Privacy Policy

Threshold is operated by Threshold, Tajikistan (“we”), who decides why and how your data is processed. This policy explains what we process, on what basis, and how you can control it. It is written for users in any country, including the EU and the UK.

1. Data we process

• Email address — to sign you in with a code and to send service emails.
• Name, if you give one — to address you in the interface and emails.
• Time zone and interface language — for reminder times and the study-day boundary.
• Learning data: completed steps, answers, results of reviews, practice tasks and two-week checks.
• Materials you upload to build your own courses.
• Technical data: session ID, IP address and request times — for security and debugging.
• Payment details: plan, term and subscription status. Paddle takes the payment (see section 4); we do not receive your card data.

2. Why, and on what basis

• To provide the service — sign-in, courses, review schedule, task checking. Basis: performance of a contract (the Terms of Service).
• To send reminders and notifications. Basis: contract; you can switch off the ones you do not need in settings.
• To take payment and keep payment records. Basis: contract and legal obligations.
• To keep the service secure, find bugs, and improve courses in anonymised form. Basis: our legitimate interest.
• To process uploaded materials with AI services. Basis: your consent, given by the checkbox at upload.

3. Automated decisions

AI models check your task answers. The result is a list of criteria you met, used for your learning; it does not affect your legal rights and is not shared with third parties. If you disagree with a check, press “report a problem” or write to us.

4. Who receives data

• Paddle — our reseller and payment processor: it takes payment, calculates taxes and is responsible for your card data. From it we receive your subscription status and the buyer’s email.
• AI model providers (Anthropic, OpenAI) and text-recognition providers (Mistral AI, LlamaIndex) — task answers and uploaded materials, only to generate and check learning content. Your name and email are not sent to them. Who receives uploaded materials and where, is listed on “Processing of uploaded materials”.
• Anyone with the link — only if you made your skill certificate public yourself: the name you entered, the course, the confirmed skills and their dates. We never show your email, the probe tasks or your answers. You can hide the page at any time; search engines do not index it.
• An email service — to deliver messages.
• A hosting provider — to store data.
• Public authorities — only where the law expressly requires it.

We will send you the full list of recipients on request at support@threshold.day. We do not sell personal data and do not share it for advertising.

5. International transfers

We are based in Tajikistan and our providers are in the EU, the US and elsewhere, so your data is processed outside your country. We pass it only to the providers above and only as much as the service needs. For users in the EU and the UK, such transfers rely on the providers’ standard contractual clauses or adequacy decisions.

6. Cookies

We use only strictly necessary cookies that keep your session so you can sign in. There are no advertising or analytics cookies, so no consent banner is needed.

7. Retention

For as long as your account exists. When you delete the account, your profile and learning data are deleted at once; uploaded materials are erased from storage in the background, within 30 days. Payment records are kept by Paddle as long as the law requires.

8. Your rights

• Find out what data we process about you and get a copy.
• Correct your name, time zone and other settings at any time in settings.
• Delete your account and data — in settings or by writing to support@threshold.day.
• Receive your data in a portable format — on request by email.
• Object to processing and withdraw consent — by deleting the account or writing to us.
• Complain to the data protection authority in your country (in the EU, the supervisory authority where you live).

We answer requests within 30 days.

9. Security

Data travels over an encrypted connection, and only people who need it to run the service can reach it. The session is kept in a cookie that page scripts cannot read. If a breach affects your data, we will tell you by email.

10. Children

At sign-up, a user confirms that they are 18 or older, or that a parent or legal guardian agrees to the registration. The service is not intended for children under 13: if we learn that a user is under 13, we delete the account and its data.

11. Changes and contact

We will tell you about material changes by email or in the service. Questions about data processing: support@threshold.day.