Privacy Policy

Last updated: 27 August 2026

The English version of this policy is the governing version. Translations are provided for convenience; in case of any discrepancy the English text prevails.

This Privacy Policy explains how Behappy Speak ("we", "us", "our") collects, uses, and protects your personal data when you use the Behappy Speak Telegram bot and Mini App (the "Service") — an AI-powered language-learning service. By using the Service you agree to the practices described here.

1. Who we are (Data Controller)

The Service is operated by Individual Entrepreneur (FOP) Illya Lavrentyev, registered in Ukraine (the "Operator", "we").

For any privacy-related question or request, contact us:

2. What data we collect

We collect only the data needed to run a personalised language-learning service:

  • Telegram account data: your Telegram ID, first/last name, username (if set), and interface language code — as provided to the bot by Telegram.
  • Learning data: your chosen interface language and the language you are learning, your learning progress, and the content of your practice sessions with the bot (messages, dialogues, exercises and error analysis) so we can give feedback and generate personalised quizzes.
  • Subscription & payment data: your subscription tier and status, the currency used, and transaction identifiers needed to confirm and manage your subscription.

We do not collect or store your full payment-card numbers, CVV, or bank credentials. Card payments are processed by our Merchant of Record, Creem (see section 8). We receive only the information required to confirm a successful payment and manage your subscription.

3. How we use your data

We process your data to:

  • provide and operate the Service and your account;
  • personalise your learning, analyse your mistakes, and generate quizzes and exercises;
  • process payments, activate and manage subscriptions, and prevent fraud;
  • provide customer support and respond to your requests;
  • maintain security and improve the quality of the Service;
  • comply with our legal and accounting obligations.

4. Legal bases for processing

Where applicable data-protection law (including the GDPR) applies, we rely on the following legal bases:

  • Performance of a contract — to provide the Service and your subscription;
  • Consent — where you have given it (e.g. optional analytics);
  • Legitimate interests — to secure, maintain and improve the Service and prevent abuse;
  • Legal obligation — to meet tax, accounting and other legal requirements.

5. Sharing with third parties

We do not sell your personal data. We share it only with service providers who help us operate the Service, and only to the extent necessary:

  • Telegram — the platform the Service runs on. Your use of Telegram is governed by Telegram's own privacy policy.
  • Creem — our Merchant of Record and contractual reseller, which processes card payments (see section 8). Creem is the seller and Merchant of Record for card orders. Payment data you enter is handled under Creem's privacy notice.
  • AI / language-model providers — the text of your practice sessions may be processed by trusted third-party AI providers solely to generate tutoring responses, corrections and exercises.
  • Hosting and infrastructure providers — to store data and run the Service.
  • Analytics (Google Analytics) — on our website, to understand aggregate usage.

We may also disclose data where required by law or to protect our rights.

6. International transfers

Some of our providers may process data outside your country. Where this happens, we take reasonable steps to ensure your data is protected by appropriate safeguards consistent with applicable law.

7. Data retention

We keep your data for as long as you use the Service and your account is active, and afterwards only as long as needed for the purposes described above or to meet legal, tax and accounting obligations. When data is no longer needed, we delete or anonymise it. You can ask us to delete your account and associated data at any time (see section 9).

8. Payments and Creem

Card payments for our orders are processed by Creem (Armitage Labs OÜ), our Merchant of Record and contractual reseller. Creem is the seller of record for card transactions and is responsible for collecting and processing payment, issuing invoices, and calculating, collecting and remitting applicable indirect taxes.

When you pay for a card subscription, the payment data you enter is collected and processed by Creem, not by us, and is subject to Creem's Privacy Notice. Payments made with Telegram Stars are handled through Telegram.

9. Your rights

Subject to applicable law, you have the right to access, correct, or delete your personal data, to restrict or object to certain processing, to data portability, and to withdraw consent at any time. You also have the right to lodge a complaint with a supervisory authority.

To exercise any of these rights, contact us at elias@lavrentech.com. You can also request deletion of your account and learning data directly through the bot or by writing to us.

10. Children

The Service is not directed to children under 16. If you believe a child has provided us with personal data, please contact us and we will delete it.

11. Security

We use reasonable technical and organisational measures to protect your data against unauthorised access, loss or misuse. No method of transmission or storage is completely secure, but we work to keep your data safe.

12. Cookies

Our website uses a small number of cookies: a functional cookie to remember your chosen language, and analytics cookies (Google Analytics) to measure aggregate usage. You can control cookies through your browser settings.

13. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top shows the latest version. Material changes will be communicated through the Service where appropriate.

14. Contact us

If you have any questions about this Privacy Policy or how we handle your data, contact Individual Entrepreneur (FOP) Illya Lavrentyev at elias@lavrentech.com.