LexieLearn Privacy Policy

Last Updated: October 12, 2025

1. Data Controller

Interlinear Oy
Albertinkatu 26-28
elina.patjas@interlinear.tech
Business ID: 3523811-5

2. Key Principles

2.1 Mobile App - No Data Collection from Children

No data remains in the app from the child
The child doesn't need to register for the app
All learning content is stored only on the user's device

2.2 Privacy Principles

We minimize data collection to what is necessary for service operation
We prioritize user privacy and data security
We are transparent about what data we collect and why

3. Processed Data

3.1 Mobile App usage data:

Device operating system and version
App usage pattern and version
Anonymous analytics data about app functionality

3.2 Mobile App - What data is NOT collected:

Personal data (name, email, phone number)
User-created content or learning materials
Location data
Device-specific identifiers

3.3 Messaging Services (WhatsApp/SMS):

For users who interact with Lexie via WhatsApp or SMS messaging, we process:

Phone number (used as your unique identifier for the messaging service)
Message content (processed temporarily for conversational context, kept in-memory for maximum 30 minutes, then automatically deleted)
User preferences (language choice, terms acceptance status, opt-out status)
Images sent via messaging (processed to create study materials, but NOT permanently stored after processing)
Study set creation events (phone number, subject area, creation source, timestamp)
Optional quiz reminders (exam date, reminder time) - only if you request this feature
Usage limits tracking (number of study sets created per phone number)

4. Purpose and Legal Basis of Data Processing

4.1 Mobile App processing purposes:

Developing app functionality
Improving user experience
Identifying and fixing technical issues
Analyzing usage statistics

4.2 Messaging Services processing purposes:

Providing conversational AI assistance via WhatsApp/SMS
Processing images sent via messaging to create study materials
Storing language preferences to provide responses in your preferred language
Enforcing usage limits (10 free study sets per phone number for messaging service users)
Sending quiz reminders on the exam date (only if you request this feature)
Analyzing study set creation patterns to improve the service

4.3 Legal basis for processing:

Legitimate interest in developing and operating the service
User consent for collecting analytics and optional features
Contract performance (providing the service you requested)
Legal obligation (responding to legal requests when required)

5. Data Storage and Protection

5.1 Mobile App data storage:

Analytics data is stored in the EU/EEA area
User-created content remains only on the user's device
Data is stored only as long as necessary

5.2 Messaging Services data retention:

Phone numbers: Stored as long as you actively use the messaging service
Conversation history: Maximum 30 minutes in-memory, then automatically deleted
Original images: NOT stored after processing is complete (typically within minutes)
Study materials: Available for 24 hours via temporary link, then automatically expire
User preferences: Stored until you opt out of the service
Quiz reminders: Deleted immediately after being sent
Analytics data: Retained for service improvement and aggregate reporting

5.3 Data security:

All communications are encrypted (HTTPS/TLS)
Access to data is restricted to necessary personnel only
Systems are properly secured with industry-standard security measures
Phone numbers and user data are stored in secure EU-hosted databases
We implement appropriate technical and organizational measures to protect your data

6. Data Transfers and Third-Party Processors

6.1 Data is not sold or shared with third parties for marketing purposes.

6.2 We use the following third-party service providers who process data on our behalf:

For Messaging Services (WhatsApp/SMS):

Twilio (USA) - For WhatsApp and SMS message delivery and media handling. Twilio processes messages and phone numbers as necessary to deliver the service.
OpenAI (USA) - For AI processing of images and text to create study materials. We configure our account to request opt-out from AI training data. Data sent to OpenAI is processed and not retained longer than necessary.
Supabase (EU-hosted) - For storing user preferences, analytics, and reminder schedules in a secure database.

For Mobile App:

OpenAI (USA) - For content processing to create study materials. Configured to opt-out of training data.

All third-party processors handle data in accordance with GDPR requirements and are bound by data processing agreements that ensure appropriate data protection measures.

6.3 Data may be shared when:

Required by law or legal process
Requested by government authorities or law enforcement
Necessary to protect our rights or the safety of users

7. User Rights

7.1 Mobile App users - Since the app only collects anonymous data, you have the right to:

Receive information about the app's data processing
Object to data processing by stopping app use
File a complaint with the supervisory authority (Finnish Data Protection Ombudsman)

7.2 Messaging Service users have additional rights:

Access: Request a copy of your stored data (phone number, preferences, usage statistics)
Rectification: Request correction of inaccurate data
Erasure: Request deletion of your phone number and associated data
Opt-out: Send "NOLEXIE" to immediately stop all messages and mark your number as opted out
Object: Object to data processing for specific purposes
Data portability: Receive your study set analytics in a structured format
Withdraw consent: Withdraw consent for optional features at any time

7.3 Exercising your rights:

For messaging services opt-out: Send "NOLEXIE" via WhatsApp or SMS
For other requests: Contact us in writing at elina.patjas@interlinear.tech
We respond to requests within 30 days
We may need to verify your identity before processing certain requests

8. Cookies and Similar Technologies

8.1 The mobile app does not use cookies.

8.2 For collecting analytics data, we use:

The app's internal analytics system, which collects only anonymized usage data

8.3 Our website may use essential cookies for basic functionality. We do not use tracking or advertising cookies.

9. Messaging Services Specific Terms

9.1 Service Description:

Users can interact with Lexie by sending text messages and photos via WhatsApp or SMS to create study materials without downloading the mobile app.

9.2 Phone Number as Identifier:

Your phone number serves as your unique identifier for messaging services. We do not link it to other personal information unless you explicitly provide it. We do not share your phone number with third parties except as necessary to deliver the service (e.g., Twilio for message delivery).

9.3 Free Usage Limits:

Messaging service users can create up to 10 free study sets. This limit is tracked per phone number to prevent abuse and ensure fair access to the service.

9.4 Message Content Processing:

Text messages are processed through AI (OpenAI GPT-4) to provide conversational responses
Conversation history is kept in-memory for 30 minutes to maintain conversational context
All conversations are automatically deleted after 30 minutes
We do not permanently store your messages
You can end all interactions at any time by sending "NOLEXIE"

9.5 Image Processing:

Images sent via messaging are temporarily downloaded from Twilio
Images are processed to extract text using OCR (Optical Character Recognition)
Extracted text is sent to OpenAI for analysis and study material generation
Original images are NOT permanently stored after processing is complete
Generated study materials (flashcards, quizzes) are available for 24 hours via a temporary link
After 24 hours, the study materials expire and are no longer accessible

9.6 Optional Features:

Quiz reminders: If you choose to receive exam reminders, we store your phone number, exam date, and preferred reminder time until the reminder is sent
Language preferences: We remember your language choice (English/Finnish) to provide a better experience in future interactions
These preferences can be deleted by opting out or requesting data deletion

9.7 Terms Acceptance:

First-time messaging service users are asked to accept our Terms of Service and Privacy Policy before using the service. Your acceptance is recorded with a timestamp.

10. Children's Privacy

10.1 Our mobile app is designed for use by students, including minors, but collects no personal data from children.

10.2 For messaging services: We do not knowingly collect personal data from children under 13 without parental consent. If a parent or guardian becomes aware that their child has provided us with personal data via messaging services, please contact us at elina.patjas@interlinear.tech so we can delete it.

11. International Data Transfers

11.1 Some of our service providers (Twilio, OpenAI) are based in the United States. When data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place:

Standard Contractual Clauses (SCCs) approved by the European Commission
Data processing agreements with GDPR-compliant terms
Commitment to data minimization and purpose limitation

11.2 We regularly review our data transfer mechanisms to ensure compliance with EU data protection laws.

12. Data Breach Notification

12.1 In the event of a data breach that poses a risk to your rights and freedoms, we will:

Notify the relevant supervisory authority within 72 hours
Notify affected users without undue delay if there is a high risk
Provide information about the nature of the breach and steps taken to address it

13. Privacy Policy Changes

13.1 We reserve the right to modify this privacy policy to reflect changes in our practices or legal requirements.

13.2 Material changes will be announced:

In the mobile app
On our website (lexielearn.com)
Via message to active messaging service users (if contact information is available)

13.3 Continued use of our services after changes constitutes acceptance of the updated policy.

14. Contact Information

14.1 Data Protection Contact:

Interlinear Oy
Albertinkatu 26-28, Helsinki, Finland
Email: elina.patjas@interlinear.tech
Business ID: 3523811-5

14.2 Supervisory Authority:

Finnish Data Protection Ombudsman (Tietosuojavaltuutetun toimisto)
Website: tietosuoja.fi