Introduction
Welcome to Marvely ("we," "our," or "us"). We are committed to protecting and respecting
your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard
your information when you use our language learning application ("Application"), where
users have spoken conversations with AI-powered avatars in immersive scenarios.
Please read this Privacy Policy carefully. By using our Application, you agree to the
terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy,
please do not use the Application.
Information We Collect
We may collect and process the following types of information about you:
Personal Information
- Registration Information: When you register to use our Application, we may collect
personal information such as your name, email address, username, password, and other registration
details.
- Profile Information: You may provide additional information as part of your profile,
such as a profile picture, language preferences, and learning goals.
Usage Information
- Interaction Data: We collect data about your interactions with the AI-powered avatars,
including spoken conversations, responses, and feedback.
- Device Information: We may collect information about the device you use to access
the Application, including the hardware model, operating system, IP address, and device identifiers.
Attribution and campaign measurement
- When you visit Marvely, we may temporarily collect information about how you arrived at our
services, such as the page you landed on, referral or campaign parameters, and limited
technical information about your visit.
- If you move between Marvely services, including games.marvely.ai and www.marvely.ai, we may
use a short-lived one-time attribution token to reconnect that visit information across
our own services.
- If you then create an account or sign in, we may associate this attribution information with
your account so that we can understand which pages and campaigns lead to registrations,
measure the effectiveness of our marketing, and improve our services.
- We use this information for our own attribution and analytics and not for third-party
cross-site profiling.
Audio Data
- Voice Recordings: To facilitate language learning, the Application may collect and
process voice recordings of your spoken conversations with the AI-powered avatars.
How We Use Your Information
We use the information we collect for various purposes, including:
- To Provide and Improve the Application: To operate, maintain, and improve our Application,
including developing new features and functionality.
- To Personalize Your Experience: To tailor the content and interactions to your language
learning preferences and goals.
- To Communicate with You: To send you updates, notifications, and other information
related to your use of the Application.
- For Research and Development: To analyse usage patterns and improve our AI algorithms
and language learning models.
- To Ensure Security: To detect, prevent, and respond to fraud, abuse, security risks,
and technical issues.
How We Share Your Information
We do not sell or rent your personal information to third parties. We may share your
information in the following circumstances:
- Service Providers: We may share your information with third-party service providers
who perform services on our behalf, such as data storage, analytics, and customer support.
In particular we use various AI API services to deliver the AI features of this application
including the APIs of OpenAI, ElevenLabs and others.
- Legal Requirements: We may disclose your information if required to do so by law or
in response to a legal request, such as a subpoena, court order, or government investigation.
- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion
of our assets, your information may be transferred as part of the transaction.
Data Security
We implement appropriate technical and organisational measures to protect the personal
information we collect and process. However, no data transmission over the internet or
electronic storage is completely secure, and we cannot guarantee the absolute security of
your information.
Data Retention
We will retain your personal information for as long as necessary to fulfill the purposes
outlined in this Privacy Policy, unless a longer retention period is required or permitted
by law.
Cookies and Tracking Technologies
Cookies
Our Application may use cookies and similar tracking technologies to enhance your
experience. Cookies are small data files that are placed on your device or computer and
often include an anonymous unique identifier. We use cookies to collect and store
information about how you use the Application.
Types of Cookies
- Essential Cookies: These cookies are necessary for the Application to function and
cannot be switched off in our systems.
- Performance Cookies: These cookies allow us to count visits and traffic sources so
we can measure and improve the performance of our Application.
- Functional Cookies: These cookies enable the Application to provide enhanced functionality
and personalization.
Managing Cookies
You can choose to accept or decline cookies. Most web browsers automatically accept
cookies, but you can usually modify your browser settings to decline cookies if you
prefer. However, this may prevent you from taking full advantage of the Application.
International Data Transfers
We may transfer your personal information to countries other than the country in which you
are located. These countries may have data protection laws that are different from the
laws of your country.
Data Transfer Agreements
When we transfer your personal information internationally, we will take appropriate
measures to ensure that your information remains protected in accordance with this Privacy
Policy. This includes implementing standard contractual clauses approved by the European
Commission or relying on other lawful transfer mechanisms.
Legal Basis for Processing Personal Information
We are a UK based company and under the UK GDPR, we must have a valid legal basis to
process your personal information. We rely on the following legal bases:
- Consent: Where you have given explicit consent for us to process your personal
information for specific purposes.
- Contract: Where the processing is necessary for the performance of a contract
with you or to take steps at your request before entering into a contract.
- Legal Obligation: Where the processing is necessary for compliance with a legal
obligation to which we are subject.
- Legitimate Interests: Where the processing is necessary for our legitimate
interests, provided that these are not overridden by your rights and interests.
Your Rights Under UK GDPR
In addition to the rights mentioned earlier, you have specific rights under the UK GDPR,
including:
- Right to Withdraw Consent: Where we rely on your consent to process your personal
information, you have the right to withdraw your consent at any time.
- Right to Object: You have the right to object to the processing of your personal
information where we are relying on legitimate interests as the legal basis.
- Right to Data Portability: You have the right to receive your personal
information in a structured, commonly used, and machine-readable format and to request
that we transfer this information to another organisation.
- Right to Restrict Processing: You have the right to request that we restrict the
processing of your personal information in certain circumstances.
To exercise these rights, please contact us at support@zzish.com
Children's Privacy
Our Application is not intended for use by children under the age of 13. We do not
knowingly collect personal information from children under 13. If we become aware that we
have collected personal information from a child under 13, we will take steps to delete
such information from our records.
Data Protection Officer
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing
questions in relation to this Privacy Policy. If you have any questions about this Privacy
Policy or our data protection practices, please contact our DPO:
Charles Wiles
Zzish Limited, 118a East Barnet Road, Barnet, England, EN4 8RE
support@zzish.com
Third-Party Links
Our Application may contain links to third-party websites or services that are not owned
or controlled by us. We have no control over, and assume no responsibility for, the
content, privacy policies, or practices of any third-party websites or services. We
encourage you to review the privacy policies of any third-party websites or services that
you visit.
Complaints
If you have any concerns about our use of your personal information, you can make a
complaint to us at [Contact Information]. You also have the right to lodge a complaint
with the Information Commissioner’s Office (ICO), the UK supervisory authority for data
protection issues:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9
5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by
posting the new Privacy Policy on this page. You are advised to review this Privacy Policy
periodically for any changes. Changes to this Privacy Policy are effective when they are
posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us at:
Zzish Limited, 118a East Barnet Road, Barnet, England, EN4 8RE
support@zzish.com
By using our Application, you acknowledge that you have read and understood this Privacy
Policy. Thank you for choosing Marvely for your language learning journey.