Privacy Policy

1. Data we collect

We may collect the following personal data:

• account data: name, phone number, email, password (encrypted), gender, and date of birth (if provided);
• authentication data: the one-time code sent by SMS, Telegram identifier;
• educational data: level-test results, course progress, and results of tests and exams taken;
• speaking-practice data: voice recordings and their text transcripts;
• communications: messages with teachers and the support team;
• rewards and referral data;
• technical data: device type, browser, approximate location (based on IP), and usage statistics.

We do not collect or store your full bank card numbers — payments are processed directly by the payment providers.

2. How we use data

The collected data is used for the following purposes:

• creating your account, authenticating you, and providing access to the Platform;
• delivering educational services and saving and personalising your progress;
• providing AI-assisted assessments and recommendations in speaking practice;
• processing payments and managing access to courses;
• support and communicating with you;
• improving service quality and ensuring security;
• complying with legal requirements.

3. Legal basis for processing

We process personal data on the basis of your consent, the need to perform the contract (the offer), and in accordance with the Republic of Uzbekistan Law “On Personal Data”. You may withdraw your consent at any time.

4. Sharing with third parties

We do not sell your data. We share it with trusted service providers (sub-processors) needed to deliver the service:

• Supabase — database, authentication, and storage;
• Google (Gemini) — AI speaking-practice tutor; during a session we send your spoken audio, the conversation transcript, and your first name;
• Bunny.net — delivery of video and media content;
• an SMS gateway provider — sending one-time verification codes;
• Telegram — login and seminar participation;
• payment providers (Payme, Click, Paynet, Uzum Bank, Octobank) — processing payments.

We may also disclose data where required by law or in response to a lawful request from authorised state bodies.

5. Cross-border data transfer

The servers of some of the service providers listed above are located outside the Republic of Uzbekistan. This means your personal data may be processed and stored on servers in foreign countries.

By using the Platform and accepting this policy, you consent to such cross-border transfer of your data. When transferring data this way, we take reasonable measures to ensure it is adequately protected.

6. Data retention

We retain your personal data for as long as your account is active and for the period necessary to provide the services and meet legal requirements.

When an account is deleted, certain data (for example, the phone number and subscription history) may be retained in anonymised form to prevent fraud and abuse of benefits.

7. Security

We apply technical and organisational measures (encryption, access restrictions, etc.) to protect your data from unauthorised access, alteration, or loss. However, no service can guarantee one-hundred-percent security of data transmission over the internet.

8. Your rights

You have the following rights:

• access to your personal data and obtaining a copy of it;
• correction of inaccurate data;
• requesting deletion of your data;
• withdrawing your consent to processing.

To exercise these rights, contact us at Abdurauf.gr@gmail.com. Account deletion is also available through the profile settings on the Platform.

9. Cookies and local storage

The Platform uses cookies and browser local storage to maintain your session, remember settings, and improve performance. You can manage cookies through your browser settings, but this may affect how some features work.

10. Minors

The Platform is not intended for persons under 18, and we do not knowingly collect their personal data. If such data is found, we will delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time. The updated version takes effect once published on the Platform, and the “Last updated” date is revised accordingly.

12. Contact

For privacy questions or requests, contact us:

• Organisation: Libera Education
• Address: Samarkand, Republic of Uzbekistan
• Email: Abdurauf.gr@gmail.com
• Phone: +998 99 876 12 71