Privacy Policy - Phraseman by Knowly

Privacy Policy - Phraseman by Knowly

Last updated: October 29, 2026

This Privacy Policy explains how Maksym Babiev, an individual trader trading as "Knowly" ("Knowly", "we", "us", or "our"), collects, uses, discloses, stores, and deletes information when you use Phraseman (the "App"), related cloud features, and Knowly website pages for Phraseman. The data controller is Maksym Babiev, Ardagh, Ballymackerry, V42 P599, Ireland. Privacy contact: support.phraseman@gmail.com.

This Policy is intended to describe the App's current data practices. If a store listing, in-app notice, or consent screen gives more specific information for a particular platform or feature, that notice also applies.

1. Scope, controller, and acceptance

This Policy applies to the Phraseman mobile app, related online services, support channels, public legal pages, and cloud features operated by Knowly. The controller responsible for your personal data is Maksym Babiev, trading as Knowly, Ardagh, Ballymackerry, V42 P599, Ireland, support.phraseman@gmail.com.

By using the App, you acknowledge that your information will be processed as described in this Policy and in any applicable store or consent disclosures. If you do not want your information processed as described, do not use the App or the affected feature.

2. Age and minors

Phraseman is intended for users aged 16 and over. During onboarding we ask you to confirm that you are 16 or over. We record only that confirmation as age-consent metadata; we do not ask for or store your date or year of birth. We do not knowingly process the personal data of anyone under 16; if we learn that we have, we delete it.

If you are a parent or guardian and believe that someone under 16 has provided personal data through the App, email support.phraseman@gmail.com with subject "Parent Privacy Request". We will review the request and delete or de-identify relevant account data unless we must retain limited records for legal, safety, fraud-prevention, moderation, transaction, or security reasons.

3. Data stored on your device

The App stores learning progress, streaks, achievements, flashcards, daily tasks, lesson state, settings, notification settings, cached activity/error queues, cached assets, and similar app data on your device using AsyncStorage, SecureStore where available, and related platform storage. Devices that used earlier versions may still hold legacy local state created by features that have since been retired or rebuilt (such as the old Quiz mode or earlier versions of competitive modes). That state does not mean those features remain available in that form and is removed through the ordinary local-data or account-deletion controls described below. After account deletion, the App also clears the offline cache kept by the Firebase database library the next time it starts.

The App also creates or uses a Phraseman stable app identifier. It may be stored in SecureStore where available and mirrored in local storage so progress, cloud sync, purchases, referrals, moderation, fraud prevention, account recovery, and account deletion can work across app sessions. Depending on iOS Keychain, Android backup/restore, device restore, or device settings, this identifier or a backup of it may survive reinstall or device restore until you use the in-app deletion flow, clear app data, or reset relevant device storage.

If you use the App as a guest (without signing in with Google or Apple), your progress is tied to this installation. Deleting the app, clearing its data, or moving to a new device may permanently lose it. Sign in with Google or Apple to keep it.

When you switch accounts on a device, the App may keep a temporary copy of the previous account's local progress on that device, so that it can be returned if you sign back in to the same account. This copy stays on the device, is only restored into the same account, and is discarded after 30 days.

4. Account, authentication, and cloud sync

The App uses Firebase Authentication. By default, Firebase may create an anonymous app session so cloud features can operate without a separate Knowly username/password.

You may optionally sign in with Google or Apple. If you do, Firebase and Knowly may process provider identifiers, Firebase Auth UID, email address if shared, display name if shared, provider type, platform, sign-in timestamps, account-linking records, and related authentication metadata. We use this to restore progress, link devices, prevent account drift, secure the service, and prevent abuse.

Cloud sync may store progress and app state in Firebase Firestore, including lessons, streaks, achievements, certificates, custom flashcards, your "My mistakes" history (the exercise, the correct answer and the answer you gave, up to 200 characters), videos you save to your favourites (the video ID and the time you saved it), daily and weekly stats, foreground usage totals, Plus status metadata, RevenueCat purchase metadata, coin and energy balances and ledgers, Peak progress, settings, language/target selections, referral state, AI dialogue memory (described in the AI features section), social feature state, and other data needed to operate requested features.

If you lose access to your progress, for example after reinstalling the App or choosing a different Google or Apple account, the App may offer to restore it with a one-time code. The code is sent by email, through our email provider (Resend), only to the email address already linked to your account. It expires after 10 minutes. We store only a protected (hashed) form of the code, together with attempt counters and recovery records used to prevent abuse.

To protect account recovery against code guessing and other abuse, the App keeps short-lived counters of recovery requests and incorrect codes. Each counter is identified only by a keyed hash (made with a secret key) of your sign-in account identifier, of the account being recovered or the email address entered for recovery, or of the IP address the request came from; we do not store the IP address itself in these counters. A counter contains only a number and timestamps, is used only to limit repeated attempts during its limit period (at most one day), and is otherwise retained only as described in the "Retention" section below.

To protect the service and its running costs against abuse, the App also keeps short-lived counters for nickname changes, nickname availability checks, and requests to features that call paid AI services (such as dialogue practice, conversation review, translation and voice). Each counter is identified only by a one-way hash of your account identifier or of the IP address the request came from; we do not store the IP address itself in these counters. A counter contains only a number and timestamps, is used only to limit repeated requests during its limit period (one hour or one day), and is otherwise retained only as described in the "Retention" section below.

If you save a video to your favourites, we store the video ID and the time you saved it in your account so your list follows you to a new device, and we keep an aggregate count of how many accounts saved each video. The count does not show who saved a video. Your list is deleted together with your account.

5. Public, social, and historical competitive data

Some data is visible to other users when you use current public or social features. This may include nickname, coin-rank avatar, profile card settings and style, the short profile-card caption you write yourself (available with the Pro profile card, a card style you can get with coins; it is not a subscription), streak, rank, Peak floor, steps and weekly result, weekly coins earned (shown to members of your Peak room), historical Arena and tournament results from earlier app versions, the Plus marker described below, friend activity, activity likes, community pack author information, seller notifications, and similar profile fields. Your profile-card caption is visible to other players who open your profile card; other players can report it, and we may remove captions that break our rules. If you answer a poll in the App, we record only which questions your account has already answered, so that you cannot vote twice; the option you choose is added only to aggregated counts and is not stored with your account ID. Your own answers may be kept on your device. Other users only see aggregated results. Visibility depends on the feature: some fields may be public to app users, some visible to friends, some visible to community pack buyers or sellers, and some visible only to moderators/admins.

Peak floor records. In a Peak room, the fastest accepted time for each floor is shown to the members of that room together with the name of the player who set it (a player without a visible name appears as "Player"). Your own best times are shown only to you. To check a record attempt, our server keeps the attempt details (a one-time token, the questions issued for the attempt and the start time) and the accepted result (the time taken, when it was completed, and confirmation that all ten answers were correct). This competitive data is separate from your lessons, coins and energy, has no separate automatic expiry, and is deleted together with your account.

If you have Phraseman Plus, other users may see a Plus marker (for example, a ring around your avatar) next to your nickname in friends lists, leaderboards, Peak rooms, and community features. The marker shows only that Plus is currently active; it does not show your plan, price, renewal date, how you got Plus, or any payment details.

Peak groups players into weekly rooms of up to 30 places for each study language. Other app users who open the room can see your nickname, avatar and cosmetic style, your steps, place and weekly result. Some places in a room may be filled by computer-controlled participants rather than real people. Weekly room records are kept as part of the Peak history; your entry is removed from them when your account is deleted.

When you study with friends in the Friends section, those friends may see whether you studied today, which days of the current week you studied, how many days you both studied on the same day, your current and longest shared streak, and the resulting friendship level and progress. Friends may also send or receive nudges through this feature.

Only friends you have accepted (not other users) may also see: in the weekly friend summary, how many study sessions you completed that week, your best day, and your Peak floor; in the shared phrase of the day, the phrase option you chose; in Learn together and duels, that you invited them and the result of a duel between the two of you; and, when you send a friend an energy gift, that it came from you.

When you set a weekly goal together with a friend in the Friends section, that friend can see the goal you chose together, how far each of you has progressed toward it this week, and whether it was completed. When the goal is completed, our servers credit coins to both of you. Only the accepted friend in that pair sees this information; it is deleted together with your account.

The weekly friend summary is calculated on your device and stored with your synced progress. It covers the current and the previous week: how many lessons you completed, on how many days you studied, your streak at the end of the week, your best Peak floor that week and how many floors it is above the previous week, and your best day. Only your accepted friends receive it, through the Friends section. You can turn off "Show my week to friends" at any time; while it is off, our servers stop sending your weekly summary to friends.

For the shared phrase of the day, your device stores your latest answer with your synced progress: the day, which phrase it was, the option you chose and whether it was correct. Only your accepted friends receive it, through the Friends section, so you can compare answers. The "Show my week to friends" switch does not hide this answer.

For learning together, your synced progress also includes a compact record of which course lessons you have completed and which are open to you. Only your accepted friends receive it, through the Friends section, so the app can show whether a lesson is open, already completed or still locked for you when they invite you.

Some special appearance themes are unlocked by achievements, special conditions or an active Phraseman Plus subscription. To check them, our servers store how long you have watched videos in the App (total watch time, the current viewing session and the time of the last update) and look at achievements already in your synced progress, such as your coin rank, streak, Peak floor and course progress. This is used only to unlock themes and is deleted together with your account.

Historical records created by retired features (such as the old Quiz mode, Arena matches, the old friend duels (not the current duels with friends described above), tournaments, clubs, the old friend gifts (not the current energy gift), or the old ideas board (submitted ideas, likes and reports on ideas)), including old results or participation records, may be retained only as reasonably necessary for security, fraud or abuse prevention, dispute handling, legal compliance, backup expiry, or deletion integrity. Account deletion is designed to delete or de-identify those historical records controlled by Knowly, subject only to the limited retention grounds described in this Policy. Those historical records are not presented as currently available gameplay features.

6. User content, community packs, reports, and moderation

If you create Community Packs, submit flashcard text, translations, reports, profile names, survey answers, ratings/votes, or other user-provided content, we process the content you provide and related metadata. This may include titles, descriptions, card text and translations, normalised text used for moderation, report reasons, reporter/reported user IDs and names, author IDs, buyer/seller IDs, moderation decisions, timestamps, platform, app version, audit fields, ranking scores, vote counts, report counts, and related safety signals.

Published Community Packs and approved catalogue metadata may be visible in the App. Pack cards may be visible to the author, moderators, and users who access or purchase the pack with coins.

If you comment on a Community Pack you have added, we store your comment text, your author ID and display name, the pack ID, timestamps, reaction counts, and pin status. Comments are visible to other users who have added the same pack, remain attached to the pack, and are not private messages. The pack's author can pin one comment and hide a comment from the pack's comment list for other viewers; a hidden comment is not deleted and may still be reviewed if reported. You can delete your own comment at any time, and any user can report a specific comment (separately from reporting the whole pack) using the same report categories described above. If someone comments on a Community Pack you authored, we send you an in-app notification containing a short excerpt of the comment so you can review it.

A Community Pack's author can edit the pack's title, description, and cards after it is published. Edited content replaces the previous version immediately and does not go through a separate moderation review before becoming visible to other users; we keep the previous version and edit metadata for audit and abuse-investigation purposes.

To check Community Packs for mistakes and to show them in other interface languages, the text of a pack (title, description, and card text) may be sent to our AI provider (OpenAI) for review and automatic translation. Translated versions may be shown to other users who view the pack. When we reply to a report you sent, a moderator may use AI assistance to draft the reply from the report text; a person reviews the reply before it is sent to you in the App.

When a Community Pack is approved for publication, the text of its cards in the language being learned (up to 300 characters per card) may be sent from our servers to our AI provider (OpenAI) to generate spoken audio for the cards. Only the card text is sent; no account details, names, or identifiers are sent with it. The generated audio files are stored in our cloud storage (Google Firebase) and played to users who open the pack. Because a clip depends only on its text, the same clip may be reused for identical card text in other packs. Audio is kept for as long as it is needed to provide the packs that use it and may be removed at any time.

Content reports. If you use the flag button to report a problem in a lesson task, test question, flashcard or AI conversation, we receive the explanation you write, the text of that task, card or reply, the answer you gave, the screen and item ID, the content language and interface language, your account ID, platform, app version and the time. If you report a conversation, we also receive up to its 12 most recent messages, including messages you wrote. We use this only to fix content, answer you and prevent abuse; a moderator may use AI assistance to draft the reply from the report text. These reports do not include the technical action history that support reports can include. If the report cannot be sent right away, it is kept in a queue on your device and sent later. Content reports are deleted automatically 30 days after they are sent and together with your account.

We may review, block, remove, hide, de-identify, retain, or disclose user content, comments, and reports when needed to operate moderation, enforce the Terms, protect users, investigate abuse, handle disputes, prevent fraud, comply with law, respond to copyright or rights complaints, or preserve service integrity.

7. Friends, referrals, invite codes, and rewards

Friend, energy-gift, referral, invite, and reward features may process friend codes, friend relationships, friend requests, the list of users you have blocked (blocking also removes that person from your friends and stops their friend requests to you; the blocked person is not told who blocked them), activity feed entries, activity likes, invite links, referral codes, referral owners, referral attributions, referrer/referee stable IDs, reward status, reward roulette spins and outcomes, coin ledger entries, daily or monthly limits, cooldowns, abuse checks, Google Play Install Referrer data on Android, and deep-link or manual-code source information.

We use this information to operate the feature, attribute rewards, prevent self-referrals and abuse, enforce caps and cooldowns, correct errors, and protect the App.

Monthly Community Pack contest: a like you give to a Community Pack published in the current month counts as a contest vote. To keep the contest fair, our servers check that the voting account is at least 3 days old and has completed at least one lesson, and count up to 10 active votes per account per month (removing a like frees the vote). On the 1st of each month we store the results: the month, the three winning packs, their authors, places, and vote counts. Phraseman Plus for winners is added to their account automatically, and each winner sees a personal story about the win in the App.

Invite ladder: if you enter a friend's invite code, we check that your account is no older than 30 days at that moment and whether you complete your first lesson within 30 days, so we can credit coins to you and your friend and add Phraseman Plus to the inviter for every three counted friends (up to 10 counted friends per month). We keep per-inviter counters and a log of granted rewards; they are deleted together with the account.

8. App messages, reactions, polls, and surveys

The App may show in-app messages, polls, product questions, cancellation surveys, VIP surveys, or similar prompts. If you respond, react, vote, dismiss, claim a reward, or otherwise interact, we may process response content, selected options, reaction type, vote choice, message IDs, survey IDs, timestamps, eligibility state, reward state, user or stable app IDs, and related metadata. For polls, the option you choose is added only to aggregated counts and is not stored with your account; we keep only a record that your account has already answered (see section 5).

We use this information to operate messages and polls, prevent duplicate rewards or abuse, understand product feedback, improve the App, maintain audit records, and apply entitlements or rewards where applicable.

9. Purchases, subscriptions, RevenueCat, and coins

Phraseman Plus subscriptions, free trials, and other purchases made in the App are billed through the Apple App Store or Google Play, and Knowly does not receive your payment card or bank details. Purchases and gifts made on the Knowly website are paid through Stripe or PayPal, as described in section 14.

We use RevenueCat to verify subscriptions, entitlements, receipts, product IDs, transaction IDs, store, environment, purchase and expiry timestamps, cancellation or billing status, refund and chargeback signals, and related webhook events. RevenueCat may receive a Phraseman app user ID, Firebase/Auth ID, canonical stable ID, and attributes such as `phraseman_uid` so subscription and purchase state can be restored and matched to your account. To show whether you have access to paid features, the App checks your subscription status with RevenueCat each time it starts — including before you buy anything and before the optional choices in onboarding. For this check RevenueCat receives the app user ID described above and the technical store and device information needed to read store receipts. It is not used for advertising or analytics and is necessary to provide the App and restore purchases (performance of the App and our legitimate interests; see Legal bases).

Coins are a virtual in-app balance earned through learning and rewards and spent inside the App (for example on Community Packs). We may store coin balances, grants, spending, refunds/reversals, pack purchases, seller credits, platform fees, reward grants, and audit logs in Firebase.

10. Analytics, diagnostics, device identifiers, and app health

We use Firebase Analytics, Firebase Crashlytics, PostHog where enabled, and our own limited app activity/error logs to operate, secure, debug, measure, and improve the App. These records may include app events, screens/features used, purchase/paywall/referral events, AI feature events, onboarding choices, notification interactions, message or survey interactions, error context, crash logs, stack traces, app version, build number, platform, OS version, device name or model, app state, your in-app nickname, Firebase/Auth IDs, stable app ID, app instance identifiers, PostHog distinct IDs where enabled, and other app metadata.

These records are not described as anonymous. Some diagnostics and analytics may be linked to your app account, Firebase/Auth ID, stable app ID, app instance, or device identifiers.

Support diagnostics: the App keeps a bounded technical action history on your device — which screens and actions were used and technical error codes from the last 24 hours, at most 200 entries (about 64 KB), stored separately for each account. It never leaves your device on its own. This history is sent to Knowly only when you explicitly submit an in-app support report: the report form tells you that it will be attached, lets you view the most recent entries before you send, and has a switch to leave the history out of that report. It is attached to that report to help us investigate the problem. It does not include message text, passwords, payment details, authentication tokens, or purchase receipts. Support reports and their attached history are deleted automatically 30 days after they are sent; they are also deleted together with your account if you delete it sooner, and you can ask us to delete them earlier through the in-app support form or by email.

When you send an in-app report about a problem, we receive your comment, the screen and content item it concerns, the answer you gave (if any), your nickname and interface language, basic account information (such as level, streak, Plus status, and days in the App), and device information (device model, operating system and version, and screen size). Unless you switch it off on the report form, the technical action history described above is attached. These reports are deleted automatically 30 days after they are sent.

We ask for your consent before collecting non-essential product analytics (such as PostHog analytics and non-essential Firebase Analytics events). If you decline, or later withdraw consent in the App, we do not collect that non-essential analytics and do not link it to your account or identifiers. We still process a limited amount of strictly necessary information, such as crash and error diagnostics, security, and fraud-prevention signals, which we rely on to keep the App working and secure. You can change your analytics choice at any time in the App settings. We also keep a record of your analytics and AI-feature consent choices (granted or denied, when, app version and platform) so we can honour and demonstrate them.

The App does not use the Google Play Services Advertising ID and does not request it. We do not sell personal information, and we do not use any advertising identifier for third-party advertising or cross-context behavioral advertising unless this Policy, store disclosures, and any required consent are updated first.

11. AI features and OpenAI processing

Some Phraseman features use generative AI providers such as OpenAI to generate dialogue replies, phrase explanations, mistake explanations (only in app versions earlier than 2.0.0), and similar learning feedback.

When you use AI features, we may send the AI provider the text you enter, recent conversation history, selected scenario or mode, language level, learning target, phrase text, phrase meaning, your exercise answer and target answer, computed learning analytics such as weak words or phrases, mistake categories, progress, streaks, study minutes, and related context needed to generate the requested response.

We may also keep limited AI-related logs for quotas, billing, cost control, abuse prevention, debugging, safety, and service reliability. These logs may include user IDs, feature type, model name, token counts, timestamps, request status, Plus status, language, lesson or phrase identifiers, and similar metadata.

When you rate a lesson, vocabulary session, or dialogue and write a comment in the rating card, that comment text may be sent to an AI provider (such as OpenAI) so we can group recurring topics across many reviews and see what to fix first, but only if you have enabled AI features in the App. Ratings and comments are optional — you can always skip the card, and every screen works exactly the same if you do. Please do not include personal data in your comment; email addresses and phone numbers are stripped before the text is grouped.

Do not submit sensitive personal data, confidential information, payment details, medical, legal, financial, immigration, employment, emergency, or safety-critical information to AI features. AI output may be inaccurate, incomplete, or unsuitable for your context.

In app versions earlier than 2.0.0 only: mistake-explanation features in lessons (the inline mistake breakdown and the simplified 'explain simpler' view) require your explicit, separate opt-in before they are used for the first time, and you can withdraw that consent at any time in the App's privacy settings. If you do not opt in, or if you withdraw consent, these two features are not shown and the associated text is not sent to the AI provider; the rest of the lesson (including the correct answer) continues to work normally. From version 2.0.0, these features are not available and no mistake text is sent to the AI provider for them.

AI dialogues (scenario practice conversations and the free-form companion chat) also require your explicit, separate opt-in before you can open them for the first time, and you can withdraw that consent at any time in the App's privacy settings. If you do not opt in, or if you withdraw consent, these screens do not open and your messages are not sent to the AI provider.

AI dialogues keep a limited, structured memory so a conversation can continue between sessions: a short learning summary for each study language (for example topics you practised, recurring language mistakes, and phrases worth reviewing) and resume checkpoints for each scenario. Knowly does not retain the raw transcript of your dialogues for this memory. The memory is stored in your account, is used only to personalise your dialogues, is never shown to other users, and is deleted together with your account. A copy of these summaries may also be kept on your device so the screen opens instantly; that copy is removed when you sign out, switch accounts, or delete the memory. You can delete all saved memory for a study language at any time in the App. Please do not tell the AI sensitive personal data (health, finances, legal matters, identifiers or passwords).

While an AI dialogue is in progress, we keep the messages of that conversation (your messages and the AI replies) on our servers so the conversation can continue and a repeated request is not processed twice. These session records are kept only as long as needed for that purpose and for security and abuse prevention.

Messages in AI dialogues are checked automatically for safety, including by our AI provider's moderation service. If a message is flagged, we may keep that message and a short excerpt of the preceding conversation as a safety record that only authorised moderators can review. Safety records are kept only as long as needed for safety, abuse prevention, or legal reasons. If you ask the App to translate text in a dialogue, the text and its translation may be kept in a shared translation cache that is not linked to your account.

12. Notifications and push tokens

If you enable notifications, the App may request notification permission and store notification settings, local scheduled notification IDs, Expo push tokens, native push tokens where applicable, device/platform metadata, user IDs, and related delivery metadata. To send remote notifications in your language and at a suitable time of day, we store your interface language and your device's time zone together with your push token.

If you turn on the daily reminder and have not chosen its time yourself, the App may pick the reminder time based on when you usually start lessons or open the App. These times are stored and processed only on your device for this purpose and are not sent to us. You can set the reminder time yourself in the notification settings, and the App will then keep your choice.

Notifications may include local reminders, phrase of the day, streak warnings, weekly/monthly recaps, lesson counts, streak counts, phrase text, re-engagement or winback reminders, account/service notices, or similar app context. Remote notifications may be delivered through Expo's push notification service and the applicable platform push service. You can disable notifications in the App or device settings, but some service messages may still appear inside the App.

13. Text-to-speech, speech recognition, and voice features

The App uses your device's built-in text-to-speech engine through expo-speech to pronounce phrases and example sentences in the language you are learning. Based on the current implementation, this pronunciation is generated on device and Knowly does not receive the generated text-to-speech audio. Some approved Community Packs also include pre-generated audio for their cards, created on our servers from the card text by our AI provider's text-to-speech service, as described in the Community Packs section; it does not use your voice or anything you type.

Where speech recognition, pronunciation practice, or voice dialogue features are enabled, the App may request microphone and speech recognition permissions. Depending on the feature, speech may be processed on device or by platform speech services, and a transcript or recognised text may be used by the App. If you use an AI voice dialogue feature, the transcript or recognised text may be sent to the AI provider as described in the AI features section. Do not say sensitive personal, confidential, payment, medical, legal, financial, or emergency information in voice features.

When you answer by voice (in lessons, flashcards, pronunciation practice, or AI dialogues), the recording is kept only in the App's temporary storage on your device, so that you can play your own answer back and the App can double-check the result; it is removed when it is no longer needed, and Knowly does not receive the recording. Pronunciation is checked on your device by comparing the recognised text with the target phrase; the App may record the result (for example, the score and whether the attempt passed) as part of your learning progress and analytics, but not your voice or the recognised text. Only in AI dialogues is the recognised text of your answer sent, as described in the AI features section. On Android, speech recognition uses your device's system speech recogniser, which may be provided by Google and may process your voice under its own terms. On iPhone and iPad, speech recognition uses Apple's speech recognition service, which may process your voice on the device or on Apple's servers under Apple's own terms.

On some Android devices, the App also uses an open-source speech model (Whisper) that runs entirely on your device to double-check pronunciation. The first time you open a speaking exercise, the App downloads the model file (about 30–60 MB) once from Hugging Face, a third-party file host. As with any download, Hugging Face receives your device's IP address and basic technical request information; no audio, recognised text, or account information is sent. Your voice is never sent to Knowly or to Hugging Face for this check.

Audio delivery (Cloudflare). Lesson audio for the Learning course may be delivered through Cloudflare (Cloudflare, Inc.), which hosts our audio files and serves them to the App. When the App downloads an audio file this way, the request includes your device's IP address, the requested audio path, and a Firebase sign-in token that identifies your Phraseman account, so that only signed-in users can download course audio. Our Worker uses the token only for access control and does not intentionally write the IP address or token to application logs. Cloudflare may process request and network metadata under its own service settings, security practices, retention rules, and privacy policy. We do not use this delivery request for advertising or product analytics. Cloudflare's privacy policy is available at https://www.cloudflare.com/privacypolicy/

Some of the libraries that power these voice features are general-purpose media and animation libraries that also support video capture and motion sensors. Because of this, on some platforms the operating system may list camera or motion permissions for the App. The App does not take photos, record video, open the camera, or read motion and fitness sensors, and it never asks you for those permissions; the only sensor input the App captures is microphone audio for the voice features described above.

14. Website, cookies, leads, and web purchases

The Knowly website uses local storage and session storage for essential preferences and flows, including theme choice, quiz progress, first-touch UTM attribution, lead email, cached prices, and your Meta Pixel consent choice. It also sends limited website events (page category, visit/view, store clicks, and quiz/checkout funnel events) to our Cloud Function, which stores aggregate counters. To protect that endpoint from abuse, we create a short-lived hash of the visitor IP address for rate limiting; hosting providers may also process IP addresses and request logs.

If Meta Pixel is enabled, we load it only after opt-in consent in the EU, EEA, UK, and Switzerland. You can accept, reject, or later change that choice using the "Cookie settings" link in the website footer.

If you request a quiz plan by email, we process your email address, quiz answers, UTM attribution, page, consent choice, and delivery/unsubscribe status to send the requested plan. We send follow-up product emails only when you separately opt in; you can withdraw that consent through the unsubscribe link in any such email or by contacting us.

If you use the website contact form, email support, or legal request channels, we may process your name, email address, message, topic, page URL, user-agent, forwarded IP header, support metadata, account identifiers you provide, and our replies. To respond faster, support messages may be triaged and answered with AI assistance: the text of your message and related support context may be shared with our AI provider (OpenAI) to classify the request and draft a reply, and routine replies may be sent automatically. You can ask for human review in your reply at any time.

For website purchases, we process your email, selected plan, quiz/UTM attribution, order identifiers, payment status, amount, currency, activation code, and payment-provider transaction references.

Gifts of Phraseman Plus for another person are sold only on the website. When you buy a gift, we process your email address, the plan, the recipient name and sender name you enter for the certificate, and the delivery method you choose: a code sent to your email or a gift link that you share yourself. We also process order identifiers, payment status, amount, currency, the activation code or gift link, and payment-provider transaction references. The certificate, gift email, and gift page show the plan and the names you entered; anyone who opens the gift link can see them. A gift is activated when the recipient enters the code or opens the gift link in the App; we then link the gift to the recipient's account to turn on Plus, or to extend an active Plus period, and to prevent repeated use. An unused gift code or gift link expires 365 days after purchase. You can cancel a code or gift link until it is activated; after cancellation it stops working, and refunds for cancelled gifts are issued manually within 5 business days to the original payment method. We do not show the buyer the recipient's account, progress, or other personal data. Card and PayPal payment credentials are collected by Stripe or PayPal, not by Knowly.

15. Email Communications and Marketing

If you provide an email address, we may send service and account emails about security, purchases, account operation, legal notices, or important service information. We send website product emails, including quiz-plan follow-ups, only where you have separately opted in. We use an email provider such as Resend. You can withdraw marketing consent at any time through the unsubscribe link in the email or by contacting support.phraseman@gmail.com; this does not affect service or account emails. We keep a suppression list so we can honour your choice.

16. Third-party services and processors

The App and related services use third-party providers, including:
- Google Firebase services such as Authentication, Firestore, Cloud Functions, Cloud Storage, Analytics, Crashlytics, and related Google Cloud infrastructure
- Google Play Services, Google Sign-In, Google Play Billing, Google Play Install Referrer, and Android platform services
- Apple Sign In, Apple App Store, Apple in-app purchase systems, and Apple platform services
- OpenAI or other AI model providers for AI dialogues, phrase explanations, mistake feedback (app versions earlier than 2.0.0), AI-assisted support replies, and related AI features
- Hugging Face, only to download the on-device speech model file used on some Android devices (no audio or text is sent)
- Cloudflare, to deliver access-controlled Learning course audio files and process the related request and network metadata under its service settings and privacy policy
- YouTube API Services and embedded YouTube players for the in-app video catalogue; when you view or play videos, YouTube/Google processes data under the Google Privacy Policy (https://policies.google.com/privacy)
- PostHog for product analytics where enabled
- RevenueCat for subscription, purchase, entitlement, and receipt verification
- Expo / EAS / Expo Updates and Expo push notification services for app infrastructure and notification delivery
- Resend or another email provider, and Gmail (Google) for the support mailbox, for contact, support, and consented website email delivery
- Stripe and PayPal for website checkout and payment processing
- Meta, only where website Pixel consent is granted
- Telegram, to send payment-order and aggregated operational notifications to authorised administrators
- App stores and payment processors for purchase, subscription, refund, tax, and compliance records

These providers process data under their own terms, privacy policies, and security programs. Data may be processed in countries other than your country of residence, subject to applicable safeguards.

17. How we use and disclose information

We use information to provide, maintain, secure, debug, personalise, and improve the App; authenticate users; sync progress; operate purchases and entitlements; manage coins and rewards; run leaderboards, friends, referrals, community packs, surveys, notifications, moderation, AI-generated feedback, AI quotas, and AI safety controls; retain, secure, delete, or de-identify historical records from retired features; prevent fraud and abuse; respond to support and legal requests; comply with law; enforce the Terms; and protect Knowly, users, and third parties.

We disclose information to service providers and processors that help operate the App; app stores and payment processors for purchases, refunds, fraud, and compliance; other users where required by current public, social, or community features; moderators/admins for safety and support; legal, regulatory, or law-enforcement authorities where required or permitted by law; and relevant parties in connection with a merger, acquisition, financing, reorganisation, asset sale, or similar transaction.

We do not sell personal information. We do not knowingly share personal information for cross-context behavioral advertising unless this Policy and applicable store disclosures are updated to describe that practice.

18. Legal bases and purposes

Depending on your location, we process information on these bases:
- Contract/performance of the App or requested service: account operation, progress sync, purchases, subscriptions, coins, leaderboards, social features, support, AI features you request, the requested website quiz plan, and requested features
- Legitimate interests: security, fraud prevention, abuse prevention, debugging, aggregate website measurement, service reliability, moderation, management of historical feature records, AI cost control, AI safety, product improvement, legal defence, and business operations
- Consent: AI-based mistake-explanation features in lessons (app versions earlier than 2.0.0), AI dialogues, website marketing emails, Meta Pixel where required, optional notifications, optional microphone/speech recognition permissions, optional Google/Apple sign-in where required, and consent-based analytics where required
- Legal obligations: tax, accounting, consumer protection, store compliance, dispute handling, copyright and rights complaints, law-enforcement requests, regulatory compliance, and sanctions/export compliance

19. Retention

We retain information only as long as reasonably needed for the purposes described in this Policy, unless a longer period is required or permitted by law.

Typical retention criteria:
- Local app data remains on your device until you delete it, use account deletion, clear app data, uninstall, or reset relevant device storage; backup/keychain behaviour may vary by platform
- Active cloud progress, profile, entitlement, and feature data is retained while your account or app instance is active
- Reports, moderation records, safety records, purchase records, entitlement records, referral records, reward records, surveys, AI quota/billing/safety logs, analytics/error records, and fraud-prevention records may be retained longer where needed for safety, disputes, legal compliance, chargebacks, refunds, accounting, moderation integrity, abuse prevention, cost control, or auditability
- Website leads, consent records, contact/support messages, and payment-order records are retained only as long as needed to deliver the requested service, honour consent or unsubscribe choices, respond, prevent abuse, and keep required business, security, or legal records
- An account signed in with Google or Apple that you asked us to delete is retained for a 14-day grace period before irreversible deletion, so that an accidental deletion can be undone; during that period the account cannot be used and the data is not processed for any other purpose. A guest account (used without signing in with Google or Apple) cannot be restored, so its server-side data is deleted as soon as the deletion request reaches our servers and they confirm that no Google or Apple sign-in is linked to it; if this cannot be confirmed at that moment, the ordinary 14-day period applies
- A minimal deletion record (hashed account identifiers, date, reason) is retained to demonstrate completed deletion requests
- Backups and logs may persist until overwritten or deleted under normal retention cycles
- In-app error and app activity logs (the limited app health records described in section 10) are deleted automatically 90 days after they are created

We do not promise automatic deletion after a fixed inactivity period unless such a deletion job is implemented and active.

20. Account and data deletion

You can request deletion from inside the App where available, from the public deletion instructions at https://knowlyapps.com/legal/data-deletion/, or by emailing support.phraseman@gmail.com with subject "Delete My Data".

The in-app deletion flow starts an authenticated backend deletion request. The App signs you out and clears local app data on that device immediately. A technical offline cache kept by the Firebase database library on the device is cleared the next time the App starts after the deletion. For an account signed in with Google or Apple, server-side deletion is then scheduled after a 14-day grace period, so that an accidental deletion can still be undone: if you sign in again during those 14 days, the App offers to restore the account, and accepting cancels the deletion and returns your data in full. Once the 14 days elapse, deletion runs and becomes irreversible. Where available in the app, you can also choose to delete your account immediately; in that case your data is deleted right away and cannot be restored. The backend deletion function is designed to delete or de-identify active account data controlled by Knowly, including the Firebase Auth user, users/{stable_id} data and subcollections, leaderboard/profile records, auth links, name/friend/referral indexes, Community Pack, report, reaction, poll-vote, survey, analytics, and error records linked to the stable ID, and local app data on the device.

Friend duels are handled so that the other person's history stays intact. If you delete your account, finished duels with a friend (their result and date) and the friend's notification about that result stay in your former friend's duel history, so their own record does not change. Your account ID, nickname and avatar are removed from those records and replaced with "Deleted player"; they are no longer linked to you and are visible only to that friend. Open duel challenges you have not answered are deleted. In the same way, if a friend deletes their account, your finished duels with them stay in your history under "Deleted player".

After deletion we keep a minimal record that a deletion took place: one-way cryptographic hashes of the account identifiers (which cannot be turned back into them), the date and the reason. We keep it to demonstrate that your request was completed and to prevent abuse; it contains no profile, progress or content. While a deletion is pending we also keep the deletion request itself (account identifiers and the scheduled date) so it can run or be cancelled if you restore the account.

If you use the App without signing in with Google or Apple (a guest account), deletion works the same way, except that a guest account has no sign-in method and therefore cannot be restored after you delete it. The App clears local app data on the device immediately and sends the deletion request to our servers in the background; for a guest account, server-side deletion starts as soon as our servers receive the request and confirm that no Google or Apple sign-in is linked to the account, because a guest account cannot be restored; if that cannot be confirmed at that moment, the ordinary 14-day period applies. If the request cannot reach our servers at that moment (for example, if the device is offline), the App keeps the deletion pending and sends the request again the next time it starts with a connection. If you uninstall the App before that happens, contact us as described below.

If you cannot access the App, if the in-app deletion request does not complete, or if you want follow-up, contact support.phraseman@gmail.com. We may need to verify your request before acting on it.

Some records may remain when retention is required or permitted for legal compliance, payment/tax/accounting, fraud prevention, security, dispute handling, chargebacks/refunds, moderation integrity, backups, or data stored by app stores and third-party processors. Deleting the account does not automatically cancel an active App Store or Google Play subscription; you must cancel it in the store subscription settings.

21. Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, object to processing, port your data, withdraw consent, opt out of certain processing, and complain to a data protection authority. You may lodge a complaint with the Irish Data Protection Commission or your local supervisory authority.

To exercise rights, email support.phraseman@gmail.com with subject "Privacy Request". We may need to verify your identity, request additional information, refuse or limit requests where permitted by law, and retain limited records of requests and responses.

22. US state privacy rights

California and other US state residents may request information about categories of personal information collected, sources, purposes, disclosures, and deletion/correction where applicable. We do not sell personal information. We do not knowingly share personal information for cross-context behavioral advertising unless this Policy and applicable store disclosures are updated to say so.

Categories of personal information we may collect include identifiers, app/account identifiers, commercial information, internet or electronic activity, approximate device/app information, inferences from app activity, learning progress and AI personalisation signals, user-generated content, support communications, transcripts or recognised text if you use voice features, and other information you provide or generate through App features.

23. International transfers

Knowly, service providers, and app platforms may process information in countries other than your country of residence. Where required, we rely on appropriate safeguards, contractual commitments, platform terms, service-provider security measures, and other lawful transfer mechanisms.

24. Security

We use technical and organisational measures such as Firebase security rules, authenticated Cloud Functions, TLS/HTTPS, access controls, logging, abuse monitoring, and operational controls. No system is perfectly secure, and we cannot guarantee absolute security.

25. Changes

We may update this Policy from time to time. Material changes will be reflected in the "Last updated" date and may include in-app notice, website updates, consent prompts, or store disclosure updates where practicable or required. Continued use of the App after changes means you acknowledge the updated Policy where permitted by law.

26. Contact

Knowly - Phraseman
Email: support.phraseman@gmail.com

Use this contact for privacy requests, parental requests, account deletion, support, legal notices, and questions about this Policy.