Clarity Privacy Policy

1 Who is responsible for your data

Clarity is developed and operated by Ilnar Sirazetdinov (“we”, “us”). We are the controller of the personal data described in this policy.

You can reach us at support@myclaritylab.app for anything in this policy: questions, requests to see, correct or delete your data, and complaints.

This policy does not cover the websites and apps of other companies that the app links to or uses, such as Apple, Google or OpenAI. Their own policies apply to what they do; section 7 gives the links.

2 What data we process, why, and on what legal basis

The cards below group the data by feature. “Legal basis” refers to the GDPR and the UK GDPR, which apply to users in the European Economic Area (EEA), the UK and, in a similar form, Switzerland. For users elsewhere we process the same data for the same purposes under the law that applies to you.

Signing in (the account data above) is necessary to use Clarity: without it we cannot create or secure your account. Everything else you provide, such as support messages, is optional. We do not make decisions about you that have legal or similarly significant effects by automated means; the AI only scores your practice answers and replies in conversations.

3 What other people can see

Clarity has social features. Here is what other users can see about you, and when.

• Friends. As soon as a friend request is sent, the other person in it (whether they received the request or sent it) gets your nickname, avatar, account number, friend code and an internal account ID in their app, even before the request is answered; the Friends screen shows the nickname and the friend code. Once you accept a request, your friend can also ask our servers for the events recorded for you for a friend feed, which come with your nickname: reaching a streak of 10, 50 or 100 days, starting your first paid plan, and adding an official catalog dictionary. The app does not show a friend feed, but our servers hand these events to an accepted friend whose app asks for them. They can be read for 14 days (7 days for catalog dictionaries); the records are kept until your account is erased or reset (section 9). The feed has no setting of its own: the switch “Show my progress to friends” (next paragraph) covers it, and while it is off our servers hand none of these events to your friends. The events are not deleted and our servers go on recording them; if you turn the switch on again, your friends can read again those that can still be read. Our servers give the other person’s app only the details named in this paragraph and the next one; the rest of your profile, such as your e-mail address, is not given to it.
• Your plan, streak and study time. Unless you turn it off, your friends also see, on their Friends screen, the name of your current plan (Free, Plus, Pro or Pro Talk), your current streak in days (0 when your streak has ended), your study time for each of the last ten days (their app shows the days of the current week) and your total study time. Only a friend, meaning a person whose friend request has been accepted, can get these details: not a person who has only sent or received a request, not a stranger, not a person you have blocked or who has blocked you, and no longer a person once you or they have deleted the friendship. They are also hidden while your account, or theirs, is waiting to be erased (section 9). In Profile > Account > Friends, the switch “Show my progress to friends” is on by default; when you turn it off, your friends no longer see these details, and their app tells them that you do not share your progress; your study time stays saved in your account (section 2) and is only hidden from them. The same switch also hides from them the feed events described in the previous paragraph. Only the study time is counted and reported by the app on your device, and we do not check it; the plan comes from our records of your App Store subscription or of a plan that we granted you, and the streak from our own records. All three are for information only, and we do not use them to rank users or for advertising. Section 2, “Progress shown to friends”, says what the app sends and how long our servers keep it.
• Earlier multiplayer rooms. Multiplayer rooms no longer exist in the app: in earlier versions, the other people in the room saw your nickname, your moves (including the words you typed) and the text you were typing while you played, and the records of those rooms and moves stay on our servers until your account is erased, but nobody can join, open or read them through the app any more. Our servers also still hold the tables of a joint Memory mode (a Memory game with a friend). As far as we know, no app version ever offered it, so they should hold nothing about you; if they do, those records are handled in the same way.
• Earlier sharing of dictionaries and tests. The current version of the app cannot share a dictionary or a test, send or answer invitations, or show who accepted one. Earlier versions could, and records of that can still be on our servers: the invitation, who accepted it and when, the completion and mistake counters that the recipient sent, the title of the item and, for a test, its text. Someone who accepted a dictionary read it on our servers. The current version no longer lists or opens it for them (the app lists only the dictionaries that belong to the account you are signed in with), but their access on our servers is not switched off automatically. Until you delete the dictionary, either of the two accounts is erased, or you ask us to end it, they may technically still be able to read its text through our servers. If they had saved the dictionary on their phone for offline use, that saved copy stays on the phone until they sign out or remove the app, and we cannot erase it. Someone who accepted a test received its text as a copy on their own phone. It stays there as their own test, which they can edit and save as a file, and we cannot erase it. Older app versions that are still installed may still show sharing screens, but our servers no longer accept sharing, invitations or answers to them from any app version. These records are erased when your account is erased (section 9), and the records of a dictionary also when you delete that dictionary; deleting a test on your phone does not erase our copy of it. To end an earlier share or have the records erased sooner, write to support@myclaritylab.app.
• Earlier features (teacher classes and leagues). Earlier app versions had teacher classes. The current version does not show them and does not create them. Records those versions created (class membership and study plans; what a teacher could see of your study time and mistakes) can still be on our servers, and an older app version that is still installed may show them to the teacher of a class you joined. Our servers also still hold tables for weekly leagues (a league group and weekly XP). No app version ever displayed them, so they should hold nothing about you; if they do, those records are handled in the same way. All these records are erased when your account is erased (section 9). To have them erased sooner, write to support@myclaritylab.app.
• Friend code. Anyone who knows your friend code can send you a friend request; the app adds friends by the friend code only, and your account number cannot be used for it. The person who sends a request gets the details described under “Friends” above at once, and you get theirs; you become friends when you accept, or at once when you and the other person have each sent the other a request. To limit abuse, we limit new friend requests to 20 for each account in any 24 hours. If you turn on “Nobody can add me” in Profile > Account > Friends (section 2), nobody can send you a new friend request until you switch it off; you can still send your own. If you block a person, they can no longer send you a request, and they are not told (they get the same answer as for a code that does not exist); the block lasts until you unblock the person or until one of the two accounts is erased or reset (section 9).
• Files from earlier versions. If you attached images or audio to your dictionaries in earlier versions of the app, anyone who has the address of such a file can open it (section 2, “Content you create”). The current version does not upload such files.
• While a deletion is pending. From the moment you ask to delete your account until the erasure date (section 9), the account is hidden from other users: they cannot find you by friend code, cannot send you a friend request or answer one of yours, do not see you in a friend list or the friend feed, and cannot see your plan, streak or study time. Your friendships, requests and blocks are not erased yet: they are shown again if you restore the account (a reset, section 9, erases them at once). The other records and files from earlier versions described above are not switched off by it: they stay as described there until your account is erased, and copies on other people’s phones are not affected. Our staff can still see the account (see “Our staff” below). If you restore the account, everything is visible again as before.
• Our staff. Authorised people can see account data in our administration tool when needed for support, security and subscriptions: e-mail address, nickname, progress, support tickets and complaints, and subscription state.

If you want another user’s connection or content removed, write to support@myclaritylab.app.

4 AI features and voices

Practice with AI

To create an exercise and to check your answer, our server sends OpenAI the source sentence, the answer you typed, the theme you set (text you typed, or one word from a dictionary you chose), the language pair, your level, the grammar topic and the reference answers. It does not send your name, e-mail, nickname, account ID or any other identifier. Please do not put personal information in your answers.

Before the app first sends your text, it shows a window that names OpenAI, lists what is sent and what is not, says that single words of the correct sentence, and of your own answer when it is graded correct, may go to the voice-synthesis service Fish Audio (section 2, “Spoken words”), and asks for your agreement. If you choose “Not now”, nothing is sent and the practice does not start. You can withdraw your consent at any time in Profile > Settings (“AI processing consent”); the app then asks again the next time you start. What was sent earlier stays with OpenAI under its own rules (see “How OpenAI treats the data” below). The app keeps your choice on your device, for your account, and we do not receive it; if you sign in on another device or with another account, or the app’s data is erased, it asks again. Versions of the app from before this window did not ask; the current version asks at the next start, also if you used the feature before.

A sentence the AI generated for you is also copied into a shared bank of exercises that other learners may receive. The copy contains no account identifier and none of your answers.

Talk with AI

Talk is available on iPhone (iOS 26 or later), depending on your plan. Before first use the app shows a consent screen; you can withdraw your consent in the Talk settings.

• Clarity API. Our server uses our own OpenAI account to set up the voice connection and to pass on your text requests, the agent settings (name, interests, writing-style examples, topic) and the recent conversation (up to the last 40 entries, 6 KB). Your voice travels directly between your device and OpenAI. For some tasks, such as finding a conversation topic, OpenAI may run a web search. We ask OpenAI not to store the responses (the “store” option is off); OpenAI’s own safety-monitoring retention can still apply.
• Your own OpenAI key. Everything goes directly from your device to OpenAI with your key, which is saved in the iOS Keychain on that device, is not synchronised, and is never sent to us. Your OpenAI account settings apply.
• What we keep. Only usage records on our server (section 2). Conversations, assessments and agents are stored on your device. The app does not save raw audio.

How OpenAI treats the data

According to OpenAI’s published API documentation, content sent through the OpenAI API is not used to train OpenAI’s models unless the customer opts in, and may be retained by OpenAI for a limited time (up to 30 days) for abuse monitoring. These are OpenAI’s rules and OpenAI can change them; see OpenAI’s privacy policy and its API data-controls documentation.

Voice synthesis

The spoken examples of many words in the app are generated by an AI voice-synthesis service (Fish Audio). They are synthetic voices created from text, not recordings of a person reading that text. Only the single words in section 2 (“Spoken words”) are sent for this.

5 Advertising and your choices

• Who sees ads. Only accounts without a paid plan, and only on iPhone and iPad. Every paid plan removes ads.
• What kind. Rewarded video ads from Google AdMob: some are shown after a lesson, others when you choose to watch one to earn hearts or diamonds.
• What Google receives. As Google describes, its SDK can process your IP address, device and app information, identifiers, ad interactions and diagnostic data to request, show and measure ads and to prevent fraud. Google’s own privacy policy covers this; see How Google uses data for ads. We do not give Google your e-mail, nickname or account ID.
• Your consent in the EEA, the UK and Switzerland. For an account without a paid plan, the app asks Google’s consent service (Google User Messaging Platform) before it requests any ad, and shows Google’s consent form where the rules of these regions require it. Ads are requested only if your choice allows it. You can accept, decline or manage options in the form.
• If you decline. Google may show ads that are not personalised, or none at all, depending on your choices and Google’s rules. Then the extra hearts or diamonds from ads may be unavailable.
• Change your choice. Where the form applies to you, Profile > Settings shows an “Ad privacy options” entry that opens it again. On iOS you can also manage tracking permission for apps in Settings > Privacy & Security > Tracking.
• Tracking prompt. After Google’s consent form, the app asks for Apple’s “Allow tracking” permission, once, and only for an account without a paid plan that can be shown ads. Your answer decides whether Google’s SDK can read the advertising identifier. If you tap “Ask App Not to Track”, ads are still shown, without that identifier. You can change the answer at any time in Settings > Privacy & Security > Tracking.
• Elsewhere. Outside those regions ads are served under Google’s terms and local law. You can manage personalised ads in your Google account at adssettings.google.com.
• Laws that count ads as a “sale” or “sharing”. Some laws, for example in California and other US states, treat passing identifiers and ad interactions to an advertising network as a “sale” or “sharing” of personal data for advertising. Ads in Clarity are shown by Google AdMob, so this can apply to an account without a paid plan. To avoid it, choose a paid plan, which removes ads. If you decline the app’s “Allow tracking” prompt, it stops Google’s SDK from reading the advertising identifier; other technical data described above is still processed while ads are shown. To make a request under such a law, write to support@myclaritylab.app.
• Children. Clarity and its ads are not directed at children (section 11).

6 Purchases

Subscriptions and diamond packs are bought through the App Store. Apple processes the payment; we never receive your card details. The app sends Apple’s signed transaction to our server, which checks it with Apple’s certificates, and Apple notifies our server about renewals, cancellations and revoked purchases. Your account ID, which the app attaches to every purchase (Apple’s appAccountToken), links the purchase to your account. You manage or cancel a subscription in your Apple ID settings.

7 Who receives your data

We share personal data only as described in this policy, and we do not sell it for money (for advertising see section 5). Providers that act on our behalf (Supabase, OpenAI, Fish Audio, Vercel, Resend, ImprovMX) process it under data-processing terms that require them to protect it; Google and Apple act under their own privacy policies.

We also disclose personal data to authorities or courts when the law requires it, and to professional advisers under a duty of confidentiality when needed to protect our rights.

8 Transfers to other countries

Our servers are in Australia, and our providers process data in the United States and other countries, so your data leaves your country, including the EEA, the UK and Switzerland. Where the GDPR or the UK GDPR requires a safeguard for such a transfer, we rely on an adequacy decision or data privacy framework certification of the recipient, or on the standard contractual clauses of the European Commission (with the UK addendum for UK data) contained in the providers’ data-processing terms. You can ask us for information about the safeguards at the address in section 14.

9 How long we keep data, and deleting your account

Your account data is kept while your account exists. That includes the waiting period after you ask to delete the account, up to the erasure date described below. We do not delete older records automatically at present, so learning history stays until the account is erased; the one exception is the day-by-day study time, of which our servers keep up to 400 days (section 2). Data that exists only on your device is erased from it at once when you ask to delete your account in the app on that device (see below); otherwise it stays until you remove the app.

Delete your account in the app

Open Profile > Settings > Manage account > Delete account. The app offers a short optional survey, tells you, before you confirm, that your data is erased 15 days after your request (with or without a subscription; deleting the account does not cancel an App Store subscription) and asks you to type a confirmation word. This needs an internet connection: if the request does not reach our servers, the app tells you and changes nothing. When it does, your account is scheduled for deletion; it is not erased on our servers yet. The app shows you the date and signs you out, and it erases at once the copies that exist only on this device (tests and courses with their photos, videos, audio and covers, the audio files of your own dictionaries, Talk conversations and key, offline lessons, the list of sentences you got wrong). Restoring the account does not bring these copies back.

When your data is erased

On the erasure date we erase your profile, settings, progress, your friend requests, friendships and blocks (so you disappear from other people’s friend lists), feed events, your study time, your rooms of earlier versions and any joint Memory sessions, dictionaries and files uploaded by earlier versions of the app, support tickets, AI practice and Talk usage records, and your sign-in record. The erasure date is 15 days after your request, whatever your subscription.

The wait is the same for everybody: 15 days. A subscription, a free trial, a renewal, a refund and a plan that we granted you do not shorten it or lengthen it, and asking to delete the account a second time does not move the date.

The app names the wait (15 days) before you confirm, and shows you the date after you confirm and on the restore screen. The erasure runs automatically shortly after the date, and if a step fails it is repeated until it succeeds.

Deleting your account does not cancel an App Store subscription, and we cannot cancel it for you. Apple keeps billing you until you cancel it in your Apple ID settings, also after your data has been erased; while a subscription period is running, the app says so and has a button that opens them. Your data is erased 15 days after your request whether or not you cancel.

Until the erasure date you can restore the account in the current version of the app: sign in again with the same Apple, Google or e-mail login (do not create a new account) and tap “Restore my account”. Your account and your data on our servers are then as they were before your request; only the copies that existed on your device alone are gone. The erasure starts shortly after the erasure date, and once it has started the account cannot be restored.

Reset instead of restoring

While the deletion is pending, the screen that offers “Restore my account” also offers “Reset”. A reset erases at once what is erased on the erasure date (the list above, including your friend requests, friendships, blocks, feed events and your study time, so you disappear from other people’s friend lists), except that your sign-in (your login and e-mail address), a paid plan that is running and your support tickets stay, and that files uploaded by earlier versions of the app are not removed by a reset: they stay until the account is erased. It cancels the deletion request, and the account comes back empty: you go through the first set-up again, and the account gets a new account number and a new friend code, so the old friend code stops working. A date of birth that an earlier version of the app stored with your profile (section 11), if there is one, is not erased by a reset: it is carried over to the new profile. The blocks you placed are erased, and so are the blocks other people placed against your account: a person who had blocked you no longer has that block. A reset cannot be undone.

A reset is possible once in 7 days. To enforce this we keep the time of your last reset, linked to your sign-in record, until your account is erased. Our basis is our legitimate interest in preventing abuse of the limits that start again with an empty account (Art. 6(1)(f) GDPR).

While the deletion is pending, your data stays on our servers until the erasure date and the account is hidden from other users (section 3). We keep the data to carry out your request and to let you restore the account. If an App Store subscription is running, the notices that Apple sends our server about it (renewals, refunds, expiry) are still recorded until the erasure, so that the plan is right if you restore the account; they do not change the erasure date. Our basis is our legitimate interest in carrying out your request correctly and in letting you undo an accidental deletion (Art. 6(1)(f) GDPR) and, while a subscription runs, the contract for it (Art. 6(1)(b)).

If anything about the date is unclear, write to support@myclaritylab.app from the address linked to your account.

What remains after deletion

• Subscription continuity record. If a paid plan is still running on the erasure date (a paid App Store period that has not ended yet, whether or not you switched off its renewal, or a plan that we granted you), we keep your e-mail address (in lower case), your former account ID, the plan, its status, transaction numbers and expiry dates, so that the running plan can be restored if you register again with the same e-mail address. If no plan is running on that date, we write no such record. Records written by deletions made before the waiting period existed follow the same rule. While the plan is still running, the record is kept so that the plan can be restored. We erase the record automatically 30 days after it can no longer be used: 30 days after the plan has ended (or after the record was written, if that is later), or 30 days after the record was used to restore the plan. The clean-up runs regularly, so the erasure follows shortly after that day. A record that carries no usable end date for its plan (for example, a plan from before expiry dates were recorded) is kept until it is used to restore the plan (and then for 30 days, as above) or you ask us to erase it. You can also ask us to erase it earlier; a paid plan will then not be restored automatically. Our basis is our legitimate interest in honouring what you paid for (while the plan is running) and in defending legal claims (during those 30 days).
• Log of Apple notifications. Notifications from Apple about purchases are kept for accounting, fraud prevention and disputes. The link to your account is removed, but an entry still contains the purchase token (your former account ID), transaction numbers, price, currency and storefront country.
• AI practice event records. Records of how exercises went (event type, language pair, level, score, duration) remain without a link to your account.
• Deletion survey. Your answers remain without a link to your account. If you write personal data in the comment, it remains too.
• Shared content. Exercises generated by AI and the audio of single words are shared with all learners and contain no account data.
• Copies on other people’s phones. A test that you shared in an earlier version and that someone accepted is a copy on that person’s own phone, and so is a dictionary of yours that they saved there for offline use. Deleting your account does not erase them; they are outside our reach.
• E-mails to support. E-mails you sent to our support address are not linked to your account: they stay in our administration tool (the link to your ticket is removed) until we delete them, and so do copies of e-mails we sent to an address that is not linked to an account. Ask us if you want them erased.
• Staff action logs. Logs of actions by our staff, for example granting a plan, can contain an account ID.
• Backups and provider logs. Our providers keep backups and technical logs for periods they set, and these age out on their own schedule.
• Other companies. OpenAI, Google, Apple, Fish Audio, Resend and ImprovMX keep data under their own policies; we do not ask them to delete it. Deleting your Clarity account does not yet revoke the Sign in with Apple connection automatically: Clarity stays in your list of apps that use Sign in with Apple until you remove it in your Apple ID settings (for Google: in your Google account).

If your request does not reach our servers (for example the connection drops), the app tells you, the account is not scheduled for deletion and nothing is erased on your device. Try again later, or write to support@myclaritylab.app if you want anything above removed. If the app shows an error but the request did reach us (for example the answer was lost), the account is scheduled all the same: sign in again to check, and you will see the restore screen with the date.

10 Your rights

Under the GDPR and the UK GDPR you have the right to:

• get confirmation of whether we process your personal data, and a copy of it (access);
• have inaccurate data corrected and incomplete data completed (rectification);
• have your data erased (erasure);
• restrict processing in the cases the law provides;
• receive the data you gave us in a structured, commonly used form and have it transmitted (portability);
• object to processing based on our legitimate interests;
• withdraw consent at any time, without affecting what was done before. Practice with AI: Profile > Settings > AI processing consent. Talk: Talk settings > AI processing. Ads: the “Ad privacy options” entry in Profile > Settings, and iOS permissions in the system Settings;
• complain to a supervisory authority, for example in the country where you live or work, or the UK Information Commissioner’s Office or the Swiss Federal Data Protection and Information Commissioner.

How to use them. Delete your account in the app; section 9 explains the waiting period before your data is erased. Data that is stored only on your device (including the audio files of your dictionaries and the photos, videos and audio of your tests and courses) is not visible to us, so we cannot export or delete it; backups, if you make them, are kept in iCloud or on your computer and are not accessible to us. You manage this data in the app, and it is erased from a device when you ask to delete your account in the app on that device or remove the app, and the files of a dictionary, test or course are also erased when you delete that dictionary, test or course on that device. For everything else, write to support@myclaritylab.app from the address linked to your account, so we can check it is you. We answer within one month; the law allows an extension for complex requests, and we will tell you if that applies. We handle requests from users in any country in the same way. The app has no screen for changing your nickname after onboarding, so ask us if you want it changed.

11 Children and minimum age

Clarity is for people aged 13 and over. It is not directed at children and we do not knowingly collect data from children under 13. We do not ask for your date of birth, so we cannot check age ourselves, and you must be at least 13 to create an account. When you sign up with an e-mail address, you tick a box saying that you are at least 13 and accept the Terms of Use and this Privacy Policy; the box is your own statement, which we cannot check. The current version of the app does not ask for a date of birth; a profile created by an earlier version may still hold one, and other users do not receive it. In some countries the age at which you can consent to the processing of your data is higher than 13 (up to 16 in some EU member states); there, if you are below that age, you may use Clarity only with the permission of a parent or guardian.

If you are a parent and think a child under 13 has an account, write to support@myclaritylab.app and we will delete it.

12 Security

We protect data with measures that fit the risk, for example encrypted connections (HTTPS) between the app and our servers, access rules in the database that let an account reach only its own data and what other users have made available to it, storage of your sign-in session and your own OpenAI key in the iOS Keychain, storage of an e-mail login password only as a salted hash, one-time codes that are valid for a short time and work once, and a password-protected administration tool for authorised people only. No system is completely secure. If a breach affects your rights, we will inform the authorities and you as the law requires.

13 Changes to this policy

When we change this policy we publish the new text on this page with a new version number and date. If a change needs your consent, or the law requires us to tell you, we will ask or tell you in the app or by another suitable way before it applies to you.

14 Contact

Ilnar Sirazetdinov – support@myclaritylab.app. You can also open a ticket (Profile > Help & support > Write to us) or send a complaint (Profile > Help & support > Complaints & suggestions) from the app.

A ticket opened in the app gets a request number, and an automatic message in the conversation confirms that we received it. If you write to support@myclaritylab.app, the e-mail is received through Resend and kept in our administration tool; section 2 (“Support and feedback”) says what is kept and for how long.