Privacy Policy
Last Updated: March 2026
"WordPlus" is an interactive language-learning service provided by IE Volodymyr Voitsekhivskyi ("Company", "we", "us"). Our services ("Services") include a mobile application ("App"), a Telegram bot ("Bot"), and a website at wordplus.app ("Website").
This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and what rights you have. It applies to all parts of the Services.
1. Data We Collect
1.1 Data you provide directly
- Account data: email address, display name, authentication method (Google, Apple, phone number)
- Date of birth (for age verification at registration)
- Learning content: word sets, cards, folders, favourites, study history, progress
- Purchases: subscription status, transactions, virtual currency (Diamonds) balance
- User-generated content published on the Market (sets, reviews)
- Support requests via in-app WordyMail
1.2 Data from the Telegram Bot
- Telegram User ID, username, and display name
- Messages you send to the Bot (used for AI-powered learning assistance)
- Language preferences and learning context
1.3 Data collected automatically
- Device information: model, operating system, app version
- IP address, timezone, country
- Push notification token (Firebase Cloud Messaging)
- Diagnostic logs: error reports, stack traces, app version (automatically deleted after 90 days)
1.4 Data collected with your consent
- Analytics data: app usage events, screen views (via Firebase Analytics, only if you consent)
- Marketing attribution: install source, advertising identifier (via AppsFlyer, only if you consent)
- Website cookies: our Website uses analytics cookies (Google Analytics) only with your explicit consent via the cookie banner
2. How We Use Your Data
We process your data on the following legal bases under GDPR Article 6:
Contract (Art. 6(1)(b)):
- Providing and operating the Services (authentication, syncing learning data, processing purchases)
- AI-powered learning features (generating exercises, translations, explanations)
- Text-to-speech pronunciation
Consent (Art. 6(1)(a)):
- Analytics and usage statistics
- Marketing attribution and install tracking
- Push notifications
Legitimate Interest (Art. 6(1)(f)):
- Error reporting and diagnostics (to maintain service quality)
- Fraud prevention and security
- Authorized personnel access for user support
You can withdraw consent for analytics at any time in the App settings. Withdrawing consent does not affect the lawfulness of processing performed before the withdrawal.
3. AI and Third-Party Processing
3.1 AI in the Mobile App
The App uses AI services to generate learning content (exercises, translations, explanations). Only anonymized text queries are sent to AI providers — no personally identifiable information (names, emails, user IDs) is included in AI requests.
3.2 AI in the Telegram Bot
The Bot uses AI services for conversational learning assistance. The AI receives anonymized learning context only: language pair, skill level, and activity summary. Your display name, Telegram ID, and other personal identifiers are never sent to AI providers. The Bot maintains short-term memory notes to improve learning continuity; these notes are processed through a PII filter that strips any personal information before storage.
3.3 Translation
Translation features send only the text to be translated and the source/target language to translation providers. No user identifiers or personal data are included in translation requests.
3.4 Text-to-Speech
Pronunciation features send only the text to be spoken and the target language to TTS providers. No user identifiers or personal data are included.
3.5 Our Service Providers
We use the following categories of third-party services for content processing:
- AI: OpenAI, Google Gemini — for generating learning content, exercises, and conversational responses
- Translation: Google Cloud Translation, Microsoft Translator — for word and phrase translations
- Text-to-Speech: Google Cloud Text-to-Speech, ElevenLabs, Azure Cognitive Services — for pronunciation
All providers operate under Data Processing Agreements (DPAs). Our API configurations ensure that providers do not retain or use your data for model training.
3.6 Data Minimization
We follow the principle of data minimization: AI and TTS providers receive only the minimum data required to perform the requested function. No user profiles, account data, or browsing history are shared with these providers.
4. Data Storage, Retention, and Deletion
4.1 Active data
Your data is stored on Google Cloud / Firebase infrastructure (United States) for as long as your account is active.
4.2 Inactive accounts
Accounts that have been inactive for 2 years are automatically deleted. You will receive a warning notification 30 days before deletion. Any activity during the warning period cancels the deletion.
4.3 Account deletion
You can delete your account at any time using the "Delete Account" button in the App settings or by sending a data deletion request to the Telegram Bot. Deletion removes all your data from active databases, including all learning data, purchase records, settings, and uploaded content.
4.4 Backup systems
Our database uses Point-in-Time Recovery (PITR) with a 7-day retention window. After account deletion, residual data in backups is naturally purged within 7 days. A tombstone mechanism ensures that deleted accounts cannot be restored from backups.
4.5 Automatic data expiry
- Bot conversation transcripts: automatically deleted after 30 days
- Client diagnostic logs: automatically deleted after 90 days
5. Data Sharing
We share your data only with the following categories of recipients:
- Infrastructure providers: Google Cloud / Firebase (hosting, database, authentication, storage)
- AI service providers: as Data Processors under DPAs, receiving only anonymized queries (see Section 3)
- Translation service providers: as Data Processors under DPAs, receiving only text and language pair
- TTS service providers: as Data Processors under DPAs, receiving only text and language
- Analytics providers (with your consent): Firebase Analytics, AppsFlyer
- App distribution platforms: Apple App Store, Google Play (for purchase processing)
- Law enforcement: only when legally required by court order or applicable law
We do not sell your personal data. We do not share your data with advertisers.
6. International Data Transfers
Your data is stored on Google Cloud servers in the United States. AI and TTS queries may be processed in the US and other countries where our providers operate.
For transfers of data from the European Economic Area (EEA), we rely on the following safeguards:
- Standard Contractual Clauses (SCCs) with our service providers
- Google Cloud Data Processing Agreement and EU Model Contract Clauses
- Provider compliance frameworks (EU-US Data Privacy Framework where applicable)
You may request a copy of the relevant safeguards by contacting us at support@wordplus.app.
7. Children's Privacy
Our Services require users to be at least 16 years old. We verify age at registration by asking for your date of birth. If we discover that a user under 16 has provided personal data, we will promptly delete their account and all associated data.
If you believe a child under 16 is using our Services, please contact us at support@wordplus.app.
8. Your Rights (GDPR)
Under the General Data Protection Regulation, you have the following rights:
- Access & Portability — export all your data in machine-readable JSON format via "Export My Data" in the App settings
- Rectification — update your data in the App settings or contact support@wordplus.app
- Erasure — delete your account via "Delete Account" in the App or the Bot's data deletion feature
- Restriction / Objection — contact support@wordplus.app
- Withdraw consent — toggle analytics off in the App settings at any time
- Lodge a complaint — you have the right to lodge a complaint with your local data protection authority
We will respond to rights requests within 30 days, as required by GDPR.
9. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including encryption in transit (TLS), access controls, audit logging of administrative access, and regular security reviews. However, no method of transmission over the Internet is 100% secure.
10. Changes to This Policy
We may update this Privacy Policy from time to time. For significant changes, we will notify you via the App or email. The updated version will always be available on this page with the "Last Updated" date.
11. Contact Us
Data Controller: IE Volodymyr Voitsekhivskyi
Address: 20 Bogunska St, apt. 79, 13300 Berdychiv, Ukraine
Email: support@wordplus.app