Privacy Policy
Last updated: December 12, 2025
1. Introduction
Welcome to Pavel’s Dog ("App"), operated by Pavel Koryagin pr Beograd, a sole proprietorship registered in Serbia at the address: Bulevar Mihajla Pupina 10a, sprat 4, stan 12, 11252 Beograd (Novi Beograd), Serbia.
This Privacy Policy explains how we collect, use, disclose, and protect your personal information. By using the App, you consent to the data practices described in this policy.
2. Information We Collect
2.1 Personal Information: We collect personal information you provide when creating an account or using the App, including:
- First Name, Last Name
- Date of Birth
- Email Address
- Avatar
- Country of residence
- Social Network IDs (when used for authentication)
2.2 User Content and Usage Data: We collect data related to your use of the App, including:
- User Content: Texts, photos, documents, video, audio, and other files that you upload to the App or raw data that you provide to the App.
- Learning Progress: Your progress through lessons and educational materials.
- Responses: Your answers, inputs, and interactions (including time delays) within the App.
- Preferences: Your settings and customization choices.
This data is used solely to implement the App's functionality as presented to you within the App.
2.3 Automatically Collected Technical Data: When you use the App, we automatically collect certain technical information, such as:
- Device Information: such as device type, operating system, and browser type/version
- Error Reports: such as crash logs and error messages to help us identify and fix technical issues
- Session Data: such as session duration, pages/screens visited within the App
- Security Data: such as IP address, browser fingerprinting and anti-fraud signals to protect against unauthorized access
This technical data is linked to your account for error debugging and security purposes. Error logs are retained for up to 90 days (see Section 5.5). This data is used solely for debugging, security monitoring, and improving App stability.
3. How We Use Your Information
3.1 Personalization: We use your data to personalize your learning experience, such as suggesting lessons and tracking your progress.
3.2 Communication: We send notifications about your progress, new content, and promotional offers. You can opt-out of marketing communications at any time by clicking the "unsubscribe" link at the bottom of any marketing email, or by emailing us at support@pavelsdog.com with subject line "Unsubscribe".
3.3 Analytics: We analyze usage data to improve the App's features and content.
3.4 Third-Party Integrations: We may share data with third-party services to support App functionality, including:
AI Cloud Services:
- OpenAI: AI-powered text, image, and audio processing.
https://openai.com/policies/privacy-policy - Anthropic: AI-powered text, image, and audio processing.
https://www.anthropic.com/privacy - Google AI: AI-powered text, image, and audio processing.
https://policies.google.com/privacy - X AI: AI-powered text, image, and audio processing.
https://x.ai/legal/privacy-policy/
Payment Processors:
- PayPal: Payment processing.
https://www.paypal.com/webapps/mpp/ua/privacy-full - Google Play Store: Payment processing and app distribution.
https://policies.google.com/privacy - Apple App Store: Payment processing and app distribution.
https://www.apple.com/legal/privacy/
Marketing and Communication Services:
- MailerLite: Email delivery services.
https://www.mailerlite.com/legal/privacy-policy
Technical Infrastructure:
- Google Cloud: Infrastructure provider.
https://cloud.google.com/terms/cloud-privacy-notice - Sentry: Software quality monitoring.
https://sentry.io/privacy/
3.5 AI and Machine Learning: We do not use your personal information, messages, or uploaded content to train AI models. When we process your data using third-party AI services, it is solely to provide you with the App's features and is not used for model training purposes.
4. Data Sharing and Disclosure
4.1 Service Providers: We share data with third-party service providers only to the extent necessary to support the App's functionality.
4.2 Legal Requirements: We may disclose your data to comply with legal obligations or in response to valid requests by public authorities.
4.3 Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your data may be transferred.
4.4 No Sale of Personal Information: We do not sell your personal information to third parties.
4.5 Third-Party Websites: The App may contain links to external websites or services that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
5. Data Security
5.1 Secure Authentication: We use secure authentication methods to protect your account.
5.2 Data Minimization: We collect only the data necessary for the App's functionality to minimize risk.
5.3 Security Practices: Our team follows best security practices, including regular training and awareness programs.
5.4 Backup and Recovery: We maintain regular data backups and have a disaster recovery plan in place.
5.5 Data Retention: We retain your data for different periods depending on the type of information:
- Account Data: Your personal information (name, email, date of birth, avatar) is retained while your account is active. Upon account deletion, this data is permanently deleted within 30 days.
- Learning Progress Data: Your learning progress, responses, and preferences are retained while your account is active and deleted along with your account data.
- Error Logs and Technical Data: Technical information about application errors is retained for up to 90 days for debugging and quality improvement purposes, then automatically deleted.
- Backup Data: Database backups containing your data are retained for up to 30 days and are automatically purged thereafter.
- Account Deletion: When you delete your account, all your personal data is removed from our active systems within 30 days. Residual copies in backups are purged within the backup retention period. Some anonymized, aggregated data that cannot be linked back to you may be retained for analytics purposes.
6. User Rights
6.1 Access and Correction: You have the right to access and correct your personal data.
6.2 Deletion: You can request the deletion of your personal data. To delete your account, you can email us at support@pavelsdog.com with subject line "Data Deletion Request". We will process your request within 30 days.
6.3 Objection and Restriction: You have the right to object to or restrict the processing of your data.
6.4 Data Portability: You have the right to request a copy of your data in a structured, commonly used, and machine-readable format.
6.5 Withdrawal of Consent: You can withdraw your consent to data processing at any time. Since the App's core functionality relies on processing your data, withdrawal of consent will result in the deletion of your account and all associated data. To withdraw consent, please follow the account deletion process described in Section 6.2 above. We will process your request within 30 days and send you a confirmation.
7. Legal Compliance
We comply with various data protection regulations, including:
- GDPR: Providing EU users with transparency and control over their personal data, including rights to access, rectify, and erase data.
- CCPA: Giving California residents the right to know what personal data is collected, request its deletion, and opt-out of its sale.
- Global Data Protection: Ensuring our data handling practices meet local legal requirements in other jurisdictions.
8. Cookies and Tracking
We use cookies for the following purposes:
- Authentication of registered users.
- Depersonalized identification of anonymous users when they are trying features that depend on cloud data processing.
- Storing your per-device preferences.
We do not use cookies for tracking or advertising purposes.
9. Do Not Track
We do not currently respond to "Do Not Track" browser signals. Instead, we continuously work to minimize user tracking across our App.
10. Children's Privacy
The App is intended for users who are at least 13 years of age. Children under the age of 13 cannot use or register for the App. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.
Users between 13 and the age of legal majority in their jurisdiction (typically 18) must have their parent or legal guardian consent to these terms and our Privacy Policy on their behalf. The parent or guardian is the contracting party and is responsible for their child's use of the App.
We strive to design the App to be suitable for all ages and do not intentionally include content that is inappropriate for younger users. However, as a small business, we do not have the resources to formally certify compliance with all child-specific privacy regulations (such as COPPA in the United States or equivalent regulations in other jurisdictions). Our legal relationship is with adults: either the user directly (if 18 or older) or with the parent/guardian of younger users.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Registered users will be notified via email, and updates will be published at pavelsdog.com/legal.
12. Contact Information
If you have any questions or concerns about this Privacy Policy, please contact us at support@pavelsdog.com. We aim to respond to all privacy-related inquiries as soon as possible, but no later than 30 days.