Privacy Policy

1. General Provisions

This Personal Data Processing Policy (hereinafter referred to as the "Policy") governs the collection, storage, processing, and protection of personal data within the Drills interactive application available at https://drills.imaginal.dev (hereinafter referred to as the "Service").

This Policy is drafted in compliance with Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as "152-FZ"). Respecting human rights, freedoms, and data privacy is an essential condition for the operation of the Service Administration and Developers (hereinafter referred to as the "Operator").

2. Legal Grounds for Data Processing

The legal grounds for personal data processing by the Operator include:

The User's consent granted upon registration by checking the mandatory consent checkbox (clause 1, part 1, article 6 of Federal Law No. 152-FZ);
The execution and performance of the Terms of Service to which the User is a party (clause 5, part 1, article 6 of Federal Law No. 152-FZ);
Compliance with legal obligations required by applicable laws.

3. Categories and Purposes of Personal Data Processing

The Operator processes the following categories of personal data strictly for the specified purposes:

3.1. User Name / Display Name

Purpose: User identification within the Service, displaying the user profile, and facilitating student-teacher connections.

3.2. Email Address

Purpose: Authentication, account security, password recovery, essential notifications, and communication with support.

3.3. Learning Content and Vocabulary Progress Data

Purpose: Managing individual dictionaries, tracking vocabulary mastery, managing study intervals, and powering the interactive training algorithm.

3.4. Technical Data & Cookies

Purpose: IP addresses, browser details, device type, and session cookies used to maintain security, prevent abuse, and ensure technical functionality.

4. Data Protection and Storage Standards

Security measures are implemented to protect personal data from unauthorized access, alteration, disclosure, or destruction:

All communications and data transfers are encrypted via HTTPS/TLS protocols.
User passwords are stored in hashed format using standard cryptographic algorithms.
Personal data is never sold, rented, or shared with third parties for marketing purposes.

5. Database Backups & Data Retention

5.1. Personal data is retained only for as long as necessary to fulfill the purposes of processing or until account deletion.

5.2. The Operator undertakes reasonable technical efforts to generate automated database backups and retain backup snapshots for a period of 5 (five) calendar days. Outdated backup snapshots older than 5 days are automatically overwritten or erased.

6. Rights of the Data Subject

In accordance with 152-FZ and data privacy principles, Users have the right to:

Request information regarding the processing of their personal data;
Request correction, updating, or deletion of incomplete or inaccurate data;
Withdraw consent to personal data processing or request full account deletion at any time.

7. Policy Updates and Contact

The Operator reserves the right to update this Policy when necessary. The current version is always accessible at: https://drills.imaginal.dev/privacy-policy.

For any questions, personal data inquiries, or to exercise your rights (including consent withdrawal or account deletion requests), please contact us at: bmo@imaginal.dev.

Privacy Policy & Personal Data Processing