoming 82609, United States. We aim to respond within 30 days.