Privacy Policy

Introduction

This Privacy Policy describes how CODE D - Web Design and Programming Business (hereinafter "we", "our" or "MrLearny") collects, uses, stores and protects your personal data when using the MrLearny learning platform.

Your privacy is extremely important to us. We are committed to protecting your data in accordance with the General Data Protection Regulation (GDPR) and Croatian data protection laws.

Data Controller Information

What Data We Collect

1. User Account Data

• Name and surname
• Email address
• Password (encrypted)
• Registration date
• Profile preferences

2. Learning Data

• Uploaded educational materials (text, PDF, images)
• Learning history and sessions
• Answers to questions and quiz results
• Progress tracking and statistics
• AI conversation logs

3. Technical Data

• IP address
• Browser type and version
• Device information
• Operating system
• Access times and dates

4. Audio Data (Optional)

• Voice recordings (if you use voice features)
• Speech-to-text transcriptions
• Note: Audio data is processed in real-time and not permanently stored

How We Use Your Data

Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent: You have given explicit consent for processing
• Contract Performance: Processing is necessary to provide our services
• Legal Obligation: We must process data to comply with the law
• Legitimate Interests: Processing is necessary for our legitimate business interests

Third-Party Services

MrLearny uses the following third-party services:

Data Security

We implement comprehensive security measures to protect your data:

Your Rights

Under GDPR, you have the following rights:

Data Retention

We retain your personal data for the following periods:

• Active accounts: Duration of account + 90 days after closure
• Learning materials: As long as your account is active
• Conversation logs: 12 months
• Analytics data: 24 months
• Legal records: As required by law (typically 7 years)

Cookies

MrLearny uses cookies and similar technologies to:

• Keep you signed in
• Remember your preferences
• Analyze platform usage
• Improve user experience

You can control cookies through your browser settings, but some features may not work properly without them.

Children's Privacy

MrLearny is available for users aged 13 and above. If you are under 18, you should use MrLearny under parental supervision. We do not knowingly collect personal data from children under 13.

If you believe we have inadvertently collected data from a child under 13, please contact us immediately at info@codedesign.hr.

International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States (OpenAI services). We ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions
• Binding corporate rules

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new policy on this page
• Updating the "Last Updated" date
• Sending you an email notification (for significant changes)

Contact Us

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

Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP):