Identification of data controller: JAIK s.r.o., ID no. 21536112, with its registered seat at Primátorská 296/38, Libeň, 180 00 Praha 8 (“we”).
Contact details: hello@frenchtess.com.
We are the creators of the FrenchTess App (“App”) and by this Privacy Policy we would like to inform you about how we process your personal data when you use our App. More information about the App is available at https://frenchtess.com/ (“website”).
We recommend that you read this information carefully. If you have any questions, you can contact us at any time using the contact details above. As we are a company located in the European Union, the processing of personal data is governed by Regulation (EU) 2016/679 (the “GDPR”).
A. Table of contents
Our goal is to ensure maximum transparency in the processing of your personal data. We have divided this document into the following sections:
- the personal data processed, including examples of the data processed (part B);
- the purposes of the processing of personal data, as well as the legal bases and periods of processing (part C/D);
- sharing of personal data (part E);
- your rights in data processing and how to exercise them (part F);
- the possibility to lodge a complaint (part G); and
- amendments to this document (part H).
Our App may also use cookies and other technical identifiers, beacons etc.; a description of the different purposes and types of third parties is set out in sections B and C of this Privacy Policy and in the cookie bar available on the website.
B. Personal data processed
We will use your personal data to provide you with the functionalities of the App, which may also include e-mail notifications, ensure legal obligations, secure our claims etc. All purposes and usage of data are stipulated in part C of this Privacy Policy.
We will not sell your data to third parties, but we may share it with our partners who help us provide our services (see Part E). We follow industry standards including TLS 1.2+ in transit and AES-256 at rest (cloud provider default). Access is role-based and logged. Despite safeguards, no online service is 100% secure; please protect your device and sign-in e-mail.
Personal data are stored within the period stipulated for each purpose in part C. Generally, we will retain your personal data for the length of time needed to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. When the data retention period expires for a given type of data, we will delete, anonymize or destroy it.
You may also request for your data to be deleted by contacting us at hello@frenchtess.com. We will assess it in accordance with GDPR.
Categories of personal data processed:
- Identifiers, such as account ID, user ID, device identifier.
- Contact info, such as first name, e-mail address, other contact details inserted into the App.
- Billing and payment information, such as payment method, plan type, card number, billing address.
- Purchases information, such as payments made and records and history of payments.
- User content, such as text, messages, your preferences, voice recordings (if you allow your microphone), photo/video uploads (if you allow it), saved content, support requests, content you generate (display name, age-band, gender, study motivation), and learning data (lesson history, progress scores, feedback).
- Usage data, such as how you interact with the App, your activity, IP address, device type, OS, session length.
- Diagnostics data, such as crash logs and performance data.
- Cookies data, including essential cookies, analytics data and advertising cookies and similar technologies.
Please do not use our App to upload any sensitive information about you, such as health, genetic or biometric data, or data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or sexual orientation.
The App is not designated for children. By downloading or installing the App, you declare that you are older than 13 years old. If you are younger than 13, the App must be used by your legal representative.
In most cases, data is gathered from your usage of the App or from your device. We may also obtain data from third parties that enable us to provide the App, in particular payment providers (e.g. Stripe, Apple, Google, RevenueCat) and app distribution platforms.
C. Purposes of the processing of personal data
We process your personal data as a data controller for the processing purposes, legal bases and periods set out below.
D.1 Provision of App core functionalities
We primarily process personal data to provide the App, create your account and plan, process payments and treat you as our customer when you download the App and agree with our Terms & Conditions. Data is processed to authenticate you, enable features, customize the experience, ensure your progress, perform support and process payments.
Categories: Identifiers, Contact info, Billing and payment information, Purchases information, User content, Usage data, Cookies data (essential). Legal basis: performance of the contract and steps taken at your request before entering it. Processed for the duration of the relationship plus 24 months after account termination.
D.2 Personalized content and difficulty
We process your profile and learning data to build a custom learning plan, recognize your level, identify gaps, adapt lesson difficulty and personalize content so the App focuses on what matters and lets you progress quickly.
Categories: Identifiers, User content, Usage data. Legal basis: legitimate interest in improving and personalizing the service. Retained while the account is active and for an additional 24 months before anonymization.
D.3 Fulfilling legal obligations
Categories: Identifiers, Contact info, Billing and payment information, Purchases information. Legal basis: compliance with our legal obligations. Processed for 7–10 years for tax and audit purposes.
D.4 Internal records, statistics and protection of our rights
Categories: Identifiers, Contact info, Billing and payment information, Purchases information, User content, Usage data, Diagnostics data. Legal basis: legitimate interest. Processed up to 10 years after the contract ends (longer in a dispute), or up to 3 years if no contract was concluded.
D.5 Service e-mails and push notifications
Categories: Identifiers, Contact info. Legal basis: legitimate interest in informing users and ensuring proper operation. Processed only as long as strictly necessary.
D.6 Newsletters and promotional communication
Categories: Contact info, Purchases information, Identifiers. Legal basis: your freely given consent, which you may withdraw at any time. Processed for the period of the relationship, max 5 years from giving consent.
D.7 App diagnostics and analytics
Categories: Identifiers, Usage data, Diagnostics data. Legal basis: legitimate interest in monitoring performance, stability and improving the App. Crash logs retained for 90 days; other analytics only as long as necessary.
D.9 App and website operation and security
We process data for the operation and security of the App, including identifying you as a user. We use SDK-level identifiers in the App and essential cookies on the website to enable sign-in, load balancing, security and other strictly necessary technical operations.
Categories: Usage data and Cookies data. Legal basis: performance of the contract and legitimate interest in proper, safe operation. Third-party tools may include error tracking (e.g. Sentry), crash reporting (e.g. Firebase Crashlytics) and authorization platforms (Google OAuth, Apple Sign-In). Personal data may be transferred outside the EU/EEA under SCCs and/or the EU–US Data Privacy Framework.
D.10 Analytics
With your consent, we may process Cookies data for analytics. Legal basis: consent. Processed until consent is withdrawn, max 1 year after your visit. Tools may include Mixpanel, Adjust, Firebase Analytics and Microsoft Clarity, with transfers safeguarded by SCCs and/or the EU–US Data Privacy Framework.
D.11 App support and promotion (marketing)
With your consent, we process Cookies data to display relevant advertising and measure campaign performance. Legal basis: consent via the cookie bar. Processed until consent is withdrawn, max 1 year. Advertisers may include Meta, TikTok, Google and Snap, with transfers safeguarded by SCCs and/or the EU–US Data Privacy Framework.
E. Sharing of personal data
We do not disclose your information to third parties for purposes other than those in this Privacy Policy. We may share data with processors who help us provide the App, which may include:
- Payment processors — Stripe Payments Europe; RevenueCat, Inc.; Apple Distribution International Limited and Google Ireland Limited.
- Klaviyo, Inc. — e-mail marketing and automation.
- Google Cloud EMEA Limited — cloud hosting and infrastructure.
- OneSignal, Inc. — push notifications and email automation.
- OpenAI Ireland Ltd — AI text generation and speech services.
- Deepgram Inc. and Eleven Labs Inc. — voice and speech services.
- External service providers (tax, law, auditors).
Your information may also be shared with social or advertising networks (Meta, TikTok, Google) where we have your consent. Where we share data outside the EEA, we do so only under an adequacy decision or appropriate safeguards such as Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs).
F. Your rights and how to exercise them
You have the right to (i) request access to your personal data; (ii) withdraw consent; (iii) request rectification; (iv) request erasure; (v) request restriction of processing; (vi) request portability; (vii) object to processing; and (viii) lodge a complaint with the relevant supervisory authority.
For any matter related to the processing of your personal data, contact us at hello@frenchtess.com. Your request will be handled without undue delay, at most within 1 month (extendable by a further 2 months for complex requests, with notice).
G. Right to file a complaint
You can file a complaint with the relevant supervisory authority, the Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7.
H. Changes to this information
We may change this information from time to time, so please check it regularly. We will post any changes to this document on our website.