Privacy policy
Last updated:
This document is also available in Finnish. Both versions have the same content. If they conflict, the Finnish version prevails.
1. Who is responsible
The controller of your personal data is AKK Capital Oy (Y-tunnus 3631240-1), Ilotulitustie 15, 00930 Helsinki, Finland ("we"), operating . Contact: .
2. What we collect and why
| Data | Purpose | Legal basis (GDPR art. 6) | Kept for |
|---|---|---|---|
| Email address | Sign-in links, your account, receipts and important service messages | Contract (6(1)(b)) | Until you delete your account |
| Your written answers, speech transcripts and the feedback | Giving you feedback and showing your history | Contract (6(1)(b)) | 12 months, then deleted automatically, or earlier if you delete them |
| Drafts you write or record before signing in | Keeping your answer while you sign in, so it can be sent for feedback | Contract (6(1)(b)), at your request | Only in your own browser (local storage). Nothing is sent to us until you ask for feedback, and the draft is removed after it is checked |
| Voice recordings | Converted to text (transcription) for feedback | Contract (6(1)(b)) | Not stored. Held in memory only while your request is processed |
| Practice days and daily goal (how many tasks you finished on each day, in Finnish time; the goal you chose) | Showing your streak, daily goal and lesson path | Contract (6(1)(b)) | About 13 months, then deleted automatically, or earlier if you delete your account |
| Pass purchases (plan, dates, amount and the withdrawal-right confirmation you gave at checkout) | Unlocking your pass; bookkeeping | Contract; legal obligation (6(1)(c)) | As required by Finnish accounting law |
| Sign-in session (one strictly necessary cookie) | Keeping you signed in | Contract / strictly necessary | 30 days |
| Aggregate page-view counts | Understanding which pages are used | Legitimate interest (6(1)(f)) | No personal data: only page path, date and referring website |
We do not use tracking or advertising cookies, we do not sell data, and we do not use your answers to train AI models.
3. Automated feedback (AI)
Feedback and level estimates are generated automatically by AI language models. They are practice estimates only. They have no legal or official effect and are not a YKI result. You can ask us questions about any feedback at the contact address above.
4. Service providers (processors)
- Cloudflare, Inc. (USA): hosting, database and security. Cloudflare's network is global, so data may be processed in the United States. Transfers rely on Cloudflare's certification under the EU–US Data Privacy Framework, with the European Commission's Standard Contractual Clauses in its data processing addendum as a fallback.
- OpenAI Ireland Ltd (Ireland): AI feedback and speech transcription. We send your answer text or recording without your email address. API data is not used to train OpenAI's models, and we ask for it not to be stored (
store: false). OpenAI Ireland may pass data to its affiliate OpenAI OpCo, LLC and sub-processors in the United States. Under OpenAI's data processing addendum, such transfers rely on the Standard Contractual Clauses or an EU adequacy decision (the EU–US Data Privacy Framework). - Plus Five Five, Inc. (Resend) (USA): sending emails such as sign-in links and receipts (your email address and the email content). Transfers rely on Resend's certification under the EU–US Data Privacy Framework and the Standard Contractual Clauses in its data processing addendum.
- Stripe (Stripe Payments Europe, Limited and Stripe Technology Europe, Limited, Ireland): payments. With Stripe Managed Payments, Stripe sells your purchase to you as the merchant of record ("Sold through Link") and processes your payment data as an independent controller under Stripe's privacy policy, including any transfers outside the EEA. We never see your card details.
Where data leaves the EU/EEA, the safeguards named above apply: the EU–US Data Privacy Framework for certified US companies, and otherwise the European Commission's Standard Contractual Clauses. You can ask us for more information about these safeguards at the contact address above.
5. Your rights
You can access, download, correct and delete your data. Use Settings → Download my data or Delete my account, or email us. You can also object to processing based on legitimate interest. You have the right to lodge a complaint with the Finnish Data Protection Ombudsman (tietosuoja.fi).
6. Age
The service is intended for people aged 16 or over.
7. Changes
If we make material changes, we will update this page and notify account holders by email.