When you access our Website, we may collect information such as your device language settings, IP address, time zone, type, and model of a device for operational purposes only. Therefore, it depends on your activities on the site.

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6), and who will be the data controller (Section 1). If any questions will remain unanswered, please contact us at;


    This Privacy Policy explains what data is collected when you use this Website and the services and products provided through it, how such personal data will be used, shared.

    BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTOOD AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) leave the Website and not access or use it.

    “GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

    “EEA” includes all current member states to the European Union and the European Economic Area.

    “Process”, in respect of personal data, includes to collect, store, and disclosing to others.

  2. PERSONAL DATA CONTROLLER GM APPDEV LIMITED, a company registered under the laws of the Republic of Cyprus, having its registered office at Nafpliou, 15, Limassol, Cyprus, 3025, will be the controller of your personal data. 2. CATEGORIES OF PERSONAL DATA WE COLLECT We collect data you give us voluntarily (for example, email address, name, approximate age, level of language knowledge, learning goals, interests, time zone). We also collect data automatically (for example, your IP address). 2.1. Data we collect automatically: 2.1.1. Data about how you found us We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad). 2.1.2. Device and Location data. We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device 2.1.3. Usage data We record how you interact with our Service. For example, we log what pages you have viewed, how often you access the Website, how long you are at the Website. 2.1.4. 

    We process your personal data: 3.1. To provide our Product which includes enabling you to use the Service in a seamless manner and preventing or addressing Product errors or technical issues. As a result of such processing, we will use your email, for example, to send you the purchased product or to render services ordered through our Website. To enable the purchase and to process your payments we use Stripe, PayPal, and other payment processing providers. 3.2. To provide you with customer support We process your data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you emails about, for example, the performance of our Service, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy. 3.3. To communicate with you regarding your use of our Service We communicate with you, for example, by emails. These may include emails with information about the Service.

    We use Google’s Privacy policy to research and analyze your use of the Product. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Website and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what products and sections of the Website our users like more, and what categories of users use our Website. As a consequence, we often decide how to improve the Website based on the results obtained from this processing. We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people visit our Website, how often users make purchases, and other interactions. Learn more about Facebook’s approach to data from its Privacy Policy. We may track and analyze behaviour of our web users (in particular, how they react to changes in structure, text, or any other component). To send you marketing communications we process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new products available on the Website.

    We may show you advertisements on our Website, and send you emails for marketing purposes. To opt out of receiving marketing emails from us, you need to unsubscribe by following the instructions in the footer of the marketing emails. To personalize our ads We and our partners, including Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have accessed our Website, you might see ads of our products, for example, in your Facebook feed. How to opt out or influence personalized advertising - iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section. - Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). - macOS: On your MacBook, you can enable Limit Ad Tracking by choosing Apple menu > System Preferences > Security & Privacy, clicking Privacy, and selecting the Limit Ad Tracking checkbox. - Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity.

    If you have other Windows version, please follow the steps here To learn even more about how to affect advertising choices on various devices, please look at the information available here. In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

    Network Advertising Initiative

    Digital Advertising Alliance

    Digital Advertising Alliance (Canada)

    Digital Advertising Alliance (EU)

    DAA AppChoices page

    It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser. - Cookie settings in Internet ExplorerCookie settings in FirefoxCookie settings in Chrome - Cookie settings in Safari web and iOSGoogle allows its users to opt out of Google’s personalized adsand to prevent their data from being used by Google Analytics.

    . We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences. We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Website (for example, added some products to cart). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.

    Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please gohereor adjust your ads settings on Facebook. Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our Website (for example, show our ads to users who have purchased a product on the Website). Some other examples of events that may be used for tailoring ads include, in particular, accessing our Website, adding some products to cart. Google allows its users to opt out of Google’s personalized adsand to prevent their data from being used by Google Analytics. To enforce ourTerms and Conditions of Useand to prevent and combat fraud We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of UseTo comply with legal obligations We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.


    In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users. We process your personal data under the following legal bases: - your consent; - to perform our contract with you; Under this legal basis we: - Provide our Service (in accordance with our Terms and Conditions of Use- Customize your experience - Provide you with customer support - Communicate with you regarding your use of our Service Process your payments for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data; We rely on legitimate interests: to communicate with you regarding your use of our Service This includes, for example, sending you email to notify you that we have released a new product or sending push notification reminding you that you have some products in your cart. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. to research and analyze your use of the Service Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the Website navigation easier and more user-friendly). to send you marketing communications The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way. to personalize our ads The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way. to process your payments We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for a certain product and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors. to enforce our Terms and Conditions of Use and to prevent and combat fraud Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Service, non-compliance with our Terms and Conditions of Use to comply with legal obligations.


    We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular: Service providers We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers: - cloud storage providers (Amazon) - payment service providers (Stripe, Solid) - data analytics providers (Facebook, Firebase, Amplitude) - message sending and notifications service providers (Firebase) - marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google) Law enforcement agencies and other public authorities We may use and disclose personal data to enforce our Terms and Conditions of Use to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law. Third parties as part of a merger or acquisition as we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g., parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.


    To be in control of your personal data, you have the following rights: Accessing / reviewing/updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website by sending us an email at You may also request a copy of your personal data collected and deleting your personal data. You can request the erasure of your personal data by sending us an When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations. Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at [Additional information for EEA-based users]: [If you are based in the EEA, you have the following rights in addition to the above: The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place. The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective requests at

    AGE LIMITATION We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at INTERNATIONAL DATA TRANSFERS We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards. In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission, or (ii) the EU-U.S. Privacy Shield Framework, or (iii) the European Commission adequacy decisions about certain countries.


    We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Product after those changes become effective, you agree to be bound by the revised Privacy Policy.

    information under the statute. To obtain this information from us, please send an email message to which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

    DATA RETENTION We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. HOW “DO NOT TRACK” REQUESTS ARE HANDLED Except as otherwise stipulated in this Privacy Policy, this Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

    CONTACT US You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at

    Effective as of 1st November 2022