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LexieLearn Privacy Policy

Last Updated: July 16, 2026

1. Data Controller

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

2. Key Principles

2.1 Mobile App - Minimal Data Collection

  • The app works without registration. An account is optional and is only needed to unlock content purchased on our website (see 3.4)
  • Learning content is stored on the user's device. Content you scan or type is sent to our server only transiently for AI processing and is not permanently stored on our servers (unless you explicitly share a study set)
  • We do not collect names, phone numbers, or location data through the app

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, device model, and app version
  • App usage pattern and version
  • Anonymous analytics data about app functionality (for example the number of study sets created and study session statistics)
  • An app-specific device identifier, used to prevent misuse, to count free study sets, and to key anonymous usage statistics. It is not linked to your name.
  • Content you submit to create study materials (photos of study materials, typed or imported text, PDF files). This content is sent to our server, processed transiently by AI to generate your study materials, and is not permanently stored on our servers.
  • Answers and chat messages you type while studying, sent to our server transiently for AI feedback and grading
  • Feedback you choose to send through the app (your message, an optional screenshot, and an optional reply email address)
  • Purchase status (whether you have an active subscription or pass). Payments are processed by Apple's App Store or Google Play; we never receive your payment card details.
  • If you share a study set, its content is uploaded to our database and is accessible to anyone with the share link

3.2 Mobile App - What data is NOT collected:

  • Name or phone number
  • Email address — unless you choose to sign in with an optional account (see 3.4)
  • Location data
  • Advertising identifiers — the app contains no ads and no ad tracking

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 for conversational context, stored securely for up to 7 days to maintain conversation continuity, 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)

3.4 Account (Optional — Website and Mobile App):

Lexie works without an account. An account is optional and can be used on our website (lexielearn.com) and in the mobile app, for example to open purchased study content. Signing in happens with your email address and a one-time code — there is no password. If you create an account, we process:

  • Your email address (used for signing in)
  • An account identifier created when you sign up
  • Purchase status (whether a purchase has been made with your account, so that paid content opens for you). When you sign in inside the mobile app, your account identifier is shared with our purchase management provider (RevenueCat) so that your purchase can be recognized across devices.
  • Study content you save to your account on the website

Accounts are intended for users aged 13 and over. Younger students can use everything Lexie does on a single device, without an account. You can delete your account and its data directly in the app, or by contacting us at elina.patjas@interlinear.tech.

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 (5 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 on the user's device. Content sent for AI processing is processed transiently and is not permanently stored on our servers.
  • Shared study sets are stored in our EU-hosted database for as long as the share link is active
  • Account data (email address, purchase status) is stored in an EU-hosted database (Supabase)
  • 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: Stored securely for up to 7 days to maintain context, 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. Twilio may retain message delivery logs under their own data retention policy, separately from LexieLearn's 7-day conversation history retention. See Twilio's privacy notice for details.
  • Google (USA / EU) - For AI processing of images and text. We use Google Cloud Vision for image text extraction (OCR), Google Generative AI (Gemini) for creating study materials, and Google Cloud Text-to-Speech and Speech-to-Text for audio features. Configured to not use customer data for model training.
  • Anthropic (USA) - For conversational AI responses on WhatsApp (Claude). Data sent to Anthropic is processed and not retained for model training under our API agreement.
  • OpenAI (USA) - For audio transcription and some text processing tasks. 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, conversation history (up to 7 days), and reminder schedules in a secure database.

For Mobile App:

  • Google (USA / EU) - For AI processing (Cloud Vision OCR, Gemini for study materials) and text-to-speech audio generation. Configured to not use customer data for model training.
  • Anthropic (USA) - For some content processing tasks, such as AI feedback on your answers. Data is processed and not retained for model training under our API agreement.
  • OpenAI (USA) - For audio transcription and some content processing. Configured to opt-out of training data.
  • Supabase (EU-hosted) - For account sign-in (email address), shared study sets, anonymous usage counters, and referral codes.
  • RevenueCat (USA) - For managing in-app purchases and subscriptions. RevenueCat processes your purchase history, an anonymous or account-linked user identifier, and the device information needed to validate purchases. Payment itself is handled by Apple's App Store or Google Play.
  • Resend (USA) - For delivering support and feedback messages you send through the app to us by email.

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 have the right to:

  • Receive information about the app's data processing
  • Object to data processing by stopping app use
  • If you have created an account: request access to, correction of, or deletion of your account data. You can delete your account directly in the app, or by contacting us at elina.patjas@interlinear.tech.
  • 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 5 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 (Anthropic Claude) to provide conversational responses
  • Conversation history is stored securely for up to 7 days to maintain conversational context and remember what you got wrong
  • After 7 days of inactivity, conversations are automatically deleted
  • Maximum 100 messages are retained per conversation
  • 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 Google (Gemini) 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. The app can be used fully without an account, and we do not knowingly collect personal data such as names, email addresses, or phone numbers from children. Accounts (which require an email address) are intended for users aged 13 and over.

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, Google, Anthropic, OpenAI, RevenueCat, Resend) 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

14.3 For privacy-related questions, data access requests, or to exercise your rights, please contact us at elina.patjas@interlinear.tech