PRIVACY POLICY
Effective Date: May 26, 2026
Last Revised: May 26, 2026
1. GENERAL PROVISIONS
1.1.This Privacy Policy ("Privacy Policy") governs the processing and protection of personal data collected through the mobile application, web application, websites, and associated interactive language learning services (collectively, the "Service" or "Application") operated by “GOVORI” Limited Liability Company (abbreviated as "GOVORI LLC"), a legal entity incorporated under the laws of the Republic of Armenia, Registration No. 999.110.1600412, TIN: 02953329, having its legal address at: Saryan str., 31 bld., 18 apt., Kentron district, Yerevan, 0002, Republic of Armenia (hereinafter referred to as "GOVORI", "Company", "we", "us", or "our").
1.2.GOVORI acts as the Data Controller with respect to the personal data collected directly from individual users, and, where applicable, acts as a Data Processor or Joint Controller when processing user data under corporate agreements with enterprise clients ("Corporate Clients" or "Employer Organizations").
1.3.By creating an account, registering via third-party authentication providers, accessing, downloading, or otherwise using the Service, you ("User", "you", or "your") acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you must immediately discontinue using the Service.
1.4.The Service provides an interactive educational platform designed to help working professionals and corporate teams master vocabulary, workplace terminology, industry-specific expressions, and conversational phrases tailored for professional and business communication.
2. INFORMATION WE COLLECT
We collect personal data directly from you, automatically through your interaction with the Service, and from authorized third parties (such as single sign-on providers and your employer).
2.1.Account Registration and Authentication Data
- Direct Registration: When creating an account directly, you must provide your valid email address (which serves as your login identifier) and create a secure password.
- Single Sign-On (SSO) Services: You may choose to register or log into the Application using third-party authentication services, specifically Google Sign-In (Google LLC / Google Ireland Limited) or Sign in with Apple (Apple Inc. / Apple Distribution International Ltd.). When using SSO, we receive your authentication token, your registered email address, and your name as authorized by your settings with the respective authentication provider.
2.2.User Profile and Professional Data
- Full Name / Display Name: The name you provide during onboarding or in your account profile.
- Profession / Job Title: Your professional specialization, industry, or occupational role, which is collected to customize the educational curriculum and recommend relevant industry-specific vocabulary modules.
- Avatar / Profile Image: You may upload an image or select a pre-designed illustration/avatar within the Application. Uploading an actual photographic image of your face is entirely optional; you may use a non-photographic graphical avatar, initials, or default illustration.
2.3.Corporate Access and Enterprise Identifiers
- Company Code: If access to the Service is provided or sponsored by your employer or an enterprise client, you may enter a unique corporate activation code ("Company Code"). This code links your account to the respective corporate subscription license, configures role-specific curriculum modules, and may enable administrative dashboard tracking by the sponsoring organization.
2.4.Learning Activity and Educational Progress Data
- Learning Metrics: Information regarding words and phrases studied, completed interactive lessons, exercise results, error statistics, repetition intervals, quiz scores, pronunciation and speaking metrics, streak counts, time spent learning, and curriculum completion rates.
- Interactive Content: Notes, user inputs, flashcard interactions, and responses submitted during interactive educational sessions.
2.5.Technical, Device, and Usage Information
- Device Identifiers: IP address, device type, operating system version, browser type, unique device identifiers (e.g., IDFA, Android Advertising ID), app version, and language settings.
- Log and Diagnostic Data: Crash logs, performance metrics, access timestamps, feature usage frequency, and navigational routes within the Application.
- Cookies and Local Storage: We utilize session identifiers and local storage tokens to maintain user authentication, remember preferences, and ensure seamless app performance.
2.6.Payment and Subscription Information
- Individual Purchases: When you purchase a direct subscription plan, payment transactions are processed directly by authorized third-party payment processors or in-app purchase systems (such as Apple App Store or Google Play Store). GOVORI does not collect, store, or process your full credit/debit card numbers or bank account credentials. We receive only transaction confirmation metadata (e.g., transaction ID, subscription tier, duration, payment status, and timestamp).
- Corporate-Funded Access: If your access is activated via a corporate license/Company Code, payment is handled separately between GOVORI and your employer under a B2B service agreement; no payment information is collected from you personally.
3. LEGAL BASES FOR DATA PROCESSING
GOVORI processes your personal data only when a valid legal basis exists under applicable data protection laws (including the GDPR and the Law of the Republic of Armenia "On Personal Data Protection"):
- Performance of Contract (Art. 6(1)(b) GDPR): To deliver the Service, manage your user account, execute educational algorithms, provide customer support, and administer subscription terms.
- Legitimate Interests (Art. 6(1)(f) GDPR): To improve curriculum algorithms, analyze user retention, prevent fraudulent use, safeguard system security, and provide corporate progress reporting to authorized enterprise clients.
- Compliance with Legal Obligations (Art. 6(1)(c) GDPR): To fulfill tax, accounting, statutory recordkeeping, and regulatory obligations.
- Consent (Art. 6(1)(a) GDPR): Where required for optional marketing communications, specific data synchronization features, or optional microphone access for interactive speech exercises.
4. PURPOSES OF DATA PROCESSING
We process collected personal data for the following specific purposes:
4.1.Creating, managing, and authenticating your personal user account.
4.2.Delivering personalized, interactive learning paths tailored to your profession, industry requirements, and vocabulary mastery level.
4.3.Validating and activating subscription plans (whether purchased individually or via a corporate Company Code).
4.4.Generating learning analytics, progress tracking, and personalized review reminders to reinforce vocabulary retention.
4.5.Providing aggregate or employee-specific training progress reports to Corporate Clients who have funded the respective user accounts.
4.6.Ensuring technical stability, diagnosing software malfunctions, optimizing user interface performance, and safeguarding against unauthorized access or fraud.
4.7.Sending critical administrative notifications, including security alerts, technical service updates, and transactional receipts.
5. SUBSCRIPTION TIERS AND PAYMENT MODELS
5.1.The Application offers varied tariff plans and subscription tiers differentiated primarily by the duration of access (e.g., monthly, quarterly, semi-annual, annual, or custom corporate duration plans).
5.2.Direct User Purchases: If you purchase a subscription on an individual basis, billing occurs through the applicable App Store platform or integrated payment gateway. Subscriptions may renew automatically unless canceled prior to the expiration of the current billing cycle in accordance with the store terms.
5.3.Corporate Sponsorship / Code Redemption: If you access the Service via an enterprise arrangement, your employer purchases the license rights directly from GOVORI LLC. Upon inputting the valid Company Code assigned to your organization, full access to the designated educational tier is granted for the contracted term without personal monetary charge to the User.
6. DATA SHARING AND THIRD-PARTY DISCLOSURES
GOVORI does not sell your personal data to data brokers or third-party advertisers. We disclose personal data only under strict confidentiality and security protocols in the following instances:
6.1.Corporate Employers / Enterprise Clients: If you access the Service using a Company Code provided by your employer, we may share your name, professional role, account email, and detailed learning statistics (e.g., completion rate, hours spent, assessment scores, vocabulary mastered) with your employer’s designated corporate administrators to verify corporate training compliance.
6.2.Service Providers and Sub-processors: We share data with vetted third-party vendors who provide infrastructural, analytical, and operational support under binding data processing agreements:
- Cloud Hosting and Infrastructure Providers (e.g., server hosting and database management services);
- Authentication Providers (Google LLC, Apple Inc.);
- Crash Analytics and Performance Monitoring Providers;
- Customer Support and Ticketing Platforms;
- Authorized Payment Gateways and In-App Billing Platforms.
6.3.Legal and Regulatory Disclosures: We may disclose personal data if required to do so by applicable statutory law, lawful judicial process, subpoena, or competent governmental authority, or where necessary to protect the vital interests, safety, and legal rights of GOVORI LLC, our users, or third parties.
6.4.Corporate Restructuring: In the event of a merger, acquisition, corporate reorganization, asset sale, or bankruptcy, user data may be transferred to the acquiring entity subject to the commitments set forth in this Privacy Policy.
7. DATA RETENTION AND ACCOUNT DELETION
7.1.General Retention: We retain your personal data for as long as your account remains active and as necessary to fulfill the educational purposes for which it was collected, or until you request account deletion.
7.2.Permanent Account Deletion (Self-Service & Manual):
- Self-Service Deletion: You have the right to delete your account permanently at any time directly through the Application interface (navigating to: Account Settings -> Security / Privacy -> Delete Account).
- Manual Deletion Request: You may also request permanent erasure by sending an email from your registered email address to: anushharutunyan@mail.ru.
7.3.Consequences of Account Deletion: Upon initiating permanent account deletion:
- Your user profile, login credentials, professional data, avatar, and individual learning history will be permanently deleted or irrecoverably anonymized from our production databases.
- Your active subscription access will be immediately terminated.
- Residual backup copies will be purged in accordance with standard automated backup rotation schedules (not exceeding thirty (30) days), except where longer retention is strictly required by statutory accounting, tax, or legal defense obligations.
8. DATA SUBJECT RIGHTS
Depending on your jurisdiction and applicable data protection legislation (including the EU GDPR), you possess the following rights regarding your personal data:
8.1.Right of Access: You have the right to obtain confirmation as to whether your personal data is being processed and to receive a copy of such data.
8.2.Right to Rectification: You may correct inaccurate or incomplete personal data via your in-app profile settings or by contacting us.
8.3.Right to Erasure ("Right to be Forgotten"): You may request the permanent deletion of your personal data as set forth in Section 7.
8.4.Right to Restriction of Processing: You may request the temporary suspension of data processing under certain legally defined circumstances.
8.5.Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
8.6.Right to Object: You may object at any time to the processing of your data based on legitimate interests or direct marketing.
8.7.Right to Withdraw Consent: If processing is based on your consent, you may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.
8.8.Right to Lodge a Complaint: You have the right to lodge a formal complaint with a competent supervisory authority for data protection in your country of residence or the Personal Data Protection Agency of the Republic of Armenia.
To exercise any of these rights, please submit a written request to: anushharutunyan@mail.ru.
9. DATA SECURITY
GOVORI implements industry-standard administrative, organizational, and technical safeguards designed to protect personal data against accidental loss, unauthorized access, alteration, disclosure, or destruction. Security measures include Transport Layer Security (TLS/HTTPS) encryption for all transmitted data, salted password hashing, restricted role-based database access, and continuous system monitoring.
10. CHILDREN’S PRIVACY
The Service is designed exclusively for adult professionals and workplace corporate learners. We do not knowingly solicit or collect personal information from individuals under the age of 16 (or under the digital age of consent in the applicable jurisdiction). If we discover that personal data of a minor has been collected without verified parental consent, we will promptly delete such data from our servers.
11. INTERNATIONAL DATA TRANSFERS
GOVORI LLC operates from the Republic of Armenia and may utilize cloud hosting infrastructure and service providers located globally. Where personal data is transferred internationally outside of the European Economic Area (EEA), we ensure that appropriate safeguards (such as Standard Contractual Clauses approved by the European Commission or equivalent statutory mechanisms) are implemented to guarantee an adequate level of data protection.
12. CHANGES TO THIS PRIVACY POLICY
We may periodically revise and update this Privacy Policy to reflect changes in our legal obligations, Service functionality, or data processing practices. When updates are published, the "Last Revised" date at the top of this document will be updated. In the event of material changes, we will notify you through an in-app banner, pop-up notification, or via an email sent to your registered address prior to the changes taking effect.
13. CONTACT INFORMATION AND DATA CONTROLLER DETAILS
If you have any questions, comments, or data privacy requests regarding this Privacy Policy or our data handling practices, please contact us using the details below:
Data Controller:
“GOVORI” Limited Liability Company (GOVORI LLC)
Registration Number: 999.110.1600412
Taxpayer Identification Number (TIN): 02953329
Director: Harutyunyan Anush (Ashot)
Legal Address:
Saryan str., 31 bld., 18 apt.,
Kentron district, Yerevan, 0002,
Republic of Armenia