Privacy Notice

This Privacy Notice explains how Baltic Mobile OÜ ("Company", "we", "us", or "our") collects, uses, stores, shares, and protects your personal information when you access or use the website located at sakinapath.com and any related services (collectively, the "Services").

This Privacy Notice also explains your privacy rights and how applicable privacy laws protect you.

By accessing or using the Services, creating an account, or otherwise providing your personal information, you acknowledge that you have read and understood this Privacy Notice.

If you do not agree with this Privacy Notice, you must discontinue use of the Services immediately.

Baltic Mobile OÜ is the controller responsible for processing your personal information.

• Company Name: Baltic Mobile OÜ
• Registered Address: Lääne-Viru maakond, Tapa vald, Moe küla, Moe keskus 6-7, 45005, Estonia
• General Support: support@sakinapath.com
• Privacy Inquiries: support@sakinapath.com

The Services are intended solely for individuals who are at least eighteen (18) years of age.

We do not knowingly collect, process, or store personal information from individuals under the age of eighteen.

If we become aware that personal information belonging to an individual under eighteen has been collected, we will take reasonable steps to delete such information without undue delay.

If you believe that a minor has provided personal information to us, please contact us at support@sakinapath.com.

We may collect information directly from you, automatically through your use of the Services, and from certain third-party service providers.

The categories of information we collect may include:

Account Information

• Name;
• Email address;
• Account credentials;
• User preferences and account settings.

Profile Information

• Learning goals and interests provided through the Services;
• Selected habits and daily practice preferences;
• Profile settings.

Learning and Progress Information

We may collect information you voluntarily provide or generate through your use of the Services, including lesson progress, quiz answers and results, habits and check-ins, daily task completions, streaks, experience points (XP), and activity dates, in order to provide personalized recommendations and Services.

Subscription Information

• Subscription identifier;
• Subscription status;
• Billing period;
• Purchase date;
• Renewal date;
• Transaction history.

Payment Information

Payments are processed by authorized third-party payment providers. We do not store complete payment card numbers or card security codes (CVV/CVC).

We may receive limited transaction-related information, including:

• Payment status;
• Transaction identifiers;
• Subscription identifiers;
• Card brand;
• Partial card number masking information;
• Purchase amount and currency.

Technical Information

We may automatically collect:

• IP address;
• Browser type and version;
• Device type;
• Operating system;
• Language preferences;
• Country and region;
• Network information;
• Diagnostic and performance information.

Usage Information

We may collect information regarding your interaction with the Services, including:

• Pages viewed;
• Features used;
• Session duration;
• Clickstream data;
• User activity and engagement metrics.

We use your personal information for the following purposes:

Providing the Services

• Creating and managing user accounts;
• Delivering personalized content, recommendations, and learning programs;
• Providing customer support;
• Managing subscriptions and account settings.

Processing Transactions

• Processing subscription purchases;
• Managing recurring billing and renewals;
• Detecting payment errors and fraudulent transactions;
• Maintaining transaction records.

Improving the Services

• Analyzing user behavior and engagement;
• Monitoring performance and stability;
• Developing new features and functionality;
• Improving user experience and service quality.

Marketing Communications

Where permitted by applicable law, we may use your information to:

• Send service-related notifications;
• Deliver newsletters and promotional communications;
• Inform you about new features, offers, or updates.

You may opt out of marketing communications at any time by following the unsubscribe instructions included in such communications or by contacting us.

Security and Fraud Prevention

We use personal information to:

• Detect, prevent, and investigate fraud;
• Protect the security and integrity of the Services;
• Prevent unauthorized access;
• Enforce our legal rights and contractual obligations.

Legal Compliance

We may process personal information when necessary to:

• Comply with applicable laws and regulations;
• Respond to lawful requests from governmental authorities;
• Resolve disputes;
• Establish, exercise, or defend legal claims.

If you are located in the European Economic Area ("EEA"), United Kingdom, or another jurisdiction requiring a lawful basis for processing, we rely on one or more of the following legal grounds:

Performance of a Contract

We process personal information where necessary to:

• Create and maintain your account;
• Deliver the Services;
• Process subscriptions and payments;
• Provide customer support.

Legitimate Interests

We process personal information where necessary for our legitimate business interests, including:

• Improving and developing the Services;
• Monitoring performance and security;
• Preventing fraud and abuse;
• Conducting analytics and business operations.

When relying on legitimate interests, we carefully balance our interests against your rights and freedoms.

Legal Obligations

We may process personal information where necessary to comply with:

• Tax obligations;
• Accounting requirements;
• Consumer protection laws;
• Regulatory obligations;
• Law enforcement requests.

Consent

Where required by law, we process personal information based on your consent. You may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing conducted before such withdrawal.

We do not sell your personal information.

We may share personal information with trusted third parties only as necessary to operate, maintain, and improve the Services.

Categories of recipients may include:

Payment Service Providers

We share limited information with payment processors to:

• Process transactions;
• Manage subscriptions;
• Prevent fraud;
• Comply with financial regulations.

Analytics Providers

We may use analytics providers to better understand how users interact with the Services and improve performance.

Communication Providers

We may use third-party communication services to send:

• Transactional emails;
• Account notifications;
• Customer support communications;
• Marketing communications where permitted.

Cloud Hosting and Infrastructure Providers

We use third-party infrastructure providers to host and maintain the Services and related systems.

Professional Advisors

We may share information with legal, accounting, compliance, and professional advisors where reasonably necessary.

Government Authorities

We may disclose personal information when required by law or where necessary to:

• Comply with legal obligations;
• Protect our rights;
• Prevent fraud or illegal activities;
• Protect users or the public.

Your personal information may be transferred to and processed in countries outside your country of residence, including the United States and other jurisdictions where our service providers operate.

Where required by applicable law, we implement appropriate safeguards for international data transfers, including:

• Standard Contractual Clauses approved by relevant regulatory authorities;
• Data Processing Agreements;
• Additional technical and organizational security measures.

By using the Services, you acknowledge that your information may be transferred to jurisdictions that may provide a different level of data protection than your country of residence.

We use cookies, pixels, SDKs, and similar technologies to operate the Services, improve functionality, analyze user behavior, and measure the effectiveness of our marketing activities.

Cookies may include:

Essential Cookies

These cookies are necessary for the operation of the Services and cannot be disabled. Examples include:

• User authentication;
• Security and fraud prevention;
• Session management;
• Subscription management.

Analytics Cookies

These cookies help us understand how users interact with the Services, including:

• Traffic sources;
• User behavior;
• Feature usage;
• Performance monitoring.

Marketing Cookies

Subject to your consent where required by law, we may use marketing technologies to:

• Measure advertising effectiveness;
• Deliver relevant advertisements;
• Build audience insights;
• Improve marketing campaigns.

You may manage cookie preferences through your browser settings or through any cookie consent tools made available on the Services.

For additional information, please review our Cookie Policy.

We implement reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

Such measures may include:

• Encryption of data in transit using HTTPS and TLS technologies;
• Access controls and authentication procedures;
• Monitoring and logging systems;
• Secure cloud infrastructure;
• Employee confidentiality obligations.

Although we strive to protect personal information, no method of electronic transmission or storage can be guaranteed to be completely secure. Therefore, we cannot guarantee absolute security.

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Notice, including:

• Providing and maintaining the Services;
• Managing subscriptions and transactions;
• Complying with legal and regulatory obligations;
• Resolving disputes;
• Enforcing agreements.

When personal information is no longer required, we will securely delete, anonymize, or otherwise dispose of it in accordance with applicable laws and internal retention policies.

Certain information may be retained for longer periods where required by law, regulatory obligations, fraud prevention requirements, accounting requirements, or legitimate business interests.

Depending on your jurisdiction, you may have certain rights regarding your personal information. These rights may include:

Right of Access

You may request information regarding the personal data we process about you.

Right to Rectification

You may request correction of inaccurate or incomplete personal data.

Right to Erasure

You may request deletion of your personal data, subject to applicable legal limitations.

Right to Restrict Processing

You may request that we temporarily or permanently limit certain processing activities.

Right to Data Portability

You may request a copy of your personal data in a structured, commonly used, and machine-readable format.

Right to Object

You may object to certain processing activities based on legitimate interests.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw such consent at any time.

Right to Lodge a Complaint

You may file a complaint with the competent data protection authority if you believe your rights have been violated.

To exercise any privacy rights, please contact us at support@sakinapath.com. We may request reasonable information to verify your identity before responding to your request.

If you are a California resident, you may have additional rights under applicable California privacy laws. Subject to applicable law, California residents may have the right to:

• Know what personal information is collected and disclosed;
• Request deletion of personal information;
• Request correction of personal information;
• Request access to collected personal information;
• Limit certain uses of sensitive personal information where applicable.

We do not sell personal information and do not share personal information for monetary consideration.

Certain web browsers may transmit "Do Not Track" signals. Because there is currently no universally accepted standard for responding to such signals, the Services may not respond to all Do Not Track requests.

We may update this Privacy Notice from time to time.

If material changes are made, we may notify users through the Services, by email, or through other reasonable means. The updated version will become effective upon publication unless otherwise stated.

Your continued use of the Services after the effective date of the updated Privacy Notice constitutes acceptance of the revised Privacy Notice.

If you have any questions regarding this Privacy Notice, your personal information, or your privacy rights, please contact us:

• Baltic Mobile OÜ
• Lääne-Viru maakond, Tapa vald, Moe küla, Moe keskus 6-7, 45005, Estonia
• Email: support@sakinapath.com

We will make reasonable efforts to respond to privacy-related inquiries within the timeframes required by applicable law.