Milaki Privacy Policy

Effective date: [DATE]. Last updated: [DATE].

Entity: [VERIFY: ORTHOREP LLC, a Washington limited liability company], [PLACEHOLDER: mailing address]

1. Who we are

This Privacy Policy explains what information Milaki ("the App") handles, where it is kept, and the choices and rights you have. It covers the Milaki iPhone app, the Milaki web app, and the milaki.app website [VERIFY: domain owned]. "We", "our", and "us" mean ORTHOREP LLC, [VERIFY: a Washington limited liability company] ([PLACEHOLDER: mailing address]). Milaki is a Modern Greek learning app. It is offered in the United States, Canada, Australia and New Zealand. Questions? See section 14.

Because Milaki stores your learning data on your own device unless you sign in, much of this policy describes what stays on your device rather than what we collect. We have written it to match what the App actually does.

2. What we collect

On your device (no account needed). Milaki works without an account. Your learning stays on your device:

• Your progress in stories, and where you left off.
• Answers you type and drafts you have not finished.
• Your review cards, review history, and words you marked as known.
• Your settings, such as playback speed and which study modes are on.
• Stories you downloaded for offline use, including their text, audio and images.
• Your self-ratings and level estimates from the app. [VERIFY: level estimates are stored.]
• A random install ID that the app makes on your device. We use it to tell your devices apart when you sync.
• Your country, so we can show the right content. On iPhone this comes from your App Store country and stays on the phone. On the web it comes from a request to our server (see "Web hosting logs").
• A log of the times you used AI help (see below), kept on your device only.

We do not see any of this unless you sign in.

If you sign in. Sign-in is optional. You sign in with your email address and a 6-digit code we email you. [VERIFY: Milaki accounts are currently created by us, not by self-signup. Update this paragraph if self-signup opens.] When you sign in, we store:

• Your email address and an account ID.
• Sign-in records: session IDs, when you signed in, and technical details such as your IP address and device type ([VERIFY: what Supabase Auth stores for this project]).
• The learning data listed above, so it can sync between your devices. This includes answers you typed, because those are part of your study history.
• Your personal notes on review cards (up to 2,000 characters). [VERIFY: notes feature and limit.]
• Technical sync records that help avoid duplicates when your connection drops.

If you use AI help. AI help is off by default. You turn it on in Settings, and you must be signed in and online to use it. [VERIFY: hosted AI help is currently disabled in the product; this describes the feature as it will be.] When you tap for help:

• For a hint, we send the text you typed (up to 1,000 characters [VERIFY]) and, if you ask again, the last hint. We send these from our server to Anthropic, which makes the Claude AI model.
• For an explanation, we send which story and sentence you are asking about.
• We do not send your name, email, account ID or device ID to Anthropic.
• Our server keeps a short record of each request: the time, the kind of request, whether it worked, and how much it cost. It does not keep the text you typed. [VERIFY: telemetry in packages/ai/src/handler.ts and platform logs never contain the draft.]
• Your device keeps a log of the AI help you got (the AI’s text, which story and exercise). It does not contain your typed draft.

Web hosting logs. When you use the web app, our host, Vercel, receives your IP address and the usual details of a web request, and may keep logs. We use the IP only to work out your country. We do not store it ourselves. [VERIFY: Vercel log retention and fields for this plan.]

Audio. The voices in Milaki are recorded or generated ahead of time. The app never records your voice and never asks for your microphone. [VERIFY: no microphone permission in app.json; confirm no dictation feature is planned.]

Location. Milaki does not ask for your name, phone number, or device location, and does not collect precise geolocation. The App never asks for or uses your device’s location services. [VERIFY: no location permission in app.json.]

Email you send us. If you email us, we keep the message and your address so we can reply and keep a record of your request.

3. How we use information

We use information only to run Milaki and keep it safe:

• Provide Milaki and sync. To save your progress, sync it between your devices, and let you export or delete it.
• Sign you in. To send your 6-digit code and keep your session secure.
• AI help, when you ask for it. To send your request to the AI provider and show you the answer.
• Security and abuse prevention. To protect accounts and servers, stop misuse, and fix technical problems.
• Legal compliance. To answer legal requests, meet our legal duties, and handle your privacy requests.
• Support. To answer your emails.

We do not build advertising profiles. We do not make decisions about you by automated profiling that has legal or similarly significant effects. We do not use your data for ads.

4. What we do not do

• We do not sell your personal information.
• We do not share it for advertising.
• We do not show ads.
• We do not use analytics or crash-reporting tools from other companies. [VERIFY: re-check before each release; none in package.json today.]
• We do not track you across other apps or websites.
• We do not use your data to train AI models, and we use providers whose terms say they will not train on it. [VERIFY: Anthropic commercial terms and DPA; zero or limited retention.]

5. Content in Milaki made with AI

Much of the story text in Milaki was drafted with AI (Claude) and is labeled in the app, for example "AI-generated · unreviewed." Narration may be an AI voice and is labeled. Some content is human-written or human-voiced and is labeled that way too. AI help answers are labeled "AI, unverified, may be wrong," and you can flag an answer that looks wrong. For details, see our AI content disclosure: [PLACEHOLDER: URL of 05-ai-content-disclosure.md as published, for example milaki.app/ai].

6. Purchases

Milaki Plus, the paid subscription, is sold only in the iPhone app. Purchases, trials, renewals, and restores are processed by Apple under your Apple ID through the App Store. The App receives a signed transaction from Apple describing your access state and nothing else. We do not receive your payment card details, billing address, or Apple ID email. [VERIFY: matches the StoreKit 2 build]

7. Website

The milaki.app website sets no cookies and runs no analytics or third-party scripts. [VERIFY: no cookies, analytics, embeds, fonts or scripts from other companies on the live site.] Our host, Vercel, receives your IP address and request details when you load a page, and may keep standard server logs. [VERIFY: Vercel log retention.] If you email us, we receive what you send. If we add a contact form or newsletter, we will update this section.

8. Who we share data with

We use a small number of service providers. They handle data for us, under contract, only to run Milaki ("processors"). We share only what each one needs.

We also use ElevenLabs to make narration audio before release. It receives no learner data. [VERIFY]

We may share information if the law requires it, or to protect people’s safety or our rights. If ORTHOREP LLC is sold or merged, your data may move to the new owner, which must honor this policy. [CONFIRM with lawyer.]

Moving data across borders. We and our providers (Supabase, Anthropic and Vercel) process data in the United States. If you live in Canada, Australia or New Zealand, your information leaves your country when you sign in, use AI help or use the web app. We take reasonable steps to protect it, including contracts that require these providers to handle it only for Milaki and to protect it. [VERIFY: Supabase region and where Anthropic and Vercel process data.] [COUNSEL: wording for Australian Privacy Principle 8 and New Zealand IPP 12.]

9. How long we keep it

When you delete your account we delete your server data [VERIFY: promptly, and whether technical sync records are purged at deletion or follow the 30-day schedule above] and it leaves backups within [VERIFY: N] days.

10. Your choices and rights

Your choices

• Export your data. In Settings > Data you can export your review deck, your history and your AI-help log. The export uses the share sheet. [VERIFY: matches the shipped build.]
• Delete your data. Deleting the Milaki app from your iPhone deletes all Milaki data on that iPhone; clearing site data does the same for the web app. You can also use Settings > Data > "Delete my data on this device". [VERIFY: not built yet.]
• Delete your account. If you are signed in: Settings > Account > "Delete my account". This removes your data from our servers and your sign-in. [VERIFY: not built yet.]
• No email, no problem. You can use Milaki without an account.
• AI help. Leave it off, or turn it off any time.
• Signing out. Each time you sign out, Milaki asks whether to keep your work on this device or remove it. The suggested choice is Remove on the web and Keep on iPhone, and you can pick either one every time. If you remove it, anything that has not synced yet is lost.
• Ask us. If you cannot use the app, email [PLACEHOLDER: privacy@milaki.app] to request deletion or a copy of your data. We will verify it is you by sending a code to the email on the account. [VERIFY: a /delete-account web page will also exist.]

Your rights

Regardless of where you live, you may:

• Know and access what personal data we hold. For data on your device, use the App or the export. We do not hold a copy unless you sign in.
• Correct your data by editing it in the App.
• Delete your data as described above.
• Port your data via the export.
• Withdraw consent for AI help (turn it off in Settings) at any time, without affecting prior processing.
• Not be discriminated against for exercising these rights.
• Complain to your state Attorney General or local data protection authority.

How to exercise your rights. Most rights can be exercised directly in the App. For anything else, email [PLACEHOLDER: privacy@milaki.app]. We will acknowledge your request within 10 days and respond within 30 days, and we will tell you if we need up to 30 more days. Requests are free.

Canada. We handle personal information under Canada’s federal privacy law (PIPEDA). You can ask to see and correct your information, withdraw consent (for example, turn AI help off), and complain to the Office of the Privacy Commissioner of Canada. [COUNSEL: Quebec Law 25; see Notes for counsel.]

Australia. We handle personal information under the Privacy Act 1988 and the Australian Privacy Principles. You can ask to access and correct your information. Your information is disclosed to providers in the United States (see section 8); we take reasonable steps to make sure they protect it (APP 8). If you are not happy with our answer, you can complain to us first, then to the Office of the Australian Information Commissioner (oaic.gov.au). [COUNSEL: whether the small-business exemption applies to ORTHOREP LLC and whether we choose to comply anyway.]

New Zealand. We handle personal information under the Privacy Act 2020. You can ask to access and correct your information. Before we send it to providers outside New Zealand we take steps to make sure it will be protected comparably (IPP 12). You can complain to the Office of the Privacy Commissioner (privacy.org.nz) if we do not resolve your concern.

California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to know, delete, and correct personal information we hold, to opt out of its sale or sharing, and not to be discriminated against for exercising those rights.

We do not sell or share your personal information as those terms are defined by the CCPA/CPRA, and we do not use it for cross-context behavioral advertising.

Categories of personal information collected in the preceding 12 months, only if you sign in or use AI help or the web app: (A) identifiers, limited to your email address, account ID, install ID, and IP address; (F) internet or other electronic network activity information, limited to your learning data that syncs to our servers (progress, typed answers, review history, settings, notes) and technical sync and request records; and geolocation data, limited to approximate location (your country) that we derive from your App Store country or from the IP address of a web request. We do not currently collect commercial information about purchases. We do not collect precise geolocation or biometric information. If you do not sign in, your learning data stays on your device and we do not collect it. We do not sell personal information, including that of consumers under 16. [VERIFY: category list matches what Supabase, Vercel and the AI server actually hold.] [COUNSEL: CCPA category labels and whether typed answers or AI-help text could be sensitive personal information.]

To exercise California rights, email [PLACEHOLDER: privacy@milaki.app].

Additional US State Privacy Rights

Residents of Virginia, Colorado, Connecticut, Utah, Oregon, Texas, and other states with comprehensive privacy laws have similar rights to access, correct, delete, and port personal data, and to opt out of targeted advertising, sale, and profiling. We do not engage in targeted advertising, sale, or profiling with legal effects. To exercise these rights, email [PLACEHOLDER: privacy@milaki.app] and we will respond within the time your state’s law requires. You can use an authorized agent to make a request, and we may need to verify the agent. If we deny a request, you can appeal by emailing us, and you may contact your state attorney general. [COUNSEL: whether ORTHOREP LLC meets any state-law thresholds; appeal wording for states that require one.]

11. Children

Milaki is intended for people 13 or older, as the Terms of Use require, and users under 18 need a parent’s or guardian’s permission. The App does not ask for or verify your age. We do not knowingly collect personal information from anyone under 13. If you believe a child under 13 has used Milaki and that we hold information about them, contact [PLACEHOLDER: privacy@milaki.app] and we will delete any such data we hold. [CONFIRM: App Store Connect age rating must match 13+; Milaki is not in the Kids Category, and the Terms say the same.] [COUNSEL: COPPA posture for a language-learning app that may attract younger users.]

12. Security

• On iPhone, data on your device is protected by Apple’s iOS Data Protection, which encrypts it when the device is locked, and by your device passcode.
• Your sign-in session is stored in your phone’s secure storage (Keychain) on iPhone [VERIFY]. On the web it is stored in your browser.
• Data moves between the app and our servers over encrypted connections (HTTPS).
• Our database allows each account to reach only its own rows. [VERIFY: confirmed against the hosted project after first apply.]
• Our server keys are never inside the app. [VERIFY]
• If you do not sign in, Milaki does not store your learning data on any server.

No security measure is perfect. If a breach affecting personal data we hold were to occur, we would notify you and the relevant authorities as required by law.

Shared devices. If you use Milaki on a shared computer or phone, use "Delete my data on this device" or choose "Remove my work from this device" when Milaki asks at sign-out (the suggested choice on the web). [VERIFY: sign-out behavior fix is built.]

13. Changes and other sites

We may update this Privacy Policy as the App or the law changes. We will post the new version at [PLACEHOLDER: milaki.app/privacy] and update the "Last updated" date. If a change materially affects how personal information is collected or shared, we will tell you in the app or by email before it takes effect. [CONFIRM: notice period.] Milaki links to a few outside sites (for example, Apple). Their privacy rules are their own. [VERIFY: whether the app links out at all.]

14. Contact

Email: [PLACEHOLDER: privacy@milaki.app]

Entity: ORTHOREP LLC, [VERIFY: a Washington limited liability company], [PLACEHOLDER: mailing address]