Privacy Policy

Last updated: 13/02/2026

This Privacy Policy describes how the APRIL (“Service”, “we”) collects, uses, and shares personal data when you access and use the English practice Service in dialogue (text and voice) in the browser.

1) Who is the controller (responsible for the data)

The controller of personal data is the Individual Entrepreneur registered in the Russian Federation (“Controller”).

Contact (privacy / LGPD / requests): ml.st.hudiev@gmail.com

2) What is APRIL

APRIL is a web service for practicing English in a dialogue format. You can chat with AI via text or voice, receive responses in the same format, see short corrections of errors, and translation by button in the chat. The Service maintains the context of the conversation and shows progress (time practiced and error patterns).

3) What data do we collect

We only collect the data necessary to operate the Service:

3.1. Data provided by you

• E-mail (mandatory only for purchasing/subscribing after the free limit).
• Content of conversations (text and, if applicable, voice messages and generated transcripts/output).
• Support requests (if you contact us by email).

3.2. Data collected automatically

• Technical and usage data: IP address, browser type, language, pages visited, usage events, timestamps, device identifiers, and cookies/ad identifiers when applicable.
• Cookies and similar technologies (detailed in the Cookie Policy).

4) Account and free use

You can use up to 5 free messages without creating an account. After this limit, we request e-mail to enable the purchase and access to the paid plan.

5) How we use the data (purposes)

We use your data for:

• Provide and maintain the Service (including responding to messages, maintaining context, and displaying progress).
• Improve quality and security of the Service (abuse prevention, failure diagnosis, performance).
• Fulfill legal obligations and respond to requests from authorities when applicable.
• Measurement and disclosure through usage analysis and pixels (as per the Cookies section).

We we do not send newsletters or recurring promotional emails. We may send necessary communications for operation (e.g.: purchase confirmation, security notices, relevant changes).

6) Legal basis (LGPD)

When applicable, we process data based on:

• Contract execution (to operate the Service and deliver the paid plan).
• Legitimate interest (security, fraud/abuse prevention, Service improvement).
• Consent (mainly for non-essential cookies, such as advertising/measurement, when required).
• Compliance with legal obligation (when applicable).

7) Data sharing (third parties)

We may share data strictly when necessary:

7.1. AI processing (OpenAI)

To generate responses, corrections, and translations, we send to the provider OpenAI the necessary content of the conversation (text and/or audio). This provider acts as operator/processor to enable the AI feature.

7.2. Payments (Robokassa)

Payments are processed by Robokassa. We do not store complete card data. We may receive from Robokassa data such as payment status, transaction identifiers, and information necessary for reconciliation and support.

7.3. Metrics and advertising

We use:

• Google Analytics
• Yandex Metrica
• Meta Pixel

These services may collect data via cookies and identifiers (see the Cookie Policy).

7.4. Hosting and infrastructure

The Service is hosted on servers located in Amsterdam (Netherlands). Infrastructure providers may process data for hosting, logs, and security purposes.

8) International data transfer

If you are in Brazil, your data may be transferred and processed outside of Brazil, including Netherlands (Amsterdam) and by global providers (e.g., OpenAI, Google, Meta, Yandex, Robokassa). We adopt reasonable measures for the protection and security of this data during transfer and storage.

9) Retention (how long we keep it)

• Content of conversations: we store for up to 1 (one) yearunless you request deletion beforehand (when possible) or if there is a legal obligation to retain.
• Account data (email) and subscription records: for the necessary period to manage the plan and fulfill legal/accounting obligations.
• Logs and technical data: for the time necessary for security and diagnostics.

10) Security

We adopt reasonable technical and organizational measures to protect data against unauthorized access, alteration, disclosure, or destruction. No system is 100% secure; therefore, we cannot guarantee absolute security.

11) Your rights (LGPD)

You can request:

• confirmation and access to the data;
• correction;
• anonymization, blocking, or deletion when applicable;
• portability when applicable;
• information about shares;
• revocation of consent (e.g.: non-essential cookies, when applicable).

How to exercise: write to ml.st.hudiev@gmail.com. Additionally, the Service offers the 'Delete account and data' buttonthat initiates deletion (with possible minimum retention necessary for legal obligations).

12) Children and adolescents

The Service is intended for over 18 years old.

13) User content

The content you send (text/voice) is used to provide the Service. We do not publish your conversations.

14) Changes to this Policy

We may update this Policy. The current version will be available on the website with the update date.

Contact: ml.st.hudiev@gmail.com