Privacy Policy

This Privacy Policy explains how Dmitry, based in Ukraine ("we", "us", or "our"), collects, uses, and protects personal data when you use @GabbyEnglishTutorBot, our AI tutor bot for practicing spoken English in Telegram, as well as our related website and Telegram Mini App.

If you have any questions or privacy requests, contact us at: gabbyenglishtutor@gmail.com

1. Who we are

We operate @GabbyEnglishTutorBot, an AI-powered English tutoring service available through Telegram, a related website, and a Telegram Mini App.

2. What data we collect

Depending on how you use the service, we may collect:

• Telegram account data, such as your Telegram user ID, username, and display name
• Messages and learning content, including text messages, corrections, explanations, and conversation history
• Voice input, including audio messages you send for transcription and tutoring. We do not store audio recordings after processing.
• Payment-related data, such as subscription status, transaction identifiers, country, and limited billing information provided to us by our payment provider
• Support communications, if you contact us by email
• Usage and analytics data from our website or Mini App, such as page visits, clicks, device/browser information, and general product usage events

3. How we use your data

We use your data to:

• Provide the tutoring service
• Generate AI replies, corrections, explanations, transcription, and speech features
• Process voice input to generate transcriptions and provide tutoring features
• Maintain conversation context and recent learning history
• Process subscriptions and manage access to paid features
• Monitor performance, fix issues, and improve reliability
• Detect abuse, fraud, misuse, or violations of our terms
• Respond to support requests
• Understand how users interact with our website, Mini App, and bot

4. Legal bases for processing

If you are in the European Economic Area or another jurisdiction with similar rules, we generally process your personal data on the following bases:

• Performance of a contract, when processing is necessary to provide the tutoring service you request
• Legitimate interests, for service security, abuse prevention, debugging, analytics, and service improvement
• Legal obligations, where we must keep certain records for tax, accounting, legal, or regulatory reasons

5. Third parties and service providers

We may share relevant personal data with service providers that help us operate the service, including:

We do not sell your personal data.

• Telegram, to deliver bot interactions
• Railway.app, for hosting, database and infrastructure
• OpenAI, for language model and speech-to-text services
• Groq, for language model services
• Inworld, for text-to-speech services
• PostHog, for product and website analytics

6. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Currently, our retention practices are:

• Chat history and conversation data: kept for up to 90 days, or deleted sooner if you reset or delete your data where applicable
• Voice/audio messages: not stored by us; audio is streamed for transcription and processed only as needed to generate the transcript
• Technical logs: typically kept for up to 90 days
• Payment and billing records: kept for as long as required by applicable tax, accounting, payment, and legal obligations
• Support emails: kept as long as needed to resolve the request and maintain a record of the support interaction

7. International data transfers

Because we use third-party providers that may process data in different countries, your personal data may be transferred to and stored outside your country, including outside Ukraine and outside the European Economic Area.

Where required, we rely on appropriate safeguards or provider commitments designed to protect personal data during such transfers.

8. Your rights

Depending on your location, you may have the right to:

To exercise your rights, contact us at: gabbyenglishtutor@gmail.com

• Request access to the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request deletion of your data
• Request restriction of processing
• Object to certain processing
• Request a copy of your data in a portable format
• Lodge a complaint with your local data protection authority

9. Deletion and user controls

You can stop using the service at any time.

You may also:

Please note that some information may still be retained where necessary for legal, billing, security, or fraud-prevention reasons.

• Request deletion of your data by email
• Request a copy of your data by email
• Use available in-bot controls, such as /reset, to clear active session data where supported

10. Analytics and cookies

We use analytics to understand how users interact with our website or Mini App and to improve the service.

We do not use marketing pixels.

We do not intend to use cookies for advertising. However, some analytics tools may use cookies or similar browser storage depending on configuration.

11. Children

Our service is intended for general users. If you are below the age at which you can validly consent to data processing under the laws of your country, please use the service only with appropriate involvement from a parent or guardian.

If you believe a child has provided personal data inappropriately, contact us and we will review the request.

12. Security

We take reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or disclosure. However, no method of transmission or storage is completely secure.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and change the "Last updated" date above.

14. Contact

If you have questions, requests, or privacy concerns, contact: