Privacy Policy

1. Who is responsible for your data

LEVELYM is currently operated by Anton Pozdeev, intended to operate as an Individual Entrepreneur in Georgia (registration pending; registration number and registered business address pending), referred to in this Policy as “LEVELYM”, “we”, “us” or “our”.

For account administration, service operation, security, support, marketing and product analytics, LEVELYM acts as the controller of personal data. For workspace content that a tutor adds about a student, the tutor generally decides why that information is used and LEVELYM generally processes it to provide the service on the tutor’s instructions. The precise legal role may depend on the circumstances and applicable law.

Questions and privacy requests can be sent to support@levelym.com.

2. Scope of this Policy

This Policy applies to the LEVELYM marketing website, web application, support communications and related notifications. It does not govern third-party websites or services that have their own privacy notices.

Tutors are responsible for giving students, parents or guardians any additional privacy information required for the tutor’s own teaching practice and for having a lawful basis to add student information to LEVELYM.

3. Personal data we collect

Depending on how you use LEVELYM, we may collect the following categories of personal data:

• Account and identity data, such as name, email address, profile image, role and authentication identifiers received through Google sign-in.
• Tutor practice and student profile data, such as subjects, goals, experience, limitations, tutor notes, invitations and account relationships.
• Teaching and learning content, such as schedules, lesson records, assessments, recaps, homework, submissions, progress criteria, ratings and messages.
• Audio and derived content when a user chooses a voice or speech feature, such as a recording, transcript or generated recap.
• Support and communication data, including messages sent to support and notification preferences for email, Telegram or other enabled channels.
• Transaction and billing data if paid features are activated. Payment-card details should be processed by the selected payment provider rather than stored by LEVELYM, except for limited billing references and transaction records.
• Device, log and usage data, such as IP address, browser and device type, language, approximate location derived from IP, pages and features used, timestamps, referral or campaign parameters, diagnostics and security events.

4. Where data comes from

We receive data directly from you, from another LEVELYM user who invites or works with you, automatically from your device when you use the service, and from connected providers such as Google authentication. A tutor may create a student record before that student registers.

If you provide personal data about another person, you must be authorised to do so, provide any required notice and ensure the data is relevant and accurate.

5. Why we use data and our legal bases

We process personal data only when we have an appropriate legal basis. Depending on the data and applicable law, we use it to:

• Provide the service and perform our agreement with you, including authentication, scheduling, student workspaces, lessons, homework, progress, messages and notifications.
• Act on a tutor’s documented instructions when hosting and processing student workspace content.
• Protect the service, prevent abuse, troubleshoot failures and keep appropriate logs based on our legitimate interests and legal obligations.
• Respond to support requests, administer accounts and communicate important service or legal updates as necessary to perform the agreement or pursue legitimate interests.
• Understand website and product performance, improve LEVELYM and measure acquisition based on consent where required, or otherwise on legitimate interests where permitted.
• Meet accounting, tax, consumer-protection, data-protection and other legal obligations, and establish or defend legal claims.
• Send optional marketing communications only where permitted. You may unsubscribe at any time.

6. AI and speech features

LEVELYM may use AI and speech-processing providers to create optional transcripts, recaps or homework drafts from the context selected for that feature. Relevant content is sent to those providers only as needed to return the requested result.

AI output may be inaccurate. Tutors must review, edit and approve drafts before sharing them with students. LEVELYM does not use solely automated decisions that produce legal or similarly significant effects for users.

Do not place unnecessary sensitive personal data in prompts, recordings, notes or messages. Where special-category or sensitive data is genuinely needed, the tutor must ensure that its use is lawful.

7. Analytics, local storage and similar technologies

The marketing site stores referral and campaign attribution in the browser’s local storage. LEVELYM uses PostHog for website and product analytics, such as page visits, sign-up and activation events, feature usage, retention and error diagnosis. Where applicable law requires consent, non-essential analytics should be activated only after that consent is obtained.

Sensitive fields—including names, email addresses, messages, private notes, student data, lesson content and homework—must be excluded or masked from analytics capture and session replay. You can limit optional analytics through the consent controls made available on the site, or by contacting us if those controls are unavailable.

Google and other connected providers may set their own cookies or similar technologies under their respective notices.

8. When we share data

We do not sell personal data. We may disclose only the data reasonably necessary to:

• Tutors and students who are connected in the same workspace, according to their roles. Private tutor notes are intended to remain visible only to the tutor.
• Infrastructure, hosting, database, authentication, analytics, email, Telegram, AI, speech, security, support and payment providers acting for us under appropriate terms.
• Professional advisers, auditors or insurers where necessary and subject to confidentiality obligations.
• Public authorities or other parties when required by law, to protect rights and safety, investigate misuse or establish and defend legal claims.
• A buyer, investor or successor in a merger, financing, reorganisation or sale, subject to appropriate confidentiality and notice where required.

9. International data transfers

LEVELYM serves users internationally, and service providers may process data in Georgia, the European Economic Area, the United States or other countries. Privacy laws in those countries may differ from the laws where you live.

When required, we use recognised safeguards for international transfers, such as an adequacy decision, approved standard contractual clauses, contractual and technical protections, or another lawful transfer mechanism. Information about relevant safeguards may be requested at support@levelym.com.

10. How long we keep data

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy. The period depends on whether the account is active, the type of workspace content, tutor instructions, backup cycles, security needs, legal limitation periods and accounting or other statutory obligations.

When an account or workspace is deleted, data is removed or anonymised within a reasonable period unless it must be retained by law, is needed to resolve a dispute or remains temporarily in protected backups. We may retain aggregated or de-identified information that no longer identifies an individual.

11. Security

We use reasonable technical and organisational measures designed to protect personal data against accidental or unlawful loss, alteration, disclosure or access. No online service can guarantee absolute security.

You are responsible for protecting access to your Google account, devices and any invitation links, and for notifying us promptly if you suspect unauthorised access.

12. Your privacy rights

Depending on where you live and subject to legal limits, you may request information about our processing; access, correction, completion, deletion or blocking/restriction of your data; object to certain processing; receive portable data where applicable; and withdraw consent without affecting earlier lawful processing.

You may also complain to the competent supervisory authority. In Georgia, the supervisory authority is the State Audit Office of Georgia. If the EU or UK data-protection rules apply to you, you may also contact the authority where you live or work.

To exercise a right, email support@levelym.com. We may need to verify your identity and may direct a student request to the relevant tutor when LEVELYM processes the data on that tutor’s instructions. We will respond within the period required by applicable law.

13. Children and students who need guardian authorisation

LEVELYM is designed for tutors and their invited students; it is not directed to children for independent use without appropriate adult involvement. Tutors must consider a student’s age and legal capacity and obtain parent or legal-guardian authorisation where required.

If you believe a child’s data was added without the required authority, contact us so that we can investigate with the relevant tutor and take appropriate action.

14. Changes to this Policy

We may update this Policy as LEVELYM, our providers or the law changes. We will post the updated version here, change the “Last updated” date and, when appropriate, give additional notice in the service or by email.

For privacy questions or complaints, contact support@levelym.com.