CIPLE Ready ("we", "us", "our") operates cipleready.com. This Privacy Policy explains how we collect, use, and protect your personal data in compliance with the EU General Data Protection Regulation (GDPR) and Portuguese data protection law (Lei n.º 58/2019).
1. Data Controller
CIPLE Ready is operated by Yana Yarotskova, based in Cascais, Portugal.
Contact: hello@cipleready.com
2. What Data We Collect
- Account data: email address, name (when you sign up)
- Payment data: processed by Stripe. We do not store your credit card details. Stripe's privacy policy applies to payment processing.
- Usage data: pages visited, exercises completed, scores, XP points
- AI writing submissions: the texts you submit for AI feedback are processed by Anthropic's Claude API. These texts are not stored permanently and are not used to train AI models.
- Audio data: if you use the speaking recording feature, recordings are stored locally in your browser and are not uploaded to our servers.
- Cookies: see our Cookie Policy below.
3. Why We Collect Data
- To provide our service (exercises, progress tracking, AI feedback)
- To process payments
- To improve our platform
- To communicate with you about your account
- To send product updates (only with your consent)
4. Legal Basis (GDPR Article 6)
- Contract performance: processing necessary to provide the service you purchased
- Legitimate interest: improving our platform, preventing fraud
- Consent: marketing emails (you can unsubscribe anytime)
5. Data Sharing
We share data only with:
We do not sell your data to third parties. We do not share data with advertisers.
6. Data Retention
- Account data: retained while your account is active. Deleted within 30 days of account deletion request.
- Usage data: retained for 2 years for analytics purposes, then anonymized.
- AI writing submissions: not stored permanently. Processed in real-time and discarded.
- Payment records: retained for 7 years as required by Portuguese tax law.
7. Your Rights (GDPR)
You have the right to:
- Access your personal data
- Correct inaccurate data
- Delete your account and data ("right to be forgotten")
- Export your data in a portable format
- Withdraw consent for marketing emails
- Object to data processing
- Lodge a complaint with the Portuguese Data Protection Authority (CNPD)
To exercise any of these rights, email hello@cipleready.com. We will respond within 30 days.
8. International Data Transfers
Some of our service providers (Anthropic, Vercel) are based in the United States. Data transfers are protected by Standard Contractual Clauses (SCCs) as required by GDPR.
9. Children
Our service is not directed at children under 16. We do not knowingly collect data from children under 16. If you are a parent and believe your child has provided us with personal data, contact us and we will delete it.
10. Changes
We may update this policy. We will notify you by email or through the platform if changes are significant.