PRIVACY POLICY

Cruisy — English on the Go

Last updated: [15.09.2026]

1. Introduction

The purpose of this Privacy Policy is to explain how Cruisy (“we”, “our”, or “the Company”) collects, uses, stores, and protects information when you use the Cruisy web application accessible at cruisy.me (the “Service”). Cruisy is a progressive web application (PWA) that helps users practice and maintain their English language skills while driving, commuting, or on the go, through audio lessons, stories, reading, and speaking exercises.

This Privacy Policy is an integral part of the Cruisy Terms and Conditions. By using the Service, you consent to the practices described in this Policy.

2. Legal Compliance

This Policy is intended to comply with applicable Israeli privacy and data protection laws, including:

The Protection of Privacy Law, 5741-1981 (including Amendment No. 13);

The Protection of Privacy Regulations (Data Security), 5777-2017, as may be amended from time to time;

The Protection of Privacy Regulations (Transfer of Data to Databases Outside the State Borders), 5761-2001.

Cruisy is operated by Elena Shamis, an Osek Patur (exempt dealer) registered in Israel. Where we transfer Personal Information outside Israel, we will do so in accordance with applicable requirements under the regulations listed above.

3. Information We Collect

We collect the following categories of information:

3.1 Information You Provide

Google Account information: When you sign in via Google Login, we receive your name, email address, and profile picture as provided by Google.

Telegram: When you sign in through the Cruisy Telegram Mini App, or through the Telegram Login Widget on our website, Telegram sends us verified account data. This data may include your Telegram user ID, first name, last name (if available), username (if set), profile photo URL (if available), and authentication timestamp (auth_date); in the Mini App it may also include optional session fields such as query_id and start_param when Telegram includes them. We verify this data using Telegram’s protocol and use it to create or link your account, to store your Telegram identity for future logins, and to display your name and avatar in the Service.

3.2 Usage and Progress Data

Lesson history: which lessons you have listened to, completed, or started;

Learning progress and statistics (e.g., completion rates, levels achieved);

Interaction data within the application (e.g., selected preferences, language level, interests).

3.3 Technical Data

IP address;

Device type, operating system, and browser information;

Identifiers stored in cookies or similar technologies, including an anonymous analytics identifier generated on your device (we do not use advertising identifiers).

Certain technical data and online identifiers listed above may be considered “Personal Information” under applicable law.

3.4 Voice Data

In speaking exercises (such as reading aloud, shadowing, and spoken test answers), the Service processes your voice input in order to recognize your speech and check your spoken answers. Voice input is processed in real time within the session. Voice recordings are not retained after the session ends; the recognized text (transcript) of your spoken answer may be stored as part of your learning progress so that you can track and review your practice.

3.5 Payment Information

When you purchase paid access, payment is handled by our third-party payment provider, AllPay (Allpay Ltd.). Cruisy does not collect or store your payment card or other financial account details. We receive from the payment provider only confirmation of the payment status and limited transaction details (such as an order reference, the amount and currency, a transaction identifier, and the email address you provide at checkout). Your payment information is processed by the payment provider under its own terms and privacy policy.

3.6 Information We Do NOT Collect

At present, users do not upload their own content to the Service. As noted in Section 3.5, we do not collect or store your payment card details directly.

4. Use of Information

The information collected will be used in accordance with this Privacy Policy or in accordance with applicable law, for the following purposes:

To provide, operate, and maintain the Service, including delivering audio lessons and speaking and reading exercises;

To process your purchase of paid access and to grant, manage, and verify your access;

To track your learning progress and personalize your experience;

To improve and develop the quality of the Service, its content, and features, including through analysis of aggregated and anonymized usage data;

For monitoring, analytics, and statistical purposes;

To modify, update, or discontinue existing services and content;

To communicate with you regarding the Service, including service updates and support;

To comply with legal obligations.

5. AI Processing

Cruisy uses third-party AI providers, including OpenAI, to power speech recognition and the automated checking of your spoken answers in speaking and test exercises. When you submit a spoken answer, the audio and/or its transcription is sent to the AI provider for the sole purpose of recognizing your speech and evaluating your answer within that session.

We do not share your personal profile information (name, email) with AI providers. Data sent to AI providers for this purpose is not used by Cruisy for any purpose other than providing the speaking and answer-checking features within your session.

Important: Cruisy is not a certified educational platform. Automated, AI-generated evaluations and feedback may contain inaccuracies. The Service is intended for language practice and maintenance, and should not be relied upon as a source of factual or professional information.

6. Data Storage and International Transfers

Your data is stored and processed using third-party infrastructure and service providers, including but not limited to:

Supabase (database and authentication);

Vercel (application hosting);

OpenAI (speech recognition and answer checking);

AllPay / Allpay Ltd. (payment processing);

PostHog (product analytics);

Google Analytics (traffic and usage analytics).

These providers may store or process data on servers located outside the State of Israel. Any transfer of Personal Information outside Israel is carried out in accordance with the Protection of Privacy Regulations (Transfer of Data to Databases Outside the State Borders), 5761-2001, and any other applicable requirements. We take reasonable steps to ensure that our service providers maintain appropriate levels of data protection.

7. Cookies and Similar Technologies

Cruisy uses cookies and similar technologies (such as pixels, tags, and local storage) on the Service to enable core functionality, enhance user experience, and analyze performance.

7.1 Cookie Categories

Essential (Strictly Necessary): Required to provide the Service you requested, including authentication and security, and to remember the choices you make while using it (for example, your native language, playback settings, and your progress within a lesson). These are always active, because without them the Service cannot deliver what you asked for.

Analytics: Used to understand how the Service is used and to improve it. This covers our own usage statistics and our analytics providers, PostHog and Google Analytics. Analytics identifiers are stored in a first-party cookie and in local storage on your device.

Marketing: Cruisy does not use marketing or advertising cookies and does not run advertising pixels on the Service.

7.2 Consent and Controls

Essential cookies are always active. For Analytics we apply one of two regimes, depending on where you access the Service from:

Where prior consent is required by applicable law (including the European Economic Area, the United Kingdom, and Switzerland), and whenever we cannot determine your location, no analytics identifier is stored and no analytics data is collected until you make a choice in the cookie banner. Declining leaves only Essential cookies in place.

Elsewhere, analytics starts on a notice and opt-out basis: we inform you that anonymised usage statistics are collected and you can switch them off at any time.

In both cases you can change or withdraw your choice at any time through the cookie settings available in the Service (in the account settings screen and at the bottom of this policy). Withdrawing your consent stops analytics collection and deletes the analytics identifiers stored on your device.

We retain a record of your choice, including the date and time and the legal basis on which analytics is running (your explicit choice, or notice and opt-out), in order to demonstrate compliance and to respect your choice.

7.3 Impact of Refusal

Declining Analytics does not limit the Service in any way: lessons, progress, and your settings work exactly the same. It only means we cannot see how the Service is used and improve it based on that usage.

7.4 Third-Party Cookies and Embedded Content

The Service may include third-party services, scripts, and embedded content (for example, analytics or advertising providers). These third parties may set their own cookies and collect data for their own purposes, subject to their own policies, and may act as independent controllers. Where possible, we use privacy-enhanced options to limit cookie usage until you interact with the relevant content.

7.5 Browser Settings

You can also control cookies through your browser settings. However, disabling cookies may affect the functionality of the Service.

8. Sharing Information with Third Parties

Cruisy does not sell your personal information. We will not provide your personal details or information collected about your activity on the Service to third parties, except in the following cases:

Service Providers: We share data with third-party service providers (such as Supabase, Vercel, OpenAI, PostHog, Google Analytics, and our payment provider AllPay) strictly as necessary for them to provide their services to us on your behalf;

Payment Processing: When you purchase paid access, the transaction data necessary to process and confirm the payment is shared with our payment provider (AllPay);

Legal Disputes: In the event of a legal dispute between you and the Company that requires the disclosure of your details;

Violation of Law: If your actions on the Service are in violation of applicable law;

Court Order: If a court ruling or other legal process orders the Company to provide your details or information to a third party;

Business Transfers: If the Company sells, transfers, or merges its operations or the Service with another entity, provided that the receiving entity accepts the provisions of this Privacy Policy towards you.

9. Data Retention

We retain your personal information for as long as your account is active and as necessary to provide you with the Service. Learning progress data is retained to allow continuity of your experience. Transaction and purchase records are retained as necessary to provide access, and for accounting, tax, and legal compliance purposes.

If you request deletion of your account, we will delete or anonymize your personal data within a reasonable timeframe, except where we are required to retain certain information by law or for legitimate business purposes (such as resolving disputes, meeting accounting or tax obligations, or enforcing our agreements).

Voice data, as noted above, is not retained beyond the individual lesson session.

10. Your Rights

Under the Protection of Privacy Law, 5741-1981 (including Amendment No. 13), and other applicable law, you may be entitled to:

Request access to the Personal Information we hold about you;

Request that such information be corrected, updated, or deleted (as applicable);

Object to or request deletion of your information from our databases where it is used for direct marketing purposes.

Requests on this subject should be directed to: elena.v.shamis@gmail.com

We will respond to your request within a reasonable timeframe and in accordance with applicable law.

11. Marketing Communications

If we send you marketing communications (such as promotional emails about the Service), you may opt out at any time by using the unsubscribe link provided in the communication or by contacting us at elena.v.shamis@gmail.com. Opting out of marketing communications will not affect your ability to use the Service.

12. Children and Minors

Cruisy offers content that is suitable for users of all ages, including fairy tales and stories appropriate for children. However, the Service is not directed at children under the age of 13 as independent users.

Children under the age of 13 may use the Service only with the active involvement and supervision of a parent or legal guardian. We do not knowingly collect personal information from children under 13 without parental consent. If we become aware that we have collected personal information from a child under 13 without appropriate parental consent, we will take steps to delete such information.

If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at elena.v.shamis@gmail.com.

13. Data Security

The Company implements up-to-date information security systems and procedures, and acts in accordance with applicable requirements under Israeli law, including the Protection of Privacy Regulations (Data Security), 5777-2017 (as amended).

While these systems and procedures reduce the risks of unauthorized intrusion, they do not provide absolute security. Therefore, the Company does not warrant that the Service will be completely immune from unauthorized access to the information stored therein.

14. Intellectual Property and User Content

All content currently available on the Service (including lessons, stories, audio materials, and interface design) is owned by or licensed to Cruisy.

If, in the future, we introduce a feature that allows users to create lessons from their own content (such as personal texts or materials), such user-generated content will remain the intellectual property of the user who created it. The terms governing user-generated content will be specified at the time such a feature is introduced.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. In the event of material changes to this Policy, particularly regarding the use of personal information you have provided, a notice will be published on the home page of the Service (cruisy.me). We encourage you to review this Policy periodically.

16. External Links

The Service may contain links to external websites owned and operated by third parties. These external services are not covered by this Privacy Policy. We encourage you to review the privacy policies of any third-party services you visit. The Company is not responsible for the privacy practices or content of external websites, or for any interaction between users and such third parties.

17. Contact

If you have any questions or concerns regarding this Privacy Policy or the handling of your personal information, please contact us at:

Elena Shamis

Email: elena.v.shamis@gmail.com

Website: cruisy.me