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Privacy Policy

Clariora A+ (also called Clariora)
Last updated: 10 September 2026
Controller: Datacentre Academy / Luminara Digital
Contact: support@datacentre.academy
Product URLs: https://clariora.com.au/ · Telegram Mini App via @ClarioraBot

Plain summary. Core study progress stays on your device by default. We do not sell personal information. Optional features (Telegram identity, Stars/TON purchases, Ghost Coach AI, optional cloud account sync) process additional data only when you use them. This policy describes those flows accurately so you can decide what to turn on.

Contents

  1. Who we are
  2. Scope of this policy
  3. Telegram Mini App specifics
  4. What we collect and why
  5. On-device and Telegram CloudStorage data
  6. Server-side processing (Cloudflare)
  7. Ghost Coach AI
  8. Payments (Telegram Stars and TON)
  9. Optional accounts and cloud sync
  10. Telemetry and product analytics
  11. Third parties
  12. Legal bases and Australian Privacy Principles
  13. Retention
  14. Your rights and choices
  15. Security
  16. Children
  17. International transfers
  18. No sale of personal information
  19. Changes
  20. Contact and complaints

1. Who we are

Clariora A+ is an educational CompTIA A+ exam simulator and study product operated by Datacentre Academy / Luminara Digital ("we", "us", "our"). CompTIA® and A+® are trademarks of CompTIA. Clariora is independent and is not affiliated with, endorsed by, or sponsored by CompTIA or Pearson VUE.

We are the organisation responsible for deciding how personal information is handled in connection with Clariora (the "controller" / APP entity for Australian Privacy Principles purposes, where those laws apply).

2. Scope of this policy

This Privacy Policy applies to:

It does not govern Telegram Messenger itself, CompTIA, Pearson VUE, payment networks, AI model hosts, or other third-party sites you may open from Clariora. Those services have their own policies.

By using Clariora you acknowledge this policy. If you do not agree, do not use the product. Where a feature requires consent under applicable law, we ask for that consent separately (for example optional telemetry upload).

3. Telegram Mini App specifics

When you open Clariora as a Telegram Mini App, Telegram provides certain data to third-party Mini Apps under the Telegram Mini Apps Terms. According to Telegram, that typically includes your IP address as seen by the Mini App host, and may include your Telegram user id, public name, username, profile picture, client language tag, Telegram Premium status, and theme colour parameters.

Clariora uses that platform data as follows:

Clariora is a third-party service independent of Telegram. Telegram is not responsible for how we handle data once it is shared with us. Registering this policy URL in @BotFather makes it available from the Mini App Settings privacy button.

4. What we collect and why

Category Examples Purpose When
Study progress (on device) Exam history, missed questions, flashcard / curriculum progress, theme, tutor mode, local profiles, proof-of-mastery ledger Operate the simulator, readiness scores, spaced practice Always for core use (stays local by default)
Telegram identity Telegram user id, username, first/last name; verified initData Authenticate Mini App sessions; entitlements; abuse prevention When you open the Mini App and when server features need identity
Purchase and entitlement records Product id, Stars amount, Telegram payment charge id, TON tx hash / wallet address, tier and expiry Fulfil digital goods; prevent double-spend; support refunds via Telegram rules Only if you buy or restore a paid tier
AI coaching content Question text, options, your chosen answer, official explanation snippets, provider choice Generate Ghost Coach remediation; enforce free daily quotas Only when you invoke Ghost Coach online
Optional account sync Email / Google / Firebase uid; learner snapshot you choose to sync; Telegram Login Widget profile if used Optional cross-device restore you explicitly enable Only if you sign in / sync (off by default)
Technical logs IP address and request metadata at our host; AI latency; error diagnostics Security, rate limits, reliability When your client talks to our Worker or CDN
Support communications Email address and message content you send to support Respond to requests and complaints Only if you contact us
Optional anonymous telemetry Install id (random), session events, feature counts (no question text, names, or email) Improve product quality Stored locally; uploaded only if we enable a remote endpoint and you consent in Settings

We do not collect government ID, biometric templates, precise geolocation, payment card PANs, or advertising identifiers for cross-app tracking.

5. On-device and Telegram CloudStorage data

Clariora is local-first. Core simulator state is stored in browser localStorage (or equivalent desktop storage) on the device you use. Clearing site data, uninstalling, or switching devices without an export will lose that local progress.

You can export / import a learner backup or sync file from the app when that feature is available. Those files are under your control; if you share them, anyone with the file can read the study data inside.

Inside Telegram, we may also use Telegram CloudStorage for selected keys so progress survives Mini App reloads. Telegram's handling of CloudStorage is governed by Telegram's own terms and privacy policy.

6. Server-side processing (Cloudflare)

Our public web app and API are hosted on Cloudflare (Workers, static assets, and D1 database). When your client calls our API (for example /api/v1/coach, Stars invoice creation, TON confirmation, optional learner sync, Telegram webhook), Cloudflare and our Worker process the request, including standard network metadata such as IP address.

Database tables may include Telegram user records, Stars/TON transaction records, AI usage counters/logs, and optional learner sync blobs keyed to a user id. We use this data to provide the feature you requested, prevent abuse, and keep purchase state consistent.

7. Ghost Coach AI

Ghost Coach is optional. Offline fallbacks can show local explanations without calling a model host. When you use online coaching:

Model hosts are independent controllers/processors for the prompts they receive. Their retention and training policies are outside Clariora's control; review their documentation if that matters to you before using online coaching.

8. Payments (Telegram Stars and TON)

Telegram Stars (XTR)

In-app digital unlocks inside Telegram are fulfilled through Telegram Stars. Telegram and its payment partners process the Stars transaction. We receive payment confirmation metadata (for example product id, Stars amount, Telegram user id, payment charge id / invoice payload) so we can unlock features. We do not receive or store your card number.

TON

If you pay with TON, public blockchain data (transaction hash, amount, wallet address you used) is inherently public on the TON network. We store references needed to confirm payment and grant entitlements. Blockchain records cannot be deleted by us.

Refunds and chargebacks for Stars follow Telegram's rules and tools. Contact us at the email below if you need help matching a purchase to your entitlement.

9. Optional accounts and cloud sync

You can use Clariora without creating an account. Optional sign-in (for example Firebase Authentication with email/password or Google, or Telegram Login) is available so you can sync learning state if you choose.

10. Telemetry and product analytics

Clariora can record anonymous product-usage events in a local buffer (random install id, session timing, feature events). By design it excludes names, emails, question text, answer text, and free-form input.

Upload is off by default. Nothing is sent to a remote telemetry endpoint unless (1) we configure an HTTPS endpoint and enable upload in product configuration, and (2) you explicitly consent via the in-app "Share anonymous usage data" control. You can withdraw consent in the same place. Until both conditions are true, telemetry stays on device.

11. Third parties

Depending on which features you use, personal information may be processed by:

We do not sell personal information to data brokers. We do not allow third parties to serve third-party behavioural advertising inside the core simulator based on your study content.

13. Retention

14. Your rights and choices

Subject to applicable law, you may request to:

Email support@datacentre.academy with the subject line "Clariora privacy request" and include your Telegram user id if the request relates to Mini App entitlements. We aim to respond within 30 days (or sooner if local law requires).

You can also:

15. Security

We use HTTPS for our hosted app and API, verify Telegram initData signatures before trusting Mini App identity, and restrict server writes to feature-related tables. No method of transmission or storage is perfectly secure. You are responsible for securing devices you use and for not sharing exported backup files.

16. Children

Clariora is aimed at career starters and adult learners preparing for professional certification. It is not directed at children under 13. If you are under the digital age of consent in your country, use Clariora only with permission of a parent or guardian where required. If you believe we have collected personal information from a child contrary to law, contact us and we will take appropriate steps to delete it from systems we control.

17. International transfers

We operate with Australian-facing branding and support. Infrastructure providers (including Cloudflare and optional Google Firebase / AI hosts) may process data in the United States, European Economic Area, or other countries. Where required, we rely on appropriate safeguards offered by those providers (for example standard contractual clauses) and on your instructions when you choose features that necessarily call those regions.

18. No sale of personal information

We do not sell personal information. We do not share personal information for cross-context behavioural advertising of the kind regulated as a "sale" or "share" under California CPRA-style laws. If that ever changes, we will update this policy before it happens and provide any required opt-out.

19. Changes

We may update this Privacy Policy to reflect product or legal changes. The "Last updated" date at the top will change when we do. Material changes will be posted at this URL. Continued use after the effective date means you accept the updated policy, except where consent is required by law for a specific new processing activity.

Canonical URL for BotFather and Mini App Settings:

https://clariora.com.au/privacy.html

20. Contact and complaints

Privacy questions and requests:

Datacentre Academy / Luminara Digital
Email: support@datacentre.academy
Product: Clariora A+ · https://clariora.com.au/

If you are in Australia and unsatisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) via https://www.oaic.gov.au/. If you are in the EEA/UK, you may lodge a complaint with your local supervisory authority.

Not legal advice. This policy describes Clariora's actual product behaviour as of the date above. It does not create warranties beyond those in our Terms, and it cannot eliminate all legal risk. For high-stakes commercial deployment, have a qualified lawyer in your jurisdiction review this text and your BotFather privacy settings.

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