Privacy Policy

Last updated: 20.05.2025

ABC Pilot (“we”, “us”, or “our”) is operated by Artgenic OÜ, a company registered in Tallinn, Estonia. We are committed to protecting your personal data and your rights under the EU General Data Protection Regulation (GDPR).

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our app, website, and services.

• 1. Who we areCompany name: Artgenic OÜ
• Registry code: [Insert Company Registration Code]
• Address: [Insert Address], Tallinn, Estonia
• Contact email: info@abcpilot.eu

2. What personal data we collect
We collect and process the following categories of personal data:

• Account data: email, username, language level
• Usage data: interactions with learning modules, tasks completed, voice recordings (for speech tasks)
• Payment data: billing info (processed via ORDIN Systems OÜ and Stripe, we do not store card details)
• Device data: browser, operating system, app version, IP address
• Support data: feedback, support messages

3. Why we collect your data
We process your data to:

• Provide access to the ABC Pilot app
• Personalize your learning experience
• Evaluate your progress and generate reports
• Process payments securely
• Ensure service functionality, performance, and improvements
• Respond to support requests
• Comply with legal obligations

4. Legal basis for processing
We process personal data based on:

• Consent – when you sign up or opt in to communication
• Contract – to deliver the educational services you've purchased
• Legal obligation – for compliance with financial and tax regulations
• Legitimate interest – to improve services, prevent abuse, or communicate with users

5. Payment processing
All payments are securely processed via:

• ORDIN Systems OÜ (intermediary)
• Stripe Payments Europe, Ltd. (primary payment processor)

We do not store or process your payment card data directly. Stripe’s privacy policy is available at https://stripe.com/privacy.

6. Data sharing and third parties
We may share limited data with:

• Technology partners (e.g., hosting and analytics providers like Firebase, Google)
• AI service providers (for language evaluation features)
• Payment processors (ORDIN Systems OÜ and Stripe)
• Public authorities – only if legally required

We do not sell or rent your personal data.

7. How long we keep your dataWe retain personal data:

• As long as your account is active
• For up to 3 years after inactivity, unless required longer by law (e.g., accounting records)
• You can request deletion at any time (see Section 9)

8. Data security
We use modern technical and organizational measures to safeguard your data:

• Secure connections (HTTPS, SSL)
• Encrypted storage where required
• Access controls and internal training

9. Your rights under GDPR
You have the right to:

• Access your personal data
• Correct inaccurate or outdated data
• Delete your data (“right to be forgotten”)
• Restrict or object to processing
• Port your data to another provider
• Withdraw consent at any time

To exercise your rights, email us at info@abcpilot.eu

10. Children’s data
ABC Pilot is not designed for children under 13 years old. Users under 16 should use the app with parental or guardian consent where applicable.

11. International transfers
Your data may be transferred outside the EU/EEA only to processors offering GDPR-compliant safeguards, such as Standard Contractual Clauses (SCCs) or equivalent mechanisms.

12. Updates to this policy
We may update this Privacy Policy to reflect legal changes or feature updates. We will notify users via the app or email when changes are significant.

13. Contact
If you have any questions or concerns about this policy or your data, contact:
Data Protection Officer
Artgenic OÜ
Email: info@abcpilot.eu