1. Who is responsible for your data

The controller of your personal data is Innohand Solutions, Cairo Investment Commercial Register no. 289532, Cairo, Egypt. For any question or request about your data: support@etkalemzayohom.com (put "my personal data" in the subject so it reaches the data-protection officer). Official contact with the company: contact@innohandsolutions.com.

2. The data we collect

Account data: name, email address, password (encrypted), and your profile picture if you sign up with Google.
Learning data: the language you learn, your level, your age group, your gender (male/female), your nationality, how you heard about us, your progress, your answers and results. Gender and nationality are used to tailor the teaching — the languages we teach change the form of a word according to the speaker's gender, and the content differs by country — and are never used for advertising or shared with third parties.
Usage and device data: pages visited, video plays (lesson and time), browser type and operating system, a technical browser identifier (a hash of general characteristics that does not track you across other sites), IP address and the approximate location inferred from it (country and city), and the last use of each device.
Content you submit: your voice in conversation exercises (with your consent). Your voice is processed live during the exercise only and is not stored — neither by us nor by the service provider; we keep only the exercise's result: the level, the weak points with the sentences that showed them, and the lessons suggested.
Payment data: order number, plan, amount, payment method, receipt and refund requests. We do not store card numbers; they are processed by Paymob.
Communication: support messages and reports, and a log of the messages we sent you.
Source: the link or campaign you arrived from.
Consents: what you agreed to, when, and from which device.

3. Why we use your data, and on what basis

Creating your account, delivering lessons, saving your progress and processing your subscription — performance of our contract.
Tailoring your path to your language and level — performance of the contract.
Generating exercises and answers with AI — performance of the contract.
Pronunciation exercises using the microphone — your consent (withdrawable at any time).
Protecting content and preventing account sharing and fraud: the device limit, the watermark, playback limits, recording devices and addresses — our legitimate interest in protecting the Service.
Securing our systems, detecting intrusions and proving consents — legitimate interest / legal obligation.
Service messages (welcome, receipts, subscription expiry, replies to your reports) — performance of the contract.
Marketing emails — your consent (withdrawable from your profile or the unsubscribe link).
Usage analysis to improve lessons (analytics cookies) — your consent via the cookie banner.
Keeping payment records and invoices — legal obligation (tax and accounting).
Responding to requests from public authorities — legal obligation.

4. Who we share your data with

We do not sell your data. We share it only with service providers working for us and on our instructions: Supabase (database and authentication), Vercel (hosting and approximate location), Bunny.net (video delivery; sees your IP address), Paymob (payments), Resend (email delivery), ElevenLabs (live voice processing in conversation exercises, with no recordings kept), OpenRouter and the model providers it routes to, and Google (AI and search), Google Analytics (if you accept analytics cookies), Meta Platforms — the Meta Pixel, which measures our Facebook and Instagram ads — and TikTok — the TikTok Pixel, which measures our TikTok ads (both only if you accept marketing cookies). We may also disclose data where required by law or a court order, or to protect our rights or users' safety.

5. Transfers outside Egypt and the European Union

Our service providers operate on servers outside Egypt (in the European Union and the United States). By creating an account you consent to the transfer and processing of your data by these providers to the extent needed to provide the Service; you can view and manage this consent on your profile page. For EU residents, transfers outside the European Economic Area are made under the European Commission's standard contractual clauses or adequacy decisions.

6. How long we keep your data

We keep your data as long as it is needed for the purposes described, then delete or anonymise it:

Account and learning data: for the life of the account, deleted within 30 days of a deletion request.
Device and video-play logs: 12 months.
Payment records and invoices: the period required by tax and accounting law.
Consents and sign-in log: for the life of the account and up to 3 years after it, as evidence.
Support messages: 2 years.
An account inactive for more than 3 years is deleted after notice to you.

7. Your rights

You have the right to: access your data and obtain a copy; correct it; delete it (delete the account from the account settings or by contacting us); restrict or object to its processing, especially for marketing; port it to another provider in a machine-readable format; and withdraw your consent at any time without affecting what was done before withdrawal. Write to support@etkalemzayohom.com; we reply within 30 days and may ask you to verify your identity. You also have the right to complain to the supervisory authority: in Egypt the Personal Data Protection Centre, and in the European Union the data-protection authority of your country of residence — we ask you to contact us first.

8. Children

The Service is for people aged 18 and over only. We do not ask children for data, do not knowingly collect it, and do not direct the Service at them. Onboarding asks for your age group, and the youngest band offered is 18–24. If we learn that an account belongs to someone under 18 we close it and delete their data within 30 days. If you are a parent or guardian and believe your child has created an account, write to support@etkalemzayohom.com.

9. Cookies and similar technologies

We use three categories of cookies. Necessary (no consent needed): sign-in and session refresh, language preference, the device identifier for the device limit, and remembering your choice in the cookie banner — lasting up to one year. Analytics (with your consent, off by default): Google Analytics (_ga, _gid) to understand how the site is used, lasting up to two years. Marketing (with your consent, off by default): the Meta Pixel (_fbp, _fbc) and the TikTok Pixel (_ttp, ttcsid, ttclid), which tell Meta and TikTok when someone who saw or clicked our ad on Facebook, Instagram or TikTok visits the platform, signs up or pays, so we can measure our ads and show them to the right people — Meta's cookies last up to 90 days, TikTok's up to 13 months. We never share your name, email or phone number with Meta or TikTok. You can change your choice at any time from "Cookie preferences" at the bottom of the page or in your browser settings; disabling necessary cookies prevents signing in.

10. Security

We protect your data with appropriate technical and organisational measures: encryption in transit, encrypted passwords, restricted access rights, signed and time-limited video links, and an audit log of support-team actions. Absolute security on the internet cannot be guaranteed; if a breach affecting your data occurs, we notify the supervisory authority and you within 72 hours of becoming aware of it, as the law requires.

11. YouTube

We use YouTube API Services, through an internal tool, to publish Etkalem Zayohom videos on our official YouTube channel. The tool accesses our own channel only: it does not access your YouTube account or any data from it, and we do not collect, store or share any data about you through it. Your use of YouTube is governed by the YouTube Terms of Service (https://www.youtube.com/t/terms) and the Google Privacy Policy (http://www.google.com/policies/privacy). If you have ever granted an application access to your Google account, you can revoke that access in your Google security settings: https://security.google.com/settings/security/permissions. For any privacy question, write to us at support@etkalemzayohom.com.

12. Sources of the driving-licence content

The practice questions for the Italian driving-licence theory exam reproduce, word for word, the official list of exam questions published by the Italian Ministry of Infrastructure and Transport (Ministero delle Infrastrutture e dei Trasporti) on the Portale dell'Automobilista; the content of the Ministry's website is available under a Creative Commons Attribution licence (CC BY 3.0). The explanations and translations are our own and do not represent the Ministry.

The drawings of Italian road signs are made from the official figures in the implementing regulation of the Italian Highway Code (D.P.R. 16 dicembre 1992, n. 495). They are not the official version, which is the one published in the Italian Official Gazette. Credit: «Segnali stradali italiani: disegni basati sulle figure del D.P.R. 16 dicembre 1992, n. 495, Allegati, Titolo II (fonte: Normattiva / Gazzetta Ufficiale – testo non ufficiale, riproduzione gratuita).»

The drawings of Spanish road signs are based on the official figures in Annex I of Royal Decree 465/2025 (Real Decreto 465/2025, Anexo I), published by Spain's State Agency for the Official Gazette, redrawn without dimensions or labels. They are not the official version. Credit: «Señales de circulación de España: basado en datos de la Agencia Estatal Boletín Oficial del Estado (https://www.boe.es). Figuras del Real Decreto 465/2025, Anexo I; redibujadas sin cotas ni rótulos.»

The images of British road signs are the official images the UK Department for Transport publishes for reproduction, unchanged except for a transparent background and scaling; the text quoted from The Highway Code and GOV.UK is available under the Open Government Licence v3.0. Credit: «Traffic sign images: © Crown copyright, Department for Transport (https://www.gov.uk/guidance/traffic-sign-images). Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).»

13. Changes to this policy

We may update this policy. For a material change we notify you by email or within the platform before it takes effect, and ask for your agreement again where required. The effective date and version number are at the top of the page.