Privacy Policy

Effective Date: July 2025

This Privacy Policy explains how Digital Ventures OÜ ("we", "us", or "our") collects, uses, and protects your information when you use the VocabAI mobile application ("App"). We are committed to protecting your privacy and being transparent about our data practices.

1. Information We Collect

a. Account Information

Registered Users (Supabase Authentication)

Email Address: Required for account creation and authentication
Password: Securely hashed and stored via Supabase (we cannot access your actual password)
Account Metadata: Registration date, last login, account status
User Preferences: App settings, learning preferences, and progress data

Guest Users (Temporary Anonymous Access)

Guest User Data Processing Notice:

Temporary Email Generation: For app functionality, we automatically generate a temporary, anonymous email identifier for guest users (e.g., "[email protected]")
No Personal Identification: These generated emails contain no personally identifiable information and cannot be used to contact you
Technical Purpose Only: Generated emails are used solely for internal app functionality and data organization
Session-Based Data: Guest learning progress, temporary preferences, and app usage data
Anonymous Device Info: Device type, OS version, app version (no unique device identifiers stored)
Upgrade Path: Guest users can convert to registered users at any time, retaining their learning progress

b. Usage and Learning Data

Learning Progress: Vocabulary learned, quiz results, study sessions (both guest and registered users)
AI Interactions: Requests sent to AI services, learning patterns (anonymized for guest users)
App Usage: Features used, time spent, navigation patterns
Device Information: Device type, OS version, app version (no persistent device identifiers for guests)

c. Subscription Data (Registered Users Only)

Purchase Information: Subscription status, billing dates (processed by App Store/Google Play)
Payment Details: We do NOT store payment information (handled by app stores)
Guest Limitation: Guest users cannot purchase subscriptions and have access to free features only

d. Advertising Data (Free Users Only)

AdMob Integration: Google AdMob collects advertising identifiers, device info, and usage data
Guest Users: Limited ad tracking with no persistent personal identifiers
Registered Users: Enhanced ad personalization based on usage patterns (can be disabled)
Ad Personalization: Based on app usage and interests (can be disabled in settings)

e. Analytics Data (Sentry)

Crash Reports: Error logs and performance data for app improvement
Usage Analytics: Feature usage, performance metrics (fully anonymized for guest users)
Guest Privacy: No personally identifiable information included in analytics for guest users

2. How We Use Your Information

All Users (Guest and Registered)

AI-Powered Learning: Personalized vocabulary recommendations, adaptive learning paths
Progress Tracking: Save learning progress, generate statistics and insights
App Improvement: Fix bugs, optimize performance, develop new features
Advertising (Free Users): Display relevant ads via Google AdMob

Registered Users Only

Authentication & Account Management: Secure login, account recovery, user verification
Subscription Management: Verify premium access, manage features
Communication: Important updates, security notices (via email)
Cross-Device Sync: Synchronize learning progress across devices

Guest Users Specifically

Session Management: Temporary email identifiers facilitate app functionality without personal data collection
Limited Data Processing: Only essential data for app functionality, no marketing or communications
Upgrade Facilitation: Smooth transition to registered account when user chooses to sign up

3. Legal Basis for Data Processing (EU GDPR)

GDPR Compliance - Legal Bases:

Legitimate Interest (Guest Users): Processing temporary, anonymous identifiers for app functionality is based on our legitimate interest in providing the service, balanced against user privacy rights
Consent (Registered Users): Account creation and personalized features based on explicit consent
Performance of Contract: Subscription services and premium features for paying users
Minimal Data Processing: We process only data necessary for the specified purposes
Guest Data Minimization: Guest user processing is limited to the absolute minimum required for app functionality

4. AI Services and Data Processing

AI-Powered Features Notice:

Third-Party AI: VocabAI uses external AI services to provide learning content and recommendations
Guest User Protection: AI requests from guest users are fully anonymized with no personal identifiers
Registered User Data: Learning requests may include user preferences for personalization (anonymized when possible)
Content Generation: AI-generated content is provided "as is" without accuracy guarantees
Learning Data: Vocabulary and learning patterns help improve AI recommendations
No Personal Data to AI: We avoid sending personally identifiable information to AI services

5. Data Sharing and Third Parties

Third-Party Services We Use:

Supabase: Authentication, database, user account management (registered users only)
Google AdMob: Advertisement delivery and targeting (minimal data for guests)
Sentry: Error tracking, performance monitoring, crash reports (anonymized for guests)
AI Providers: Content generation, learning recommendations (data anonymized for all users)
App Stores: Apple App Store, Google Play (subscription processing for registered users only)

We do NOT sell your personal data. Data is shared only with the above services to provide app functionality. Guest users have significantly reduced data sharing. Premium subscribers have the least data sharing (no advertising data).

6. Your Rights and Account Control

Guest User Rights

Guest User Data Control:

Data Deletion: Request deletion of all guest data through app settings ("Delete My Data" option)
No Personal Data: Since no personal information is collected, there's minimal data to access or export
Upgrade Anytime: Convert to registered account to gain full data control rights
App Removal: Uninstalling the app automatically removes local guest data
Session Reset: Guest data is automatically purged after extended inactivity

Registered User Rights

Account Access: View and edit your profile information within the app
Data Export: Request a copy of your learning data by contacting us
Account Deletion: Delete your account at any time through app settings or by contacting us
Subscription Management: Manage subscriptions through your App Store account
Data Portability: Export your learning progress and vocabulary lists

Privacy Controls (All Users)

Ad Personalization: Opt out of personalized ads through device settings
Email Communications: Unsubscribe from non-essential emails (registered users only)
Data Sharing: Premium subscription reduces third-party data sharing
Guest to Registered: Upgrade account to gain enhanced privacy controls

Data Deletion Process

Data Deletion Effects:

Guest Users: All temporary data and learning progress permanently deleted within 24 hours
Registered Users: All account data and learning progress permanently deleted within 30 days
Irreversible Action: Data deletion cannot be undone
Subscription Management: Active subscriptions should be cancelled separately through app stores
Analytics Data: Some anonymized usage data may be retained for analytics (no personal identifiers)
Legal Compliance: Some data may be retained longer for legal compliance requirements (minimum time possible)

7. DMCA Compliance & Content Removal

We respect intellectual property rights and comply with copyright laws. If you believe content infringes your rights:

Copyright Claim Process:

Email: [email protected]
Subject: "COPYRIGHT CLAIM - VocabAI"
Include:
- Specific content in question
- Proof of ownership or authorization
- Your contact information
- Good faith statement that use is unauthorized
- Statement that information provided is accurate

We will investigate claims within 5-10 business days and remove valid infringing content promptly.

8. Data Security and Retention

Security Measures

Guest Data: Minimal data collection with temporary, non-personal identifiers
Registered Users: Supabase provides enterprise-level security for account data
Password Protection: Passwords are hashed and cannot be viewed by us
Data Encryption: All data transmission encrypted via HTTPS/TLS
Access Controls: Strict internal access controls and monitoring

Data Retention

Guest Users: Data retained only during active sessions, automatically purged after extended inactivity
Registered Users: Account data retained while account is active, deleted upon account deletion
Analytics Data: Retained for app improvement purposes, anonymized when possible
Legal Requirements: Some data may be retained longer for legal compliance (minimum time required)
Breach Notification: Users will be notified of any significant data breaches

9. Content and AI Disclaimer

Important Legal Notice:

AI-Generated Content: VocabAI uses artificial intelligence to generate vocabulary content, definitions, and examples. We do not guarantee accuracy, completeness, or reliability of AI-generated content.
Educational Purpose Only: Content is for educational and learning purposes only, not professional or academic certification.
User Responsibility: Users are responsible for verifying the accuracy of content and using it appropriately.
Third-Party Content: Some content may be sourced from public databases or APIs. We cannot guarantee all content is free from copyright claims.
No Liability: Digital Ventures OU assumes NO responsibility for errors, inaccuracies, or consequences from using AI-generated content.

10. Limitation of Liability

Legal Disclaimers:

VocabAI is provided "as is" without warranties of any kind
We disclaim liability for AI content accuracy, learning outcomes, or educational effectiveness
Users assume all risks associated with app usage and learning content
Our liability is limited to the maximum extent permitted by law
Not responsible for how users apply or share learned vocabulary
No guarantee of specific learning results or language proficiency improvements
Guest users use the service entirely at their own risk with no warranties

11. Children's Privacy

VocabAI is not intended for children under 13. We do not knowingly collect personal information from children under 13. If we discover we have collected data from a child under 13, we will delete it immediately and terminate the account.

Guest Users: Since guest accounts collect no personal information, they do not pose privacy risks for children, but parental supervision is still recommended.

12. International Users & GDPR Compliance

If you use VocabAI outside Estonia, your data may be transferred to and processed in Estonia and other jurisdictions where our service providers operate. By using the app, you consent to such transfers.

For EU Users (GDPR Rights):

Right to Access: Request information about your personal data
Right to Rectification: Correct inaccurate personal data
Right to Erasure: Request deletion of your personal data ("Right to be Forgotten")
Right to Data Portability: Receive your data in a machine-readable format
Right to Object: Object to processing based on legitimate interests
Right to Restrict Processing: Limit how we process your data
Guest Users: Limited GDPR rights due to minimal personal data collection

13. Changes to Privacy Policy

We may update this Privacy Policy as needed. Material changes will be communicated through the app or email (for registered users). Continued use after changes indicates acceptance of the updated policy. Guest users will be notified of significant changes through in-app notifications.

14. Contact Information

For privacy questions, account deletion requests, or copyright reports:

Digital Ventures OÜ

Email: [email protected]

Copyright Claims: Please include "COPYRIGHT CLAIM - VocabAI" in subject line

Privacy Concerns: Please include "PRIVACY - VocabAI" in subject line

Account Deletion: Please include "DELETE ACCOUNT - VocabAI" in subject line

Guest Data Deletion: Please include "DELETE GUEST DATA - VocabAI" in subject line

GDPR Requests: Please include "GDPR REQUEST - VocabAI" in subject line

Last updated: July 2025

Version: 2.0

This policy complies with GDPR, CCPA, and other applicable privacy regulations. We reserve the right to update this policy as needed to maintain legal compliance. Guest user provisions comply with EU data minimization principles and legitimate interest processing.

Guest Users

You can use VocabAI as a guest without registration. For guest users:

We generate a temporary, non-identifying email (e.g., "[email protected]")
This email contains no personal information and is used only for app functionality
Guest sessions are temporary and data is automatically purged after extended inactivity
You can upgrade to a registered account at any time, preserving your progress
Guest users have full app functionality including premium subscription purchases through Apple App Store or Google Play Store
Premium subscriptions are managed by Apple/Google, not our systems

Premium Subscriptions

Both guest and registered users can purchase premium subscriptions through Apple App Store or Google Play Store. We do not process payments directly.

All subscription transactions are handled by Apple/Google
We receive only subscription status (active/inactive) from app stores
Premium users (guest or registered) receive ad-free experience and enhanced features
Subscription management is done through your Apple/Google account settings
We do not store payment information or financial data