Last Updated: Mar 11, 2025

1. Introduction
This Privacy Policy explains how Stuward LTD ("Company" or "we") collects, uses, discloses, and otherwise processes your personal data and details your rights regarding such data. We provide you with our service, toobe.ai—a platform for learning English with the assistance of an AI tutor. When you use our service or interact with us (for example, via email), you may provide us with personal data. By using our service, you agree to the terms of this Privacy Policy.

2. Data We Process
2.1. Minimal User Data
We collect only the information you voluntarily provide when registering and using our service:
- Personal Data: Your name and email address.
- Payment Data: When you make a payment, you are redirected to Stripe's secure payment system, where your credit card details are entered. We do not directly store or process these payment details.

2.2. Interaction with AI
When using our service, you interact with language models (LLMs). These interactions are used solely to provide you with educational services and may be processed to enhance service quality. Your messages are not linked to your identity unless required for service provision.

2.3. Automatically Collected Information
We may automatically collect the following information when you use our service:
- Browser and Device Data: Your IP address, browser type and version, operating system, and device settings.
- Analytics Data: Information regarding the time, duration, and manner of your usage.
This data is used to maintain security, optimize service performance, and improve your overall experience.

3. Purposes for Processing Personal Data
We use your personal data for the following purposes:
- Service Provision: Account registration and verification, providing access to our educational platform, processing payments via Stripe, and offering customer support.
- Service Improvement: Analyzing usage patterns, optimizing our platform, and detecting or preventing fraudulent activities.
- Communication: Sending notifications, registration confirmations, updates about new features, promotions, and other relevant information (with an option to opt-out).

4. Legal Basis for Processing (in Accordance with GDPR)
We process your personal data on the following legal grounds:
- Contractual Necessity: Processing is necessary to provide you with our English learning services.
- Consent: In cases where processing is based on your consent (for instance, receiving marketing emails).
- Legitimate Interests: For ensuring the security of our service, preventing fraud, and improving service quality.
- Compliance with Legal Obligations: To meet legal requirements imposed by EU, UK, and other applicable laws.

5. Disclosure of Personal Data
We do not sell or disclose your personal data to third parties except in the following circumstances:
- Legal Requirements: When required by law, court order, or to protect our or users' rights.
- Service Providers and Partners: To trusted service providers (such as web hosting, support, analytics, or payment processing via Stripe) who require access to the minimal necessary information.
- Business Transactions: In connection with mergers, asset sales, or changes in control, provided we take steps to ensure your data remains confidential.

6. International Data Transfers
Your personal data may be transferred to and processed in countries where our servers, affiliates, or service providers are located (e.g., Stripe). When transferring data outside the EU or UK, we implement appropriate safeguards as required by applicable laws.

7. Your Rights (Under GDPR and UK GDPR)
Depending on your jurisdiction, you have the following rights regarding your personal data:
- Right of Access: You can request information on what personal data we hold about you.
- Right to Rectification: You may request corrections or updates to inaccurate data.
- Right to Erasure: You can request deletion of your data, provided there is no legal obligation to retain it.
- Right to Restrict Processing: You may ask us to limit the processing of your data.
- Right to Data Portability: You have the right to receive your data in a machine-readable format for transfer to another controller.
- Right to Object: You can object to the processing of your data on legitimate grounds, including for marketing purposes.
- Withdrawal of Consent: If processing is based on your consent, you may withdraw it at any time.
To exercise these rights, please contact us at: eli@askstu.co.

8. Data Security
We implement appropriate administrative, technical, and physical measures to protect your personal data from unauthorized access, misuse, or alteration. Although no method of transmission over the internet is 100% secure, we take reasonable steps to ensure your data is safeguarded.

9. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws (e.g., tax and accounting regulations).

10. Children’s Privacy
Our service is intended for users aged 18 and older. We do not knowingly collect personal data from children under the age of 16. Should we become aware that we have collected data from a child under 16, we will take immediate steps to delete such data.

11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If significant changes are made, we will notify you via email or through an on-site notice. Continued use of our service after changes have been implemented constitutes your acceptance of the updated policy.

12. Contact Information
If you have any questions or concerns regarding this Privacy Policy or our data protection practices, please contact us at: eli@askstu.co.