Privacy Policy

1Who we are

Thinkly is a microlearning mobile application operated by Allie Ltd ("Thinkly", "we", "us", or "our"), a company registered in the Republic of Cyprus.

• Company: Allie Ltd
• Registration No.: HE 460424
• VAT No.: 60076104S
• Registered address: Emmanouil Roidi 44, Kirzis Center, 3031, Limassol, Cyprus
• Contact: support@thinklyapp.ai

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our mobile application and related services (collectively, the "Service").

By using the Service, you agree to the collection and use of information in accordance with this policy. If you do not agree with any part of this policy, please do not use the Service.

2Information we collect

Information you provide directly

• Account data — name, email address, and password when you register via email, or the public profile data your provider shares when you sign in with Apple or Google. Passwords are stored in hashed form and are never accessible to us in plain text.
• Onboarding answers — your age range, learning goals, preferred topics, daily target, learning style, and other preferences you enter during onboarding.
• In-app activity — lessons you start, complete, or bookmark; quiz answers; ratings and comments.
• Subscription information — purchase receipts and subscription status are processed by Adapty and the relevant app store. We do not store your payment card details.

Information collected automatically

• Usage data — features accessed, screens viewed, buttons tapped, session duration, streak data, and lesson completion times.
• Device data — device model, operating system version, unique device identifiers, app version, and crash reports.
• Analytics data — aggregated behavioral signals collected via Amplitude to understand how users interact with the app.
• Push notification token — a Firebase Cloud Messaging token to deliver push notifications, collected only after you grant permission.

3How we use your information

We use the information we collect to:

• Provide, maintain, and improve the Service — including generating your personalized lesson feed and learning plan based on the preferences you selected during onboarding.
• Personalize your experience based on your topics, goals, and learning history.
• Track and display your learning progress, streaks, and achievements.
• Send push notifications about daily lessons, streak reminders, and account updates (only with your permission).
• Process subscription purchases and validate receipts.
• Analyze aggregate usage patterns to improve content quality and app performance.
• Detect and prevent fraud, abuse, and security incidents.
• Comply with legal obligations.

Personalization is rule-based and does not involve automated decision-making that produces legal or similarly significant effects on you within the meaning of Article 22 GDPR.

We rely on the following legal bases under applicable data protection laws: contract performance (to deliver the Service), legitimate interests (analytics, security, service improvement), and consent (push notifications, optional data collection).

4How we share your information

We do not sell, rent, or trade your personal information. We share data only in these circumstances:

• Service providers — trusted third parties that help us operate the Service: AWS (cloud hosting), Adapty (subscription management), Amplitude (analytics), Firebase / Google (push notifications), SendGrid (transactional email). Each is bound by data processing agreements.
• Legal requirements — if required by law, court order, or government authority, or to protect the rights, property, or safety of Thinkly, our users, or others.
• Business transfers — in the event of a merger, acquisition, or sale of assets, user data may be transferred. We will notify you via in-app notice or email before your data becomes subject to a different privacy policy.
• With your consent — for any other purpose with your explicit consent.

5Data retention

We retain your personal information for as long as your account is active or as needed to provide the Service. If you delete your account, we will delete or anonymize your personal data within 30 days, except where we are required to retain certain information by law (e.g., billing records under Cyprus tax law) or for legitimate business purposes (e.g., fraud prevention).

Aggregated, anonymized analytics data may be retained indefinitely as it cannot be used to identify you.

6Your rights & choices

As a data subject under the EU General Data Protection Regulation (GDPR) and equivalent laws, you have the following rights regarding your personal data:

• Access — request a copy of the personal data we hold about you.
• Correction — ask us to correct inaccurate or incomplete data.
• Deletion — request deletion of your account and associated personal data ("right to be forgotten").
• Portability — receive your data in a structured, machine-readable format.
• Objection / restriction — object to or request restriction of certain processing activities.
• Withdraw consent — where processing is based on consent, withdraw it at any time without affecting prior processing.

To exercise any of these rights, email us at support@thinklyapp.ai. We will respond within 30 days. You may also delete your account directly within the app under Profile → Settings → Delete Account.

If you are in the EU/EEA, you have the right to lodge a complaint with your local data protection authority. The supervisory authority for Allie Ltd is the Office of the Commissioner for Personal Data Protection of Cyprus (commissioner@dataprotection.gov.cy, www.dataprotection.gov.cy).

California residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know, the right to delete, and the right to opt out of the sale of personal information. We do not sell personal information. To exercise your CCPA rights, contact us at support@thinklyapp.ai.

7Push notifications

We use Firebase Cloud Messaging to send push notifications such as daily lesson reminders and streak alerts. You can opt in or out at any time through your device's notification settings or within the app under Profile → Settings → Notifications. Disabling notifications does not affect any other functionality.

8Children's privacy

The Service is intended for users aged 18 and over. During onboarding we ask you to select your age range; we use this information to personalize lesson recommendations.

We do not knowingly collect personal information from children under the age of 13 (or under the applicable age of digital consent in your country, which is 14–16 in some EU/EEA member states) without verifiable parental consent. If you are under that age, please do not use the Service or provide any personal information.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us at support@thinklyapp.ai and we will promptly delete that information and close the associated account.

9Security

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256).
• JWT-based authentication with short-lived access tokens and refresh token rotation.
• Regular security audits and vulnerability scans.
• Access controls limiting employee access to personal data on a need-to-know basis.

No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a personal data breach affecting your rights and freedoms, we will notify you and the competent supervisory authority as required by Articles 33–34 GDPR.

10International transfers

Allie Ltd is established in the Republic of Cyprus (EU). Your information may be transferred to, stored, and processed in countries outside the EU/EEA, including the United States, where our cloud infrastructure is hosted (AWS us-east-1). These countries may have different data protection laws than those of your country of residence.

Where we transfer data from the EU/EEA to third countries, we rely on European Commission–approved Standard Contractual Clauses or other appropriate safeguards under Chapter V GDPR. A copy of these safeguards is available on request at support@thinklyapp.ai.

11Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy in the app and updating the "Last updated" date at the top of this page. For significant changes that affect your rights, we will obtain your renewed consent where required by law or send an in-app notification or email at least 30 days before the changes take effect.

12Contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all privacy inquiries within 30 days.