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Privacy Policy

Last updated: June 5, 2026

This Privacy Policy applies to all mobile applications published by Otters Camp (legal name: IE Anton Porozhniak), including Praxee and any other current or future apps (“we”, “our”, or “us”). This policy explains how we collect, use, and protect your information when you use our apps.

1. Definitions

For the purposes of this Policy:

2. Information We Collect

We may collect certain information automatically when you use our apps, including:

We do not currently collect personally identifying details such as your name, email address, or contact information, since users cannot create accounts at this time. The only exception is any content you choose to type into our AI-powered features (see Section 3a), which may contain personal information if you enter it yourself. If account features are added in the future, this policy will be updated accordingly.

3. SDKs, Identifiers, and Local Storage

Our apps may use software development kits (SDKs) and device identifiers for analytics, performance tracking, error detection, subscription management, and marketing attribution. These include Firebase Analytics, Unity Analytics, GameAnalytics, RevenueCat, and AppsFlyer. We may also store small amounts of information locally on your device (“local storage”) to remember progress, preferences, or settings.

For marketing attribution, we use AppsFlyer, which may process device and advertising identifiers (such as Apple's IDFA or Google's Advertising ID) to measure the effectiveness of our marketing and understand how users discover our apps. On Apple devices, the advertising identifier is only accessed if you grant permission through the App Tracking Transparency prompt. You can reset or limit your advertising identifier at any time in your device settings.

3a. AI-Powered Features

Some features of our apps use third-party artificial intelligence services to generate responses, feedback, or learning content. These providers are OpenAI (ChatGPT) by OpenAI, L.L.C. and Google Gemini by Google LLC.

When you use these features, the text you enter and your selected language are sent to the relevant AI provider in order to process your request and return a response. We do not send your name, email, device identifiers, or other personal identifiers to these providers together with your input. Please avoid entering sensitive personal information into AI features, as your input is transmitted to and processed by these third parties.

You can learn more about how these providers handle data in their privacy policies:

3b. Microphone and Voice Recordings

Some features of our apps let you record your voice (for example, to practice or receive feedback on pronunciation). These features use your device's microphone, and we will ask for microphone permission before recording. Recording only happens when you actively choose to use such a feature; we do not record audio in the background or without your action. You can deny or revoke microphone access at any time in your device settings, though related features may then be unavailable.

When you submit a recording, the audio is stored on our servers (including Google Firebase) and may be sent to Google Gemini to process your request and generate feedback or results. We do not use your voice recordings to identify you, for advertising, or for any purpose other than providing the requested feature and improving our services. Your recordings are retained until you request their deletion (see Section 10).

4. Analytics and Crash Reporting

We use third-party services to understand how our apps are used and to improve their performance and stability:

These services automatically collect non-personal and aggregated data related to app usage and technical performance. You can learn more about how these providers process data by reviewing their respective privacy policies:

5. Payments and Subscriptions

Some of our apps offer in-app purchases or auto-renewing subscriptions. All payments are processed securely by the Apple App Store or Google Play. We do not have access to or store payment card details, billing information, or any financial credentials. We use RevenueCat to manage and validate subscriptions and in-app purchases and to analyze subscription and revenue metrics; RevenueCat receives purchase and device-level information (such as anonymous purchase identifiers) for these purposes, but not your payment card details. Refunds or cancellations must be managed directly through your platform account.

5a. Push Notifications

With your permission, our apps may send you push notifications (for example, reminders or updates about your learning progress). When you enable notifications, a device push token is generated and processed through the operating system's notification service (Apple Push Notification service or Firebase Cloud Messaging) so that messages can be delivered to your device. You can disable push notifications at any time in your device settings.

6. How We Use Information

We use the data we collect to:

We use marketing attribution data (through AppsFlyer) solely to measure the performance of our own marketing campaigns and to understand how users discover our apps. We do not sell your data, and we do not use it to serve personalized advertising to you within our apps.

7. Data Sharing

We do not sell or rent user data. We may share limited technical information with third-party service providers such as Firebase, Unity, GameAnalytics, RevenueCat, or AppsFlyer strictly for analytics, subscription, marketing attribution, and operational purposes, and we share the input you provide to AI features — including any text and any voice recordings you submit — with OpenAI and Google Gemini solely to process your request, as described in this Policy.

We may also disclose information if required by law, court order, or government authority.

7a. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the CPRA, gives you certain rights regarding your personal information. We do not sell or share your personal information as those terms are defined under California law, and we do not use it for cross-context behavioral advertising.

Subject to applicable limitations, you have the right to request access to, correction of, or deletion of the personal information we hold about you, and the right not to be discriminated against for exercising these rights. To request deletion, please use the in-app “Request data deletion” option where possible, as described in Section 10, so we can verify the request relates to you; for other requests, contact us at [email protected]. Please note that processing such requests may take some time.

8. International Data Transfers

Our analytics and hosting providers (such as Google Firebase) may process and store your data on servers located outside of Georgia, including in the European Union and the United States. Such transfers take place on the basis of the applicable legal grounds described in Section 9a (for example, your consent for analytics, or the performance of a contract for features you request). We take reasonable steps to ensure that these providers protect your data according to applicable standards.

9. Data Retention

We retain analytics and crash data as long as necessary for operational, analytical, and security purposes. We do not automatically delete this data after a fixed time period unless required by applicable law or the service provider’s retention policies.

9a. Legal Basis and Consent (EEA/UK Users)

If you are located in the European Economic Area (EEA), the United Kingdom, or another region with similar data protection laws, we process your data on the following legal bases:

You also have the right to access, correct, delete, restrict, or object to the processing of your personal data, and to data portability. To request deletion, please use the in-app “Request data deletion” option where possible, as explained in Section 10, since this is how we can verify that the data relates to you. For other requests or questions, contact us at [email protected]. You may also lodge a complaint with your local data protection authority.

10. Data Access and Deletion

This section explains how you can request deletion of the data collected by Praxee and other apps published by Otters Camp.

How to request deletion. Because our apps do not require accounts, the data we collect is tied to your device or installation rather than to your name or email. For this reason, the primary way to request deletion of your data is:

If you are unable to use the in-app option (for example, you no longer have the app installed), you may contact us at [email protected], and we will help to the extent we are able. Under applicable data protection laws, where we cannot identify you from the data we hold, we are not required to collect additional information solely to identify you, and we may ask you to provide details (such as your device or installation identifier) so we can verify the request. Requests made through channels where we cannot verify that the data belongs to you may not be able to be fulfilled.

What is deleted. Upon a valid request, we delete the personal data associated with your device or installation that we control, including your in-app progress and activity data, any voice or audio recordings you have submitted, and your analytics data (for example, data held in Firebase Analytics, deleted via the provider's user-deletion mechanism). Related crash and diagnostic identifiers are also removed or disassociated.

When deletion takes effect. After you submit a valid deletion request, your data is permanently deleted 30 days later. During this 30-day period you can cancel (withdraw) your deletion request — for example, if you change your mind or continue using the app — and your data will be kept. If the request is not cancelled within 30 days, the deletion is carried out and cannot be reversed.

What is kept. We may retain certain information where we are legally required or permitted to do so, including records of purchases and subscriptions, which are needed for accounting, tax, and fraud-prevention purposes and are processed by the Apple App Store or Google Play rather than by us. We may also retain data that has been aggregated or anonymized so that it can no longer be linked to you. Such retained data is kept only for as long as required by applicable law or the relevant provider's retention policies.

Please note that processing these requests may take some time, as our apps do not provide automated self-service deletion and some information is handled through third-party providers. We will make reasonable efforts to fulfill valid requests within a reasonable period (and within any timeframe required by applicable law), subject to any legal or technical limitations.

11. Children’s Privacy

Our apps are intended for a general audience and are not directed to children. They are not intended for use by children under the age of 13 (or the higher minimum age required in your country, such as 16 in parts of the EEA). We do not knowingly collect personal data from children under these ages, and we do not market our apps to children.

App store age ratings (such as 12+ on the App Store or PEGI 3 on Google Play) describe the suitability of our content and do not indicate that our apps are designed for or directed to children. If you believe that a child under the applicable age has provided us with personal data, please contact us at [email protected], and we will take reasonable steps to delete it.

12. Security

We take reasonable and appropriate measures to protect information against unauthorized access, alteration, disclosure, or destruction. However, please note that no system or network is completely secure.

In the event of a data breach that affects your personal data, we will notify the relevant supervisory authority and, where required by applicable law, affected users, within the timeframes set out by that law.

13. Third-Party Links

Our apps may contain links to external websites or services. We are not responsible for the content or privacy practices of these third-party services. We encourage you to review their privacy policies before interacting with them.

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our apps, data practices, or legal requirements. The updated version will be posted within our apps and on our website, with the “Last updated” date adjusted accordingly.

15. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

Email: [email protected]

16. Governing Law

This Privacy Policy is governed by the laws of Georgia (the country), except where otherwise required by applicable data protection laws (such as the GDPR). Nothing in this Policy deprives consumers in the EEA or UK of the mandatory protections granted by the laws of their country of residence.