Privacy Policy

Effective Date: 1st December 2025

FRATA LTD ("we", "us", or "our") operates the Alyona: Learn Russian mobile application (the "App"). This Privacy Policy explains how we collect, use, and protect your information when you use our App.

1. Information We Collect

We collect minimal information to provide and improve our service:

Automatically Collected Information

• Device Information: Device type, operating system version, unique device identifiers
• Usage Data: Anonymous analytics about how you use the App (e.g., features used, time spent, crash reports)
• Purchase Information: Records of subscriptions and purchases made through the App

Information We Do NOT Collect

• We do not collect your name, email address, or other personal contact information
• We do not collect location data
• We do not collect any user-generated content

2. How We Use Your Information

We use the collected information to:

• Provide and maintain the App
• Improve and optimise the App's performance
• Fix bugs and technical issues
• Process and manage your subscriptions
• Understand how users interact with the App

3. Legal Basis for Processing

We process your information based on:

• Contract Performance: To provide the service you have subscribed to
• Legitimate Interests: To improve our App and fix issues, where this does not override your rights

This applies to users in the UK, European Economic Area (EEA), and other jurisdictions with similar requirements.

4. Third-Party Services

We use the following third-party services that may collect information:

These services have their own privacy policies. We encourage you to review them.

5. Data Retention

We retain your information only as long as necessary to provide our services:

• Analytics data is retained for up to 14 months
• Purchase records are retained as required by applicable law and for accounting purposes

6. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including the United States (where Firebase servers are located). These transfers are protected by appropriate safeguards in compliance with applicable data protection laws.

7. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal data:

For Users in the UK, EEA, and Switzerland

Under GDPR/UK GDPR, you have the right to:

• Access: Request a copy of your data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Request we limit processing of your data
• Portability: Request transfer of your data to another service
• Objection: Object to processing based on legitimate interests

For Users in California (USA)

Under the California Consumer Privacy Act (CCPA), you have the right to:

• Know what personal information we collect
• Request deletion of your personal information
• Opt out of the sale of personal information (note: we do not sell your data)
• Non-discrimination for exercising your rights

For Users in Brazil

Under the Lei Geral de Proteção de Dados (LGPD), you have similar rights to access, correct, and delete your data.

For All Users

Regardless of your location, you may contact us to request information about or deletion of your data.

To exercise any of these rights, contact us at support@frata.io.

8. Children's Privacy

The App is not specifically targeted at children under 13 years of age (or 16 in some jurisdictions). We do not knowingly collect personal information from children under the applicable age in their jurisdiction. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@frata.io and we will delete such information.

9. Data Security

We implement appropriate technical and organisational measures to protect your information against unauthorised access, alteration, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top.

11. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact us:

FRATA LTD
82A James Carter Road
Mildenhall
United Kingdom IP28 7DE

Email: support@frata.io