PRIVACY POLICY Croatia My Love IP LLC · www.croatiamylove.com · www.myfamilylearnscroatian.com · Effective Date: September 3, 2026 Summary. Croatia My Love is a Croatian language learning service for families. An adult holds the account; children take part through profiles that adult creates and controls. We do not sell personal information, we do not show advertising, we do not use your information to train artificial intelligence models, and we do not record live lessons. This summary is for convenience only and does not vary the sections below. If you read one section, read Section 12, which covers children.
1. Introduction and Acceptance
This Privacy Policy explains how IP LLC collects, uses, discloses and protects information in connection with the Croatia My Love service. It applies to the websites, applications and features described in Section 4. By creating an account, using the Service, or booking a live lesson, you confirm that you have read and understood this Policy. Where we rely on your consent, we ask for it separately and you may withdraw it as described in Section 21. If you do not agree with this Policy, please do not use the Service. This Policy is incorporated into our Terms of Service. Defined terms used here have the meaning given to them in the Terms of Service unless stated otherwise.
2. Who We Are
IP LLC is a limited liability company formed in the State of Wyoming, United States. We operate the Croatia My Love service, marketed at www.croatiamylove.com and delivered at www.myfamilylearnscroatian.com. In this Policy, Croatia My Love, the Company, we, our and us all mean IP LLC. We are the controller of the personal information described in this Policy. You can contact us about anything in it at main@myfamilylearnscroatian.com. Both web addresses belong to us and refer to the same Service. Correspondence from us will come from the myfamilylearnscroatian.com domain.
3. Scope of This Policy
This Policy covers information we collect from and about account holders, family member profiles including children, tutors who offer lessons through the platform, and visitors to our websites. It does not cover the independent privacy practices of the service providers listed in Section 17, each of which handles information under its own terms in addition to its agreement with us. It does not cover any website or service you reach by a link from ours. It does not cover what a tutor does with information outside our platform in breach of their obligations to us, although we will act on any such breach that is reported to us.
4. What the Service Includes
The Service has two parts, and they handle information differently. Where a section below applies to only one of them, we say so. Self-paced learning. A structured Croatian curriculum covering A1 to B2, interactive exercises, family progress tracking, a pronunciation trainer, a built-in translator, native Croatian voice audio and an AI tutor. No other person is involved. Live Lessons. Optional one-to-one video lessons with an independent Croatian tutor, booked and paid for through the Service and held in a video room we create. Where the learner is under 18, a supervising adult must be present throughout.
5. Information You Provide to Us
5.1 Account information
Your email address, and a password which we store only as a secure cryptographic hash and never in readable form Your family name, and the display name and family role of each profile you create, for example Rafael, Son Your time zone, so that lessons are scheduled correctly
5.2 Payment information
Payments are processed by Stripe. We do not receive, hold or store your full card number or bank details. We receive a record that a payment succeeded or failed, the amount, the currency, and the card type and last four digits for display in your own billing history.
5.3 Communications
If you contact us by email or through the Service, we retain that correspondence so that we can respond, resolve the matter and refer back to it if you contact us again.
5.4 Live Lesson information
Booking records: which profile, which tutor, the date, time and duration, the price, the booking status and the applicable time zone Reviews you submit about a tutor, including the rating, your comment and the name displayed against it Reports you make about a lesson, a tutor or a safeguarding concern, in your own words
6. Information We Collect Automatically
Learning activity: lessons completed, exercises answered, XP earned, streak counts and session timestamps Device information: browser type, operating system, device type and language settings Log data: IP address, pages visited, time spent, referring page and error logs Video room participation records: the room identifier associated with a booking, and records of when participants joined and left a lesson We collect this to operate, secure, debug and improve the Service. We do not use advertising trackers, and we do not track you across other websites or services.
7. Local Storage Rather Than Cookies
We use browser localStorage rather than cookies to hold your session token and your display preferences on your own device. This is what keeps you signed in between visits. You can clear this data at any time through your browser settings. Doing so will sign you out and reset your preferences, but will not affect your account or your saved progress, which are held on our servers. We do not use advertising cookies, third-party analytics cookies, pixels or similar tracking technologies. Because we do not track users across sites, we do not respond differently to browser Do Not Track signals.
8. The Pronunciation Trainer
The pronunciation trainer asks permission to use your device microphone so that you can record yourself and compare your pronunciation with a native speaker. Your recording is processed entirely on your own device, in your browser. It is never uploaded to us, never transmitted to any third party, and never stored on our servers. It is analysed locally to produce a score and is discarded the moment you move to another word or close the page. We never receive a copy of your voice, and there is nothing for us to disclose, retain or delete, because it never reaches us. You may decline microphone access and continue using every other part of the self-paced Service, and you may withdraw permission at any time through your browser settings.
9. Live Video Lessons
9.1 How the video room works
Live Lessons are hosted by Daily.co. We create a private room for each individual booking shortly before the lesson begins, and delete it afterwards. During the lesson your audio and video are transmitted through Daily.co so that you and the tutor can see and hear one another, in the same way that a telephone call transmits your voice.
9.2 We do not record Live Lessons
We do not record Live Lessons. This is not a setting we have left switched off. Our rooms are created without recording permission enabled at all, which means no participant can start a recording, including the tutor, including you and including us. No recording of any lesson exists, and there is accordingly nothing for us to store, disclose or delete. Families and tutors are each prohibited by contract from recording, photographing, screenshotting or streaming a lesson by any other means. We cannot technically prevent every such act by a determined participant, and we accept no responsibility for the acts of a user or tutor who breaches that prohibition, but we will act on any report of it. If we ever introduce recording, we will publish a revised Policy explaining what would be recorded, who could access it and for how long it would be retained, and we will obtain fresh consent before any recording takes place. It will not be introduced by a configuration change alone.
9.3 What we retain about a lesson
We retain the booking record described in Section 5.4, the room identifier until the room is deleted, records of when participants joined and left, and anything you or the tutor subsequently submits as a review or a report. We retain nothing about what was said or done during the lesson. We do not monitor lessons while they are in progress and no member of our team joins or observes them.
9.4 Room controls
Rooms are private and expire automatically, removing all participants when they do. Text chat is disabled. A maximum of four participants may join. The tutor must be present before anyone else can enter, so a learner never waits alone in a room with any other person holding a link.
10. The AI Tutor
The Service includes an AI tutor. It is a computer program and not a person, and it is identified as artificial intelligence wherever it appears. Conversations with it are transmitted to Anthropic for processing in order to generate responses. The AI tutor exists for language practice. It is not a companion, a friend, a counsellor or a source of advice on any subject other than learning Croatian, and it must not be relied upon as one. It may produce responses that are inaccurate. We ask that children are not permitted to use it as a confidant. Conversations with the AI tutor, and all other personal information described in this Policy, are not used to train artificial intelligence models. If any conversation raises a concern about a learner's welfare, please contact us or an appropriate support service directly rather than relying on the software to respond.
11. Family Member Profiles
When you add a family member you provide a display name and a family role. That information is stored on our servers to operate the family learning dashboard and to attribute progress correctly. We do not require, request or store the full legal name, date of birth, home address, telephone number, email address, school or photograph of any family member profile. Please do not enter any of that information into a display name field. All profiles on an account belong to the account holder, who controls them and may review, amend or delete them at any time. Family member profiles are not independent accounts, cannot be used to register, pay or book independently, and cannot be transferred to another account.
12. Children
This section is the most important in this Policy and is set out in full rather than summarised.
12.1 How children use the Service
The Service is designed for families and we expect children to use it. Children do not create their own accounts. An adult of 18 or over creates and controls the family account and adds a profile for each child. A child cannot register independently, make a payment, or book a Live Lesson.
12.2 We apply the stricter standard
Because the Service has a children's curriculum, gamified design and is marketed to families, we treat it as directed to children under the Children's Online Privacy Protection Act, and we apply COPPA protections to every child profile rather than only where we have specific knowledge that a particular user is under 13.
12.3 What we collect about a child
For each child profile we collect the display name and family role you provide, the learning activity described in Section 6, and the technical log data associated with the device in use. Where a child takes Live Lessons we additionally hold the booking records described in Section 5.4. We collect no more than is needed to operate the learning experience. We never ask a child for a full name, date of birth, address, telephone number, email address or photograph.
12.4 Verifiable parental consent
We obtain verifiable parental consent before a child profile is used beyond the free introductory content. Where you subscribe or book a lesson, consent is obtained through the payment card transaction processed by Stripe, which notifies you of each individual transaction Where no payment is involved, we use an email-based confirmation process, and features involving disclosure to a third party are restricted until consent by a method permitting such disclosure is obtained Before requesting consent we give you direct notice of what we will collect, how we will use it, the identity of the third parties we will disclose it to, and the purpose of each disclosure. You may consent to our collection and use of a child's information without consenting to its disclosure to a third party, and we will explain what that choice means for the features available.
12.5 Live Lessons and children
A Live Lesson involving a child requires the informed consent of the adult account holder, given at the point of booking. During the lesson the child's image and voice are transmitted live to the tutor through Daily.co. Nothing is recorded and nothing about the content of the lesson is retained. A supervising adult must be present for the entire lesson whenever the learner is under 18. This is a condition of using the Service, a condition of every tutor's agreement with us, and the central protection in our safeguarding model. It is set out in full in our Safeguarding and Child Protection Policy, which we ask every family to read before booking a first lesson.
12.6 Parental rights
As the account holder you may at any time review the information associated with any profile on your account, request that we delete a profile and everything associated with it, refuse to permit any further collection for that profile by deleting it or closing the account, and consent to collection and use without consenting to third-party disclosure. Contact main@myfamilylearnscroatian.com. We will verify that you are the account holder before acting on any request, will respond within 30 days, and will not charge you for exercising any of these rights.
12.7 If a child has registered independently
If you believe a child under 13 has created an account without a parent, contact us at main@myfamilylearnscroatian.com and we will delete the account and its associated information.
13. Information About Tutors
This section concerns tutors rather than families. Identity. Tutors onboard through Stripe Connect Express. Stripe collects and verifies government identification and bank details directly. We never see or store those documents. We receive from Stripe only confirmation of whether an account is verified and enabled for payouts. Profile. Name, biography, languages, rate, photograph and introduction video, each reviewed by a person before publication. Photographs and uploaded documents are stored with Cloudflare R2 and introduction videos with Cloudflare Stream. Qualifications. Where a tutor claims a qualification they upload the certificate and a member of our team verifies it. We then delete the document and retain only the claim, the outcome, the identity of the person who decided and the date. Operational records. Bookings, payouts, reviews received, reports made about them, and an append-only log of approvals, suspensions, rate changes and decisions about profile media. We do not carry out criminal record checks on tutors. Our approach is explained in Section 12.5 above and in full in our Safeguarding and Child Protection Policy.
14. How We Use Information
To create, operate and secure your family account and to authenticate you To deliver and personalise the learning experience and to track progress, XP and streaks across devices To operate the marketplace: publishing tutor profiles, taking bookings, creating video rooms and paying tutors To process payments, refunds, reversals and payouts through Stripe To send transactional messages including password resets, booking confirmations, reminders, renewal notices and receipts To keep the Service safe: investigating reports, suspending accounts, preventing fraud and abuse, and protecting children To maintain, debug and improve the Service and to develop new features To establish, exercise or defend legal claims, and to enforce our Terms of Service To comply with legal obligations, including the retention of payment and tax records
15. Legal Bases for Processing
Where the General Data Protection Regulation or UK data protection law applies to you, we rely on the following legal bases: Performance of a contract: creating and operating your account, delivering lessons, managing bookings, taking payment and paying tutors Consent: microphone access for the pronunciation trainer, and participation in a Live Lesson. You may withdraw consent at any time, which does not affect processing carried out beforehand Legitimate interests: securing the Service, investigating reports, preventing fraud and abuse, debugging and improving the Service, and defending legal claims. We have considered your rights and freedoms in each case and you may object as described in Section 21 Legal obligation: retaining payment and tax records and responding to lawful requests from authorities Vital interests: acting on information indicating that a child is at risk of harm
16. What We Do Not Do
We do not sell personal information, and have never done so We do not share personal information for cross-context behavioural advertising We do not display advertising in the Service or share information with advertisers We do not use personal information to train artificial intelligence models We do not record Live Lessons We do not use automated decision-making that produces legal effects or similarly significant effects. Two routine actions are automatic, and we would rather name them than let the sentence above imply otherwise. First, a safeguarding report suspends a tutor immediately, before any person has reviewed it — this is a precaution, not a finding, and a person decides what happens next. Second, payment for a lesson is released automatically once the three-day reporting window closes with no problem reported. Every decision that permanently removes a tutor, withholds payment, or resolves a dispute is made by a person
17. Service Providers and Disclosure
We disclose information only to the service providers below, and only to the extent each needs it to perform its function for us. Each is bound by contract to protect it and to use it only on our instructions. Stripe: payments, refunds, tutor identity verification and payouts. Receives payment information, and for tutors the identity and bank details Stripe collects directly Daily.co: hosting Live Lessons. Receives live audio and video during a lesson and the room identifier. Receives no recordings, because none are made Anthropic: powering the AI tutor. Receives the content of AI tutor conversations Google Cloud: text-to-speech audio. Receives lesson text for conversion to audio MyMemory: the built-in translator. Receives text you enter into the translator Cloudflare R2: storage of tutor photographs and uploaded documents Cloudflare Stream: hosting of tutor introduction videos Railway: application and database hosting. Processes service data as our infrastructure provider Resend: transactional email delivery. Receives email addresses and message content A note on the translator. Text you enter into the translator is transmitted to MyMemory to be translated. Translation is integral to a language learning service, which is why it does not require separate consent, but please do not enter sensitive personal information into it. We will also disclose information where we are required to by law or valid legal process, where necessary to enforce our Terms of Service, where necessary to establish or defend legal claims, and where we believe in good faith that disclosure is necessary to protect a child or any person from harm. If our business is sold, merged or otherwise transferred, personal information may transfer as part of that transaction. We will notify you before it takes effect and you will have the opportunity to delete your account first.
18. International Transfers
We are based in the United States and our service providers process information principally in the United States. Some of our tutors are located in Croatia and elsewhere in Europe, so where you book a lesson with such a tutor, the information necessary to deliver that lesson reaches them there. Where we transfer personal data out of the European Economic Area, the United Kingdom or Switzerland, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum where applicable. You may request further information about these safeguards using the contact details in Section 25.
19. Data Retention
We keep information only for as long as we need it for the purposes described in this Policy, or for as long as the law requires. In practice: Account and learning progress: for as long as the account remains active All account information after you delete your account: deleted within 30 days, subject to the exceptions below Payment and tax records: 7 years, as required by law Booking records and participation records: 3 years from the date of the lesson Video room identifiers: until the room is deleted following the lesson Incident and safeguarding reports and related decisions: 7 years, given that they may concern a child Reviews: for as long as the tutor profile remains published, then deleted or anonymised Tutor identity and qualification documents: deleted immediately upon verification Tutor audit log: 7 years We keep children's information only for as long as reasonably necessary to fulfil the purpose for which it was collected, and delete it when that purpose is complete. We do not retain it indefinitely. We may retain information beyond these periods where necessary to comply with a legal obligation, to establish, exercise or defend a legal claim, or where we are on notice of an actual or anticipated dispute or investigation.
20. Security
We maintain a written information security programme with safeguards appropriate to the sensitivity of the information we hold. These include encrypted connections using HTTPS and TLS, passwords stored only as bcrypt hashes, access-controlled databases, restriction of staff access to what each person needs, deletion of verification documents upon completion, and periodic review of the security arrangements of our service providers. You are responsible for keeping your account credentials confidential and for all activity under your account. Please notify us immediately if you suspect unauthorised access. No system of transmission or storage is completely secure, and we cannot guarantee absolute security. Where a breach affects your personal information, we will notify you and the relevant supervisory authorities as and where required by law.
21. Your Rights and How to Exercise Them
Depending on where you live, you may have the right to access the personal information we hold about you, to correct it, to delete it, to obtain a portable copy, to restrict or object to certain processing, to withdraw consent, and to appeal a decision we make on a request. To exercise any right, contact main@myfamilylearnscroatian.com. We will take reasonable steps to verify your identity, which may include confirming control of the account email address. We respond within 30 days, or such shorter period as the law requires, and we may extend that period where permitted, in which case we will tell you. We do not charge for responding to requests, and we will never deny service, change prices or provide a different quality of service because you exercised a right. We may decline a request that is manifestly unfounded or excessive, or where an exception applies, and we will explain our reasons if we do. An authorised agent may submit a request on your behalf with written proof of authority.
22. California Residents
We do not sell personal information and we do not share it for cross-context behavioural advertising, as those terms are defined under California law, and we have not done so in the preceding 12 months. We do not knowingly sell or share the personal information of consumers under 16. California residents may request to know the categories and specific pieces of personal information we have collected, the sources, the purposes and the categories of third parties to whom it was disclosed; request correction of inaccurate information; request deletion; limit the use of sensitive personal information; and appeal a refusal. The categories of personal information we collect are identifiers, commercial information, internet and device activity, audio and visual information in the limited form described in Sections 8 and 9, and inferences drawn about learning progress. The categories of sources, purposes and recipients are described in Sections 5, 6, 14 and 17. Certain obligations under California law apply only to businesses meeting defined revenue or volume thresholds, which we may not currently meet. The rights described above are available to California residents regardless.
23. Other United States State Privacy Rights
Residents of other states with comprehensive privacy legislation may have equivalent rights of access, correction, deletion, portability, appeal and opt-out of targeted advertising, sale and profiling. We do not conduct targeted advertising, do not sell personal information and do not engage in profiling producing legal or similarly significant effects, so those particular opt-outs do not arise. The remaining rights are exercised as described in Section 21. Some states also impose design and default-setting duties in relation to services likely to be accessed by children. Our practices are described in Sections 11, 12 and 16 and are designed to meet those expectations.
24. Changes to This Policy
We may update this Policy from time to time. Where a change is material, we will notify you by email and post the updated Policy before it takes effect, and we will update the Effective Date above. We will not apply a materially different use to information already collected without first obtaining any consent required by law. Your continued use of the Service after a change takes effect constitutes acceptance of the updated Policy, except where consent is required.
25. Contact Us
IP LLC Email: main@myfamilylearnscroatian.com Websites: www.croatiamylove.com and www.myfamilylearnscroatian.com State of formation: Wyoming, United States If you are in the European Union or the United Kingdom and believe we have handled your personal data improperly, you may lodge a complaint with your local supervisory authority. In the United Kingdom this is the Information Commissioner's Office at www.ico.org.uk. We would appreciate the opportunity to address your concern first.