iOS
Privacy Policy
Опубліковано англійською.
Last Updated: August 17, 2026
Introduction
This Privacy Policy describes how Oleksii Mykhalchuk ("we", "us", or "our") collects, uses, and shares information when you use the ProWord iOS app ("the App"). By using the App, you agree to the practices described in this policy.
Information We Collect
Personal Information
When you create an account using Apple Sign-In, we collect your name and email address.
Account Data
We store a username used to identify and manage your account within the App.
Usage Data
We collect data about how you use the App, including:
- Progress in vocabulary learning sessions
- Quiz and exercise scores
- Time spent in the App
- Languages you are learning
- Words and flashcards you create
Voice Data
If you use pronunciation practice, the App records your speech through the microphone in order to transcribe it and check your pronunciation. Transcription is performed by Apple's speech recognition service, which means the audio is sent to Apple's servers for processing; Apple's handling of it is governed by Apple's Privacy Policy. We receive only the resulting text. We do not store your recordings — they are discarded once transcription completes.
Push Notification Tokens
If you enable notifications, we store the push token Apple issues for your device so we can send you learning reminders. You can turn notifications off at any time in your device settings.
Device Information
We collect your device type and operating system version via Apple's Authentication API.
Install Identifier
The App generates a random identifier for your installation, stores it in your device's Keychain, and sends it to our servers together with your push notification token so that reminders reach the right device. It is not shared with advertisers, and it is deleted when you delete your account.
Camera and Photos
If you use the App's camera scan feature to create flashcards, the App requests access to your device's camera (and, if you choose to select an existing picture instead of taking a new one, your photo library). A captured or selected photo is sent directly to our AI provider, OpenAI, to identify objects and text in it and suggest a flashcard — see Third-Party Services below.
- We do not upload or store this photo on our own servers. It is held only in the App's memory for the duration of the scan, and is discarded if you cancel or retake it.
- OpenAI processes the photo to generate its response. Under OpenAI's API terms, data submitted through the API is not used to train its models, and is retained only for a limited period (currently up to 30 days) for abuse monitoring before deletion.
- If you save the resulting flashcard, the photo becomes that flashcard's image and is stored the same way as any other flashcard content you create — locally on your device and in iCloud (see Data Storage and Security).
Please do not scan photographs containing other people's personal or sensitive information, or any material you do not have the right to share.
How We Use Your Information
We use the information we collect to:
- Personalize your learning experience and adapt content to your level
- Identify objects and text in photos you capture or select, to suggest new flashcards (camera scan feature)
- Improve App functionality and performance
- Provide customer support
- Analyze usage trends to develop new features
- Send you reminders and notifications related to your learning schedule (spaced repetition intervals)
- Comply with legal obligations
Legal Bases for Processing (EEA and UK Users)
If you are in the European Economic Area or the United Kingdom, we process your personal data on the following legal bases under the GDPR:
| Purpose | Legal Basis |
|---|---|
| Creating and managing your account; providing the App's learning features | Performance of a contract — Art. 6(1)(b) |
| Sending learning reminders and notifications | Consent — Art. 6(1)(a) |
| Advertising attribution and marketing analytics | Consent — Art. 6(1)(a), obtained via Apple's App Tracking Transparency prompt |
| Product analytics, crash reporting, and improving the App | Legitimate interests — Art. 6(1)(f), in understanding and improving how the App is used |
| Complying with legal obligations | Legal obligation — Art. 6(1)(c) |
Where we rely on consent, you may withdraw it at any time; withdrawal does not affect processing carried out before you withdrew.
Sharing Your Information
We do not sell your personal information for money. We share your data only in the following circumstances:
- With service providers listed in the Third-Party Services section below, as required to operate the App
- With advertising and attribution partners, where you have allowed tracking — see Advertising, Attribution, and Tracking below. Note that this may count as "sharing" under California law; see Notice for California Residents
- When legally required, such as in response to a court order or government request
- With your consent, for any other purpose disclosed at the time of collection
Third-Party Services
The App integrates the following third-party services, each governed by their own privacy policy:
| Service | Purpose | Privacy Policy |
|---|---|---|
| Firebase (Google) | Authentication, database, analytics, crash reporting | firebase.google.com/support/privacy |
| Google Analytics | Usage analytics | policies.google.com/privacy |
| Google Translate API | Word and sentence translation | policies.google.com/privacy |
| OpenAI API | AI-powered flashcard generation, chat, and camera-based object/text recognition | openai.com/policies/privacy-policy |
| DeepL API | Alternative word and sentence translation | deepl.com/privacy |
| ElevenLabs API | Text-to-speech audio pronunciation | elevenlabs.io/privacy |
| Pixabay API | Image search for flashcard illustrations | pixabay.com/service/privacy |
| Apple In-App Purchases | Subscription and payment processing | apple.com/legal/privacy |
| Apple Speech Recognition | Transcribing your speech during pronunciation practice | apple.com/legal/privacy |
| Facebook SDK (Meta) | Analytics and attribution | facebook.com/policy.php |
| TikTok SDK | Analytics and attribution | tiktok.com/legal/privacy-policy |
| AppsFlyer | Mobile attribution and marketing analytics | appsflyer.com/legal/privacy-policy |
Advertising, Attribution, and Tracking
The App includes the Meta (Facebook), TikTok, and AppsFlyer SDKs, which we use to measure how well our marketing works and to understand how people find the App. These SDKs may collect device identifiers — including Apple's Identifier for Advertisers (IDFA) — IP address, and in-app event data.
Before accessing the IDFA for tracking purposes, we ask for your permission through Apple's App Tracking Transparency prompt. If you decline, we do not use the IDFA to track you across apps and websites owned by other companies. You can change your choice at any time in Settings → Privacy & Security → Tracking.
International Data Transfers
We operate from Ukraine, and the third-party services listed above are located primarily in the United States. Your personal data may therefore be transferred to, stored in, and processed in countries outside your own, which may not offer the same level of data protection as your home jurisdiction.
Where personal data is transferred out of the EEA or the UK, we rely on the safeguards offered by those providers — typically the European Commission's Standard Contractual Clauses (with the UK International Data Transfer Addendum where applicable), or the provider's certification under the EU–U.S. Data Privacy Framework. You may request further information about these safeguards at support@oleksi.dev.
Data Storage and Security
Your data is stored in the following ways:
- Locally on your device using SwiftData (Apple's on-device database framework)
- On our own servers at
api.proword.app, which hold your profile (display name, email address, app language, and the language you are learning) and your device registration (your push notification token and install identifier) - In Firebase (Google Cloud) for authentication, analytics, and crash reporting
- In iCloud associated with your Apple ID, for word data and progress sync across your devices
Our servers also relay some requests on your behalf so that our API keys never have to be placed on your device — for example, the text you ask the App to pronounce is passed through our servers to our speech provider. We do not use that text for any purpose other than returning the audio to you.
Account authentication tokens and credentials are stored securely in your device's Keychain using Apple's Authentication API. We apply industry-standard security measures to protect your data against unauthorized access, disclosure, or destruction.
Retention: We keep your account data and learning content for as long as your account is active. If you ask us to delete your account, we delete it from our live systems within 30 days; residual copies may persist in encrypted backups for up to a further 90 days before being overwritten. Analytics and attribution data held by the providers listed above is retained according to their own retention schedules. We may retain limited records for longer where we are required to do so by law.
Children's Privacy
ProWord is a general-audience app. It is not directed to children, and we do not knowingly collect personal information from children under 13 — or under the minimum age of digital consent in your country, which is between 13 and 16 across the EEA.
We do not ask for your age and we do not attempt to determine it, so we cannot identify a child user from the information we collect. If you are a parent or guardian and believe your child has created an account or provided us with personal information, contact us at support@oleksi.dev and we will delete the account and its data promptly.
Your Rights
Depending on where you live, you have some or all of the following rights regarding your personal data:
- Access: You may contact us to request information about the data we hold about you.
- Correction: You may update your account information within the App settings.
- Deletion: You can delete your account and its data directly in the App, at any time, from Settings → Delete account. This removes your profile and device records from our servers and deletes your authentication account immediately. If you would rather we do it for you, email support@oleksi.dev with the subject line "Data Deletion Request" and we will process it within 30 days.
- Portability: To request an export of your data in a machine-readable format, contact us at support@oleksi.dev.
- Objection: You may object to processing we carry out on the basis of legitimate interests, including analytics.
- Restriction: You may ask us to restrict processing of your data in certain circumstances.
- Withdrawal of consent: Where we rely on consent, you may withdraw it at any time — for example by turning off notifications in your device settings, or by disabling tracking in Settings → Privacy & Security → Tracking.
- Complaint: You may lodge a complaint with your local data protection authority. In the EEA, find yours via the European Data Protection Board; in the UK, the ICO.
- Non-discrimination: We will not deny you service, charge you a different price, or give you a lower quality of service because you exercised any of these rights.
To exercise any of these rights, email support@oleksi.dev. We may need to verify your identity before acting on a request. Account deletion is already available in the App; we are continuing to expand in-app tools for the remaining rights.
Notice for California Residents
Under the California Consumer Privacy Act, as amended by the CPRA, we disclose the categories of personal information we have collected in the past 12 months:
| Category | Examples |
|---|---|
| Identifiers | Name, email address, username, install identifier, push notification token, device identifiers (including IDFA) |
| Commercial information | Subscription and purchase history (processed by Apple) |
| Internet or network activity | Usage data, in-app events, crash reports |
| Audio and visual information | Photos you capture or select for camera scanning; voice recordings for pronunciation practice |
| Inferences | Your learning level and progress |
We collect this information for the purposes described in How We Use Your Information, and disclose it to the service providers listed in Third-Party Services for those business purposes.
Sale and sharing: We do not sell your personal information for money. However, our use of advertising-attribution SDKs (Meta, TikTok, AppsFlyer) may constitute "sharing" for cross-context behavioral advertising as the CPRA defines it. You may opt out at any time by declining Apple's App Tracking Transparency prompt, by turning off Settings → Privacy & Security → Tracking, or by emailing support@oleksi.dev with the subject line "Do Not Sell or Share My Personal Information."
California residents also have the rights to know, delete, correct, and limit the use of sensitive personal information, and to be free from discrimination for exercising them. See Your Rights above.
Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the "Last Updated" date at the top of this page and, where the change is material, by notice in the App. Where a change materially affects processing that relies on your consent, we will ask for your consent again rather than relying on your continued use.
Contact
The data controller responsible for your personal data is:
Oleksii Mykhalchuk
Email: support@oleksi.dev
App: ProWord by Oleksii Mykhalchuk
If you have any questions about this Privacy Policy, or wish to exercise any of the rights described above, contact us at the address above.