Last updated: 14 June 2025
Introduction
JAIK LLC (“JAIK,” “Company,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose and safeguard Personal Data when you use the Captain English mobile or web application (the “Service”). It also explains your choices and rights.
Additional regional disclosures apply to:
California residents – see § 16 (CCPA/CPRA).
EU/EEA & UK residents – see § 17 (European Privacy).
Children under 18 – see § 15 (Children’s Privacy).
If you have any questions, e-mail us at adminllc@jaik.app
Definitions
Capitalised terms have the meanings below, matching our Terms & Conditions (updated 14 June 2025).
Account: The profile you create to access the Service.
App Store Account: Your Apple App Store or Google Play account.
Personal Data: Information that identifies or can identify an individual.
Processor / Service Provider: A third party that processes Personal Data on our instructions (e.g., Stripe, RevenueCat, Klaviyo, Microsoft Clarity).
Controller / Business: The entity deciding why and how Personal Data is processed — in this case, JAIK.
Child: A person under 13 years old in the USA, or under the local digital age of consent..
What Personal Data We Collect
We collect the following categories of data:
Profile Data: Display name, age-band, gender, hobbies, study motivation — provided by you.
Learning Data: Lesson history, progress scores, AI feedback, streaks — generated by the Service.
Contact Data: Your email address, used for magic-link sign-in — provided by you.
Subscription Data: Plan type, purchase and renewal dates — sourced from the App Store, Stripe, or RevenueCat.
Marketing Events: Email opens, push-token, ad-click attribution — from Klaviyo and ad networks.
Usage Data: IP address, device type, OS, crash logs, session length, heatmaps — collected automatically.
Optional Media: Future features may allow voice, photo, or video uploads — optional and user-controlled.
Note: We do not collect biometric data today. Any future speech or image features will be clearly disclosed and require consent if necessary.
Why We Process Your Data & Legal Bases
Provide core language-learning features – Contract (GDPR Art. 6(1)(b))
Personalise content, avatars, difficulty – Legitimate Interests (Art. 6(1)(f)); opt-out available
Process payments & subscriptions – Contract
Send service emails & push notifications – Legitimate Interests; marketing requires Consent
Analytics & diagnostics (Clarity, cookies) – Legitimate Interests; consent where required
Ad measurement (Meta, Google, TikTok) – Consent (EEA/UK); “Share” under CPRA
Legal compliance & fraud prevention – Legal Obligation
How We Use Your Data
We use your data to:
Create and manage your Account, and remember your preferences
Deliver lessons, track progress, and personalise learning
Process payments and manage subscriptions via Stripe, Apple, Google, and RevenueCat
Send service-related messages and, with consent, newsletters via Klaviyo
Analyze usage and improve performance via Firebase and Microsoft Clarity (pseudonymised)
Measure ads using hashed identifiers — see Section 12
Comply with legal obligations and defend against fraud or claims
Third-Party Processors
We use the following services:
Stripe: Payments — US (EU–US DPF & SCCs)
RevenueCat: Subscriptions — US (EU–US DPF & SCCs)
Apple / Google: In-app billing — Global
Klaviyo: Email and push campaigns — US (EU–US DPF)
Microsoft Clarity: Analytics and heatmaps — US (EU–US DPF)
Advertising Partners (Meta, Google, TikTok): Ad targeting — Global (SCCs or DPF)
All act under our instructions and may not use data for their own purposes.
Cookies & Similar Technologies
The mobile app uses SDK-level identifiers; the web app uses cookies for:
Essential operations (sign-in, load balancing) – cannot be disabled
Analytics (Clarity, Firebase)
Advertising (consent-based in EEA/UK)
Browser users can manage cookies via browser settings or opt-out portals like the Digital Advertising Alliance.
Data Retention
We keep Personal Data only as long as necessary:
Account & learning history – while your Account is active plus 24 months, then anonymised.
Payment records – 7 years for tax/audit.
Marketing opt-out logs – 5 years to demonstrate compliance.
Crash logs – 90 days.
You may delete your Account in-app; automated backend jobs purge associated data within 30 days.
Security
We follow industry standards including TLS 1.2+ in transit and AES-256 at rest (cloud provider default). Access is role-based and logged. Despite safeguards, no online service is 100 % secure; please protect your device and sign-in e-mail.
International Transfers
Your data may be processed in the United States and other countries. Transfers from the EEA/UK rely on:
EU–US Data Privacy Framework adequacy decision (10 July 2023) , where the recipient is certified; or
Standard Contractual Clauses approved by the European Commission / UK ICO.
Your Privacy Choices
You may:
Access / correct data: Email adminllc@jaik.app or use in-app tools
Delete your Account: Use “Delete Account” in settings
Download data (EU/UK): Email request; data provided in 30 days
Opt-out of marketing: Use unsubscribe links or app settings
Limit ads (US): Use OS features like “Limit Ad Tracking” (iOS) or “Opt out of Ads Personalization” (Android)
Behavioral Advertising (“Sale/Share” – California)
We use hashed e-mails or advertising IDs to measure ad conversions on Meta, Google, TikTok. Under CPRA this may be a “share” of Personal Data. California users can toggle “Do Not Share My Data for Ads” in settings.
Analytics & Automated Decision-Making
AI scoring adapts lesson difficulty but has no legal or similarly significant effect on you (e.g., no credit decisions). You can retake lessons or contact support to contest any outcome.
Links to Other Sites & Third-Party Content
Links inside the Service (e.g., YouTube grammar videos) are governed by their own policies—we are not responsible for external practices.
Children’s Privacy
The Service is usable by learners under 18. If we learn a user is under 13 and parental consent is not in place, we will delete the Account as required by COPPA. Parents may review or delete a child’s data by e-mailing adminllc@jaik.app.
Push notifications to minors comply with future FTC amendments (2024 proposal).
California Consumer Privacy (CCPA/CPRA)
California residents have the rights to know, delete, correct, limit, opt-out of share, and no retaliation. See Sections 11–12 for how to exercise them. We have not sold data for monetary consideration in the past 12 months.
Categories collected, disclosed or shared mirror § 3.
European Privacy (GDPR/UK GDPR)
JAIK LLC is the controller. We have not yet appointed an EU/UK representative under Art 27; until we do, contact adminllc@jaik.app.
Data subjects have rights of access, portability, rectification, erasure, restriction, objection and consent withdrawal. Complaints may be lodged with your local supervisory authority or the UK ICO.
"Do Not Track” Signals
The web app does not respond to browser DNT signals; instead, use the cookie banner and ad-tracking toggles.
Changes to This Policy
We may update this Policy. Material changes will be notified by e-mail or in-app at least 30 days before they take effect. The “Last updated” date reflects the newest version.
Contact Us
JAIK LLC
16192 Coastal Highway, Lewes, Delaware 19958, USA
E-mail: adminllc@jaik.app
© 2025 JAIK LLC. All rights reserved.
