Privacy Policy

This Privacy Policy describes how Elpis Labs, a brand operated by Daniil Kotau, an individual entrepreneur registered in Georgia ("Brieflex", "we", "us", or "our"), collects, uses, discloses, transfers, stores, retains, and otherwise processes Your personal information when You sign up for an account and use the Brieflex mobile application, the website located at brieflex.app, and related services (collectively, the "Brieflex Services"). References to "You" or "Your" mean the individual user of the Brieflex Services.

Brieflex is a mobile English-learning application that delivers a structured, research-backed English program together with a personal AI teacher named "Emma". Please read this document carefully to understand how we collect, use, protect, and otherwise handle Your personal information. For the purposes of this Privacy Policy, "Personal Information" means any information that identifies You, or that can reasonably be linked to You. By continuing to use the Brieflex Services, You consent to the practices described in this Privacy Policy.

WHO WE ARE AND HOW TO CONTACT US

Brieflex is operated by Elpis Labs, a brand of Daniil Kotau, an individual entrepreneur registered in Georgia. For the purposes of data-protection law, we are the data controller for the Personal Information processed through the Brieflex Services. You can contact us at any time about privacy matters at support@brieflex.app. If You are located in the European Economic Area (EEA) or the United Kingdom and we are required to designate a representative, the representative's details will be made available on request.

AGE RESTRICTION — ADULTS ONLY

The Brieflex Services are strictly for users aged 18 and older. We do not market the Brieflex Services to, or knowingly create accounts for, anyone under 18, and account creation is gated behind adult sign-in flows. If we learn that we have collected Personal Information from a person under 18, we will delete it. If You believe a minor has provided us with Personal Information, please contact support@brieflex.app.

INFORMATION BRIEFLEX COLLECTS

Brieflex collects only what it needs to provide the Brieflex Services. The categories below depend on how You use the Brieflex Services.

Registration and Identity Data. When You sign up using Apple Sign-In, Google Sign-In, or an email magic link, we receive and store Your email address, Your name if You choose to provide it, a stable account identifier issued by our authentication provider, and the sign-in method You used. We do not receive or store the passwords of Your Apple, Google, or email accounts.

Onboarding and Profile Information. During onboarding You may provide, in order to personalize Your program, Your learning goal, Your profession or field, the learning challenge You want to overcome, Your starting level and weekly study goal, and Your device language and time zone. We do not ask for or store Your salary, income, or any financial amounts.

Learning Activity. As You use the program, we store Your learning state so that the Brieflex Services function and so that You can see Your progress, including the lessons, homework, reviews, and exams You complete, Your answers and attempts, and the letter grades, GPA, and transcripts generated by the application. These grades and transcripts are internal application feedback only, and are not accredited or officially recognized qualifications.

Emma Chat, Voice, and Memory. Emma is an AI English teacher You can chat with. When You use Emma, we process the text messages You send and receive in the chat. If You use the voice feature, Your audio is sent to a third-party speech-to-text provider for transcription so that Emma can understand You; this input audio is not stored on our servers and is discarded immediately after it is transcribed. Emma's spoken (text-to-speech) replies are generated and cached on our content-delivery storage for up to 30 days, after which they are automatically deleted. To teach You more effectively, Emma also keeps a small set of teaching-relevant notes between sessions, such as Your stated learning goal and deadline, practical context for examples (for instance, Your city or region, field of work, interests, and native language), and Emma's own pedagogical notes about how You learn. Emma's memory is deliberately limited: a built-in privacy filter blocks and never stores sensitive categories, including health and medical information, financial amounts, religion and political views, relationship and dating details, physical appearance, and the names of Your family members. You can view and delete everything Emma remembers at any time, as described in the Your Rights and Choices section below.

Subscription Information. Brieflex subscriptions are purchased and managed through the Apple App Store and Google Play, with subscription status handled by our subscriptions provider. We do not collect or store Your credit-card or banking details, which are handled entirely by Apple and Google. We receive subscription-status information such as Your plan, whether a trial is active, renewal and expiry dates, and a subscription identifier.

Device, Technical, and Usage Information. To keep the Brieflex Services working, secure, and improving, certain data is automatically collected, including the application version and build, the platform (iOS or Android), the operating-system version and device model, network type, language, and time zone, the IP address and similar technical identifiers used for delivery, security, and diagnostics, and product-analytics events (such as which screens and features are used) together with crash and error reports.

Website Information. The brieflex.app website may use essential cookies and basic, privacy-respecting analytics needed to operate and measure the site. We do not use the Brieflex Services to run advertising networks, and we do not sell Your Personal Information.

HOW BRIEFLEX COLLECTS YOUR DATA

Brieflex collects and processes data when You register for and use the Brieflex Services, when You voluntarily complete a survey or provide feedback, automatically through Your device and Your interaction with the application and website, and through the third-party service providers that help us operate the Brieflex Services.

HOW WE USE YOUR INFORMATION

We use Personal Information to provide the Brieflex Services (to create and maintain Your account, deliver lessons, grade Your work, run Emma, and sync Your progress across devices); to personalize Your learning (to tailor Your program, recommendations, and Emma's teaching to Your goal and level); to process subscriptions (to confirm entitlement and manage trials, renewals, and reactivation through the app stores); to communicate with You (to send service messages, learning reminders and push notifications, which You can control, and to respond to support requests); to maintain and improve the Brieflex Services (to diagnose problems, monitor performance, analyze usage in aggregate, and develop new features and improvements, including to our AI features); to keep the Brieflex Services safe (to detect, prevent, and address fraud, abuse, security incidents, and violations of our Terms); and to comply with our legal obligations and enforce our legal rights.

LEGAL BASES FOR PROCESSING

If You are in the EEA or the UK, we rely on the following legal bases under the General Data Protection Regulation ("GDPR") and the UK GDPR: performance of a contract, to provide the Brieflex Services You sign up for; legitimate interests, to secure, maintain, analyze, and improve the Brieflex Services, where not overridden by Your rights; consent, where required, for example for certain push notifications or optional analytics, which You can withdraw at any time; and compliance with a legal obligation. Brieflex is established in Georgia and also processes Personal Information in accordance with the Law of Georgia on Personal Data Protection.

HOW WE SHARE INFORMATION

We do not sell Your Personal Information. We share it only in the limited circumstances described below.

Service Providers. We rely on trusted third parties that process data on our behalf, under contractual confidentiality and data-protection obligations, and only to provide the Brieflex Services: Supabase, for authentication and identity; RevenueCat, for subscription-status management; the Apple App Store and Google Play, for payment processing, sign-in, and push delivery; Anthropic, for AI processing for Emma and for grading certain open-ended answers; OpenAI, for speech-to-text transcription of voice messages; ElevenLabs, for text-to-speech generation of Emma's voice replies; Expo, for push-notification delivery; Mixpanel, for product analytics; Sentry, for crash and error reporting; LangSmith, for diagnostic tracing of AI interactions; Cloudflare, for content storage and delivery; and our cloud-hosting providers, such as Railway and AWS, for application and database hosting. This list may change as the Brieflex Services evolve, and we will keep it current.

Legal and Protective Disclosures. We may disclose information where we reasonably believe it is necessary to comply with the law, a legal process, or a government or law-enforcement request; to enforce our Terms; to detect, limit, or prevent fraud or security or technical issues; or to protect the rights, property, or personal safety of Brieflex, our users, or the public.

Business Transfers. If Brieflex is involved in a merger, acquisition, reorganization, or sale of assets, Personal Information may be transferred as part of that transaction, subject to this Privacy Policy.

Aggregated or Anonymized Information. We may create and use anonymized or aggregated information that no longer identifies You for any purpose, including analytics and improving the Brieflex Services. Anonymized or aggregated information does not identify You as an individual and is therefore not Personal Information as defined in this Privacy Policy.

USING YOUR DATA TO IMPROVE THE BRIEFLEX SERVICES

We may use the content You provide, such as Your answers and Your interactions with Emma, to operate, maintain, secure, evaluate, and improve the quality and accuracy of the Brieflex Services, including our curriculum, our grading, and our AI features. Where we use Your content for these improvement purposes beyond what is necessary to deliver the Brieflex Services to You, we do so using de-identified or aggregated data wherever practicable. We do not access the substance of Your conversations except where reasonably necessary to operate, support, secure, or improve the Brieflex Services, to respond to Your requests, or to comply with our legal obligations.

INTERNATIONAL DATA TRANSFERS

Brieflex is based in Georgia, and our service providers operate in various countries, including the United States. As a result, Your Personal Information may be transferred to, stored in, and processed in countries other than Your own, whose data-protection laws may differ from those where You live. Where we transfer the Personal Information of EEA or UK users outside the EEA or UK, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses or an applicable adequacy decision. By using the Brieflex Services, You agree to Your Personal Information being transferred outside Your original territory and subject to the terms of this Privacy Policy. You can request more information about these safeguards via support@brieflex.app.

HOW LONG WE KEEP YOUR INFORMATION

We keep Personal Information only for as long as needed for the purposes described in this Privacy Policy, and then delete or anonymize it. As an indication, we keep account and profile data for as long as Your account is active, and after You request account deletion we remove Your data within approximately 30 days; learning attempts and history for up to 2 years; Emma chat messages active for approximately 90 days, archived for up to 1 year, and then deleted; Emma's text-to-speech audio for up to 30 days; voice input audio not at all, as it is discarded immediately after transcription; and analytics and crash data according to each provider's standard retention settings. We may retain a minimal record proving that a deletion was carried out, such as the date and the types of records cleared, as required for our compliance obligations; this record contains no content from Your conversations.

HOW WE STORE YOUR DATA AND SECURITY

The security of Your Personal Information is important to us. We use commercially reasonable technical and organizational measures designed to protect Your Personal Information against unauthorized or unlawful processing and against accidental loss, destruction, or damage, including encrypted storage of authentication tokens, access controls, and redaction of sensitive fields from logs and diagnostics. Unfortunately, no method of transmission over the internet or storage of information can be guaranteed to be 100% secure. As a result, while we strive to protect Your Personal Information, we cannot ensure or warrant its absolute security, and You do so at Your own risk. Please help keep Your account safe by protecting Your sign-in method and signing out on shared devices.

YOUR RIGHTS AND CHOICES

Depending on where You live, You have some or all of the following rights over Your Personal Information: the right to access and obtain a copy of the Personal Information we hold about You and to receive it in a portable format; the right to correct inaccurate or incomplete information; the right to deletion of Your Personal Information; the right to object to, or request restriction of, certain processing; the right to withdraw consent where we rely on consent, without affecting prior processing; and the right to lodge a complaint with Your local data-protection authority.

You can exercise these rights as follows. To delete Your account, use the in-application option or email support@brieflex.app; deletion is processed with a short grace period and then permanently removes Your data within approximately 30 days. To control what Emma remembers, use the in-application "What Emma remembers" screen, which lets You view Emma's notes, delete any individual item or section, or choose "Forget everything", with a confirmation step and a grace period before the data is cleared. To manage notifications, adjust push notifications in Your device settings or in the application. To manage Your subscription, use Your Apple App Store or Google Play account. For any other request, including access, export, or correction, email support@brieflex.app; we may need to verify Your identity before acting, and we will respond within the time required by applicable law. We do not discriminate against You for exercising any of these rights.

COOKIES AND SIMILAR TECHNOLOGIES

Our mobile application does not use advertising cookies or third-party advertising trackers. Our website (brieflex.app) may use essential cookies and storage required for the site to function, and analytics to understand, in aggregate, how the site is used and to improve it. Most browsers let You block or delete cookies through their settings; blocking essential cookies may affect how parts of the site work. Our site does not recognize or respond to browser "Do Not Track" signals.

CALIFORNIA PRIVACY RIGHTS

If You are a California resident, California law requires us to provide certain additional information about how we collect, use, and share Your Personal Information as defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"). The categories of Personal Information we collect are described in the Information Brieflex Collects section above, and include identifiers (such as name, email address, and IP address), commercial information (such as Your subscription and transaction status), internet and other network activity information (such as application and website usage), geolocation data (such as country or region derived from Your IP address or time zone), audio information limited to the transcription of voice messages (input audio is not stored), and inferences drawn from Your use of the Brieflex Services. We use and share these categories for the business purposes described throughout this Privacy Policy.

As a California resident, You have the right to know what Personal Information we collect and how we use it, the right to access and delete it, the right to correct it, and the right to opt out of the "sale" or "sharing" of Personal Information. We do not sell or share Your Personal Information as those terms are defined under California law. To exercise Your rights, contact support@brieflex.app. We will take reasonable steps to verify Your identity before responding, and we will not discriminate against You for exercising any of Your rights.

GDPR NOTICE FOR RESIDENTS IN THE EEA OR UK

If You are an EEA or UK resident, in addition to the legal bases described above, You are entitled to certain rights in relation to Your Personal Information.

Right to Access: You have the right to request access to any of Your Personal Information that we hold, and to obtain information about its processing.

Right to Correct: You are entitled to have any inaccurate, incomplete, or out-of-date Personal Information rectified.

Right to Erasure: You are entitled to have Your Personal Information erased in certain circumstances, such as where You have withdrawn Your consent, where You object to processing based on legitimate interests and we have no overriding legitimate grounds, or where Your Personal Information has been unlawfully processed.

Right to Data Portability: where we rely on Your consent or on the performance of a contract, and the Personal Information is processed by automated means, You have the right to receive that Personal Information in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller where technically feasible.

Right to Restriction of Processing: You have the right to restrict our processing of Your Personal Information in certain circumstances, such as where You contest its accuracy, where the processing is unlawful but You do not want it erased, or where You have objected to processing pending verification of our grounds.

Right to Object: You can object to our processing of Your Personal Information that is based on our legitimate interests, and we will no longer process it unless we can demonstrate compelling legitimate grounds, and You may object at any time to the use of Your Personal Information for direct marketing.

Right to Withdraw Consent: where processing is based on Your consent, You may withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.

You also have the right to lodge a complaint with the supervisory authority of Your habitual residence, place of work, or place of alleged infringement. Where Your Personal Information is transferred outside the EEA or UK, we take steps to ensure it receives a level of protection equivalent to that within the EEA or UK, including by entering into the European Commission's Standard Contractual Clauses. You can obtain details of the relevant transfer mechanism by contacting us as set out in the How to Contact Us section.

PRIVACY POLICIES OF OTHER WEBSITES AND SERVICES

The Brieflex Services rely on, and may link to, third-party platforms, such as Apple, Google, and the providers listed in the How We Share Information section. Their handling of Your information is governed by their own privacy policies, not this one. We encourage You to review them.

CHANGES TO THIS PRIVACY POLICY

We keep this Privacy Policy under regular review and will post any updates on this page. When we make changes, we will revise the "Effective" date above, and where the changes are material we will provide additional notice as appropriate. Your continued use of the Brieflex Services after an update means You accept the revised Privacy Policy.

HOW TO CONTACT US

If You have any questions about this Privacy Policy, the data we hold about You, or You would like to exercise one of Your rights, please contact us at support@brieflex.app.

Brieflex — a product of Elpis Labs, operated by Daniil Kotau, individual entrepreneur, Georgia.