Privacy Policy

Version 0.2 draft · not yet in force

What we collect on this website, why, and the choices you have.

1. Who is responsible

The controller of your personal data is A-PROMO DIGITAL GROUP LTD, registered in Cyprus under number HE 449235, Pavlou Valdaseridi 2A, 1st floor, 6018 Larnaca, Cyprus.

Support email: support@newlevel.mobi

2. What we collect

  • Quiz answers — the options you choose (for example, your focus, the conversation you want to get right and your preferred rhythm). The Website does not record your voice.
  • Pre-order details — the plan you chose, the amount, the time you agreed to the pre-order terms and the payment provider’s transaction reference. Card details go directly to the payment provider; we never see them.
  • Email — if you pre-order (for your receipt, refund and early-access invite), join the waitlist or agree to a short call.
  • Optional survey answers — if you answer the questions after a pre-order or on the waitlist.
  • Usage data — pages viewed and buttons tapped, a random device identifier and, if you arrived from an ad, the ad click identifier.

3. How we use it

  • to show the concept and the pre-order you chose, and to process and refund pre-orders (to perform our contract with you);
  • to measure whether there is demand for Clearer and improve the Website (our legitimate interest);
  • to email you about your pre-order, the launch or a call you asked for;
  • to measure our ads (with your consent where the law requires it).

Your answers about how you feel in conversations are never sent to advertising platforms. Ad platforms receive only step numbers and conversion events.

4. Who we share it with

  • Payment provider — Stripe, to take and refund payments.
  • Hosting and database — the providers that run the Website and store pre-orders and waitlist entries.
  • Product analytics — to understand how the Website is used.
  • Ad platforms — the platform that showed you an ad receives the conversion events described above.

We do not sell personal data.

5. International transfers

Some of our providers process data outside the European Economic Area. Where they do, we rely on safeguards recognised by law, such as the European Commission’s standard contractual clauses.

6. How long we keep it

We keep your email and chosen plan until we send your early-access invite or, if Clearer does not launch, for no longer than 12 months after the test ends; then we delete them. Payment and refund records are kept as long as accounting law requires. Quiz answers and usage data are kept for no longer than 12 months.

7. Your rights

You can ask us to access, correct, delete or export your data, to restrict or object to its use, and withdraw consent at any time. Write to our support email (support@newlevel.mobi).

You can also complain to the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus — https://www.dataprotection.gov.cy, or to the data protection authority where you live.

8. Children

The Website is not intended for anyone under 18, and we do not knowingly collect their data.

9. Changes

We may update this policy. The version and date at the top show when it last changed.

10. Contact

A-PROMO DIGITAL GROUP LTD, Pavlou Valdaseridi 2A, 1st floor, 6018 Larnaca, Cyprus

Support email: support@newlevel.mobi