1. Scope and relationship to other policies

This Privacy Policy applies to MIHNORYA by LEADER AD, including its learning, career, course, lesson, test, simulation, project, certification, subscription, support, and—where offered—AI mentor, marketplace, or organization features.

This Policy covers processing performed by or specifically through MIHNORYA by LEADER AD. Website visits, Website accounts, checkout, product purchases, downloads, and communications made directly through LEADERAD.site remain subject to the LEADER AD Website Privacy Policy, unless this Policy expressly states otherwise.

2. Who is responsible and how to contact us

For processing under LEADER AD’s control and covered by this Policy, the responsible business is LEADER AD.

Privacy contact: [email protected]
Website: LEADERAD.site
Privacy Center: LEADERAD.site/privacy/

Where a customer uses the product to process information for its own website, business, personnel, learners, clients, visitors, or users, that customer may independently determine the purposes and means of that processing. In that context, the customer is responsible for its notices, instructions, permissions, and lawful basis, while LEADER AD acts only within the role required by the feature, agreement, and applicable law.

3. How MIHNORYA works

MIHNORYA provides multilingual educational and career experiences that may include lessons, tests, projects, simulations, progress tracking, and certificates. Depending on the current plan and release, a user may create an account, enroll in a career or course, submit work, complete assessments, purchase access, communicate with support, or use optional AI, marketplace, or organization functionality. Features described as optional or ‘where offered’ do not represent processing for users who do not use them.

4. Information processed

The information processed depends on the features used, configuration, product version, and the actions requested.

5. How information is obtained

Information may be obtained through the following sources:

• from the learner, buyer, seller, instructor, or organization administrator;
• from learning activity, assessments, project submissions, certificate requirements, and feature use;
• from payment, identity, hosting, email, content-delivery, AI, or marketplace providers used for a selected feature;
• from security, moderation, integrity, diagnostic, and support activity.

We do not infer that optional information is present merely because the product can technically support a related feature.

6. Purposes and legal bases

Information may be processed only as reasonably related to the following purposes:

• create and secure accounts and deliver multilingual learning services;
• provide lessons, tests, projects, simulations, feedback, progress, achievements, and certificates;
• manage enrollments, plans, purchases, subscriptions, refunds, commissions, and entitlements;
• provide optional AI mentor or content-processing features when invoked;
• operate optional marketplace listings, delivery, moderation, payouts, and disputes;
• provide authorized organization dashboards, assignments, and reports where contracted;
• prevent cheating, fraud, abuse, unauthorized sharing, and security incidents;
• improve content, accessibility, reliability, and learner support using proportionate information.

Where applicable law requires a legal basis, processing may rely on one or more of the following, depending on the activity:

• performance of a contract or steps requested before entering into a contract;
• LEADER AD’s legitimate interests in operating, securing, supporting, improving, and protecting the product, provided those interests are not overridden by applicable rights;
• compliance with legal, accounting, tax, security, or regulatory obligations;
• consent, where consent is required or selected by the user; and
• protection of users, systems, property, or legal rights where permitted by law.

The legal basis depends on the specific feature, context, jurisdiction, and information involved. Consent may be withdrawn for future processing without affecting processing already lawfully performed.

7. Information and access not intentionally required

The ordinary operation of this product is not intended to require unnecessary personal or sensitive information.

• MIHNORYA does not require government identifiers, health data, precise location, contacts, camera, microphone, or payment-card numbers for ordinary learning unless a specific disclosed feature genuinely requires them;
• full payment credentials should be collected directly by the selected payment provider;
• users should not include confidential employer, client, or third-party personal information in projects or AI prompts without authority;
• learning records are not sold or used by LEADER AD for unrelated advertising profiles.

Do not submit passwords, secret keys, payment-card numbers, government identifiers, health data, or other sensitive information through ordinary support or description fields unless LEADER AD has specifically requested it through an appropriate secure process and it is genuinely necessary.

8. Learning, assessments, and certificates

Assessment results and completion rules are used to provide feedback, determine whether stated requirements were met, and issue a MIHNORYA credential where offered. MIHNORYA may invalidate, withhold, or review a result where there is reasonable evidence of fraud, impersonation, prohibited assistance, technical error, or violation of program rules.

A MIHNORYA certificate records completion within the platform; it does not automatically represent government accreditation, professional licensure, employment eligibility, or a guaranteed outcome unless an official statement expressly says so.

9. Optional AI, marketplace, and organization features

When AI Mentor or another AI feature is used, the selected prompt and context may be sent to an AI provider. Users must review outputs, which may be inaccurate or unsuitable. AI should not receive secrets or sensitive personal data unless the feature is expressly designed and authorized for that purpose.

Marketplace participants are responsible for having rights to listings and delivered assets. LEADER AD may process moderation, commission, payout, fraud, and dispute records and may remove content or restrict activity that appears unlawful or violates applicable rules.

Where an organization provides access, it may receive progress or activity reports identified in its agreement and notice. MIHNORYA will not treat all personal learning as organization-visible unless the user is enrolled in that organization’s managed program or another disclosed basis applies.

Sharing, service providers, and disclosures

LEADER AD does not sell personal information processed under this Policy. Information may be disclosed only as reasonably necessary for the relevant purpose, subject to suitable safeguards and applicable law.

• instructors, reviewers, mentors, or organization administrators authorized for the relevant learning activity;
• hosting, authentication, email, payment, content-delivery, support, analytics, and security providers acting for LEADER AD;
• AI providers when the user invokes the corresponding feature;
• marketplace buyers, sellers, payment/payout providers, or moderators to complete a transaction or resolve a dispute;
• a public credential-verification recipient only for information intentionally made verifiable and subject to available controls.

Information may also be disclosed when reasonably necessary to comply with law or a valid legal process; protect users, systems, property, safety, or rights; investigate misuse or fraud; enforce applicable terms; or support a merger, financing, acquisition, reorganization, or sale of assets. Any business successor would remain subject to applicable privacy obligations for the information it receives.

International processing and transfers

Service providers, infrastructure, app stores, cloud platforms, or authorized recipients may operate in countries other than the user’s country. Where personal information is transferred internationally, LEADER AD will use the mechanism, authorization, contractual protection, or other safeguard required by the law applicable to that transfer.

A reference to an international provider does not by itself mean that every user’s information is transferred to every location in which that provider operates.

Retention

Information is retained only for as long as reasonably necessary for the purpose for which it was processed, including to provide the product, maintain security and transaction records, resolve disputes, enforce agreements, comply with legal or accounting requirements, and establish or defend legal claims.

• account, enrollment, progress, and achievement records remain while the account or program is active and for a reasonable support or credential-verification period;
• assessment attempts, integrity evidence, and project records may be retained to validate completion and resolve disputes;
• transaction, subscription, commission, and payout records follow accounting, tax, fraud, and legal requirements;
• AI prompts, marketplace content, organization reports, and technical logs follow the retention disclosed for the specific feature and provider.

Retention can vary because local information is controlled by the user or operating system, server logs rotate on different schedules, backup copies expire according to configured cycles, and legal duties may require certain records to be held longer. Information may be deleted, anonymized, aggregated, or isolated when it is no longer required.

Security

LEADER AD uses administrative, technical, and organizational measures selected according to the nature of the product and information involved. Measures may include access controls, separation of duties, authentication, encryption in transit where supported, secure coding and update practices, logging, monitoring, rate limits, integrity checks, and restricted administrative access.

No product, transmission, device, storage system, or security measure can be guaranteed to be completely secure. Users and customer administrators must protect accounts, devices, recovery material, API keys, hosting access, and other credentials under their control; apply updates; limit privileges; review activity; and report suspected compromise promptly.

User and administrator controls

Controls vary by role and feature and may include account settings, content management, communication choices, organization permissions, and privacy requests.

• review and correct profile information;
• manage enrollments, submissions, listings, or account content where the interface permits;
• choose whether to use optional AI or marketplace features;
• manage marketing preferences without disabling required service messages;
• request correction of an assessment record affected by a technical or identity error and seek human review where appropriate;
• request deletion of an account, subject to credential, transaction, integrity, dispute, organization, and legal exceptions.

Removing a local app, disconnecting an integration, or deleting an account does not necessarily erase records that another controller, app store, payment provider, backup destination, or legal obligation independently requires that party to keep.

Privacy rights and requests

Depending on where you live and the law that applies, you may have rights to request access to personal information, obtain a copy, correct inaccurate or incomplete information, object to or restrict certain processing, request deletion where the legal conditions are met, withdraw consent for future processing, and receive certain information in a portable format.

These rights are not absolute. A request may be limited where information must be retained to complete a transaction, protect security, establish or defend legal claims, comply with law, preserve the rights of others, or where another lawful exception applies. We may ask for information reasonably necessary to verify the requester and prevent unauthorized disclosure.

Requests may be sent to [email protected] or through the LEADER AD contact page. We will respond through the appropriate channel and within the period required by applicable law.

Children

MIHNORYA is not intended for unsupervised use below the age at which a person can lawfully consent to the relevant online service. A parent, guardian, school, or organization must provide authorization and notice where required. Marketplace selling, payouts, or contracts may require an adult or other legally capable representative.

If LEADER AD learns that information was collected from a child in circumstances requiring parental authorization and that authorization was not validly obtained, we may delete or restrict the information as required by law. A parent or guardian may contact [email protected].

Automated decisions

MIHNORYA may automatically score objective questions, calculate progress, recommend content, detect integrity signals, moderate content, or generate AI feedback. Important disputes, certificate invalidation, organization decisions, and other significant outcomes should receive appropriate human review. AI output is educational assistance, not professional legal, medical, financial, or employment advice.

Security, fraud, spam, licensing, integrity, or quality systems may automatically flag, limit, queue, or block an event. Where required by law, a person may contact LEADER AD to request appropriate review of a decision producing legal or similarly significant effects.

Changes to this Policy and product evolution

LEADER AD may update this Policy to reflect product changes, new optional features, security improvements, provider changes, or legal requirements. The “Last Updated” date will identify the current published version. Where required, material changes will be communicated through an appropriate product, account, website, store-listing, or direct notice before they take effect.

A future feature is not treated as active processing solely because this Policy explains how it would be handled if offered. If a new feature materially changes data practices, LEADER AD will update the applicable notice and obtain consent where the law requires it.

Contact and interpretation

This Policy is intended to describe actual product data practices in clear language. It does not waive rights that cannot lawfully be waived, create processing that does not otherwise occur, or require publication of private personal details that are not necessary for a valid public notice.