Trust
Privacy Policy
Maya is available worldwide. This policy explains what we collect, why, who we share it with, and the rights you have under the laws of the country where you are — including children.
Effective 14 August 2026
1. Who we are and what this covers
The operator is Michal Topchiashvili (“we”), resident in Israel. The product is Maya — website, iOS app, and PWA. The public site is https://michaltopch1-bit-craft-your-teacher.cleomare.workers.dev. The service is offered worldwide, not only in Israel.
If the law of your country of residence gives stronger protection, that stronger protection prevails. Nothing here waives a non-waivable consumer or child right.
2. Which laws may apply
Depending on where you are, the following may apply: GDPR (EU), UK GDPR and the Age Appropriate Design Code (UK), COPPA and FERPA (US; FERPA applies to schools — we are not a school), CCPA/CPRA (California) and other US state laws, LGPD (Brazil), PIPEDA (Canada), the Privacy Act (Australia), APPI (Japan), PDPA (Singapore), POPIA (South Africa), PDPL (UAE and Gulf), and Israel’s Protection of Privacy Law. We design the product to the stricter child-protection standard among them.
3. What we collect
On the device: a name the parent or child chooses, room progress, mastered topics, language, accessibility, consent choices, and a device id. No account is required to start.
From the parent: an email address to verify consent and to pause AI. We do not collect a child’s email.
When you ask for an AI lesson or voice: the text, photo, or recording is sent to the AI provider to generate that response. We do not keep photos or voice clips after the request finishes.
Payment: if you buy Maya Plus, Apple or Stripe (depending on the platform) process the payment method. We receive subscription status, not the card number.
Short-lived technical server logs (IP address, browser type, errors) to run security and fix failures — not for advertising profiles.
4. Why we use it
To run the room and catalog, fit language and age, let a parent approve or pause AI, generate a lesson or voice when asked, bill a subscription, prevent abuse, and comply with law.
There are no ads inside the lesson. We do not sell personal information. We do not do behavioral tracking for ads.
5. Legal bases (GDPR / UK GDPR and equivalents)
Contract: running the service you asked for. Legitimate interests: security, fraud prevention, reliability — balanced against children’s rights. Legal obligation: authority requests and accounting. Consent: parental verification for AI, any future non-essential cookies, and parent email. You may withdraw consent at any time without affecting lawfulness before withdrawal.
6. Children worldwide
Maya is for children with a parent nearby. The digital age of consent varies: in the US, COPPA applies under 13; in the EU the default is 16 unless a member state lowered it to 13; in the UK the Age Appropriate Design Code also applies. We require parent verification for every product age band (including 13–17) before AI unlocks on the server — stricter than the floor in some countries.
Full parent detail: the Children’s Privacy Notice. We are not a school and we do not keep a FERPA “education record.”
7. Who we share with
Cloud and hosting (Cloudflare, Vercel), optional database (Supabase), parent email, AI providers (Google, Anthropic, OpenAI / Lovable gateway) only when you ask for a lesson or speech, and payment providers (Apple, Stripe). They process under our instructions and their contracts. List: Subprocessors.
We disclose information if the law requires it, to protect a child from harm, or in a sale/reorganization of the operation — with the same restrictions.
8. International transfers
Servers and vendors may be in the US, Europe, or elsewhere. When GDPR or UK GDPR apply, we rely on adequacy decisions and/or Standard Contractual Clauses (SCCs) plus vendor restrictions. Request a copy via the email below.
9. How long we keep it
The room stays on the device until you delete it. A cloud sync copy — while the device is active or until deletion. Technical logs — a few days unless a security investigation. Subscription status — as required for accounting and local tax law. Lesson photos/voice — not kept by us after the request.
10. Your rights by region
Everywhere: access, correct, delete (“Forget everything” on the memory screen + a parent request), and object to processing that is not necessary.
EEA/UK: also restriction, portability, and withdrawal of consent. Complain to your local data-protection authority (e.g. CNIL, ICO, BfDI). We have not yet appointed an Art. 27 EU/UK representative; if required, we will post an address here.
California and other US state privacy laws: we do not sell or “share” information for cross-context advertising. You may request to know, delete, and correct. We will not discriminate against you for exercising a right.
Brazil (LGPD), Canada, Australia, Japan, Singapore, South Africa, the Gulf: the same requests via email. We will respond under local law.
11. Security
HTTPS, an HttpOnly session cookie on the web, a device secret, and parent verification on the server before AI. No security is perfect. If a breach must be notified under the law of your country, we will notify as required.
12. Cookies
Essential cookies for running the app and sign-in. Google Fonts load from Google’s servers. No advertising cookies. Details: Cookie Policy.
13. Changes
If we make a material change, we will update the date at the top and, where needed, email the parent. Continued use after that date accepts the new version, unless the law of your country requires fresh consent.
14. Contact
Privacy and rights requests worldwide: michaltopch1@gmail.com. Parent controls: /parent on the site.
Contact
US COPPA product checklist
7 of 8 controls shipped
✓ Age band before AI
Onboarding collects under-13 / 13–17 only (product age ranges 5–17). Forged 18plus claims are coerced server-side to under13.
✓ Parent acknowledgement + email verify
All product age bands stay pending_parent until parent email verify. Continue requires email sent (or verified), not checkbox alone. Client AI waits for serverStatus=allowed. Parent email requests require deviceId + deviceSecret.
✓ AI notice
Learners acknowledge that lessons are generated by AI and can be wrong.
✓ Local delete
Hard wipe clears maya.* keys, consent, analytics, and device session, and deletes server device_guards / platform rows for that device when authorized.
✓ Published privacy page
The /privacy route is a parent-facing policy: who collects, what, AI processors, retention, and delete.
✓ Verifiable parental consent (email/SMS)
Parent magic-link is emailed only to the parent mailbox; consuming it stamps a server consent ledger for that device. All product age bands (under13 / 13to17) stay pending until verify. Production AI calls require status=allowed. Demo verify is gated behind ALLOW_DEV_AUTH_LINKS.
○ Parent email verify (dev stub)
Demo parent verify is disabled unless ALLOW_DEV_AUTH_LINKS=true in non-production.
✓ Account-bound parental controls
Parent magic-link account on /parent lists devices whose consent.email matches, can pause AI (aiPaused), and erase cloud data + queue device wipe. Weekly digest / multi-parent sharing not shipped.
