Privacy Policy

Definitions of Terms

“We” / “Us” / “Company” / “Application administration”

Ozzio Apps, operated by Konokhov Oleksandr Oleksandrovych, an individual entrepreneur (FOP / Фізична особа-підприємець) registered in Ukraine (D-U-N-S: 667631442).

“Application “ViaWords”” (hereinafter – “Application” / “App” / “Service”)

Software installed on smartphones and/or other hardware devices that enables the use of the Application on supported platforms, through which, via the Internet, the User can access the relevant data and functionality of the Application provided by the Application Administration. The App is currently available on Android via Google Play. An iOS version distributed via the Apple App Store is planned; this Privacy Policy will apply equally to that version when it is released.

• Google Play link: The link will be added w Google Play listing is approved.
• App Store link: Not currently available. An iOS version and App Store listing are planned; the link will be added when published.

“Confidentiality of personal data”

The requirement not to allow the distribution of personal data (mandatory for compliance by the Administrator or another person who has access to personal data) without the consent of the subject of personal data or the presence of another legal basis. Mandatory for compliance by the Administrator or another person who has gained access to personal data.

“User”

A person who uses the Application and has agreed to comply with the Application Terms and conditions.

“Personal data”

Any information relating directly or indirectly to an individual (subject of personal data).

“Processing of personal data”

Any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.

“Terms of Service” / “Terms”

The conditions governing the use of the Application, which are an integral part of this Contract and are available at the link: Terms of Service.

“IP address”

A unique network address of a node in a computer network built according to the IP protocol.

General Information

This Personal Data Privacy Policy (hereinafter referred to as the “Privacy Policy”) applies to information that we process about you when you use the Application. We apply appropriate technical and organizational measures to protect personal data in accordance with applicable law and as described in this Privacy Policy.

In this document you will find a description of the categories of personal data we process; the purposes and legal bases of processing; how and for how long we process personal data; your rights; and other relevant provisions. If you have any questions after reading this document, you can contact us at: [email protected].

This Privacy Policy has been developed to confirm the compliance of the services provided by the Application with the provisions of the Law of Ukraine “On Personal Data Protection”, the General Data Protection Regulation, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”), the California Online Privacy Protection Act (“CalOPPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Utah Consumer Privacy Act (“UCPA”) and other laws governing the interaction with personal data of Internet users.

Data Retention

We process your personal data for as long as you have an active relationship with us (an active User account) and for as long as needed to fulfill the purposes described in this Privacy Policy, the Terms of Service, and/or other contractual obligations, unless a longer retention period is required or permitted by applicable law.

As a general rule, personal data provided during registration and generated through your use of the App is retained for up to one year after your last account activity, after which it is deleted or irreversibly anonymized.

If you delete your User account (an option available within the App), we will delete the information associated with it, including your account content, usage data, and contact details, unless we are required to keep certain data for legal reasons under applicable legislation (for example, transaction records). As an exception, we retain the e-mail address used during registration, on the basis of our legitimate interest in preventing account duplication, abuse of free trials or promotions, and related fraud.

We do not sell or share your personal data (within the meaning of the California Consumer Privacy Act, as amended).

Restrictions on Sensitive Data

Our Application is designed solely for educational purposes to support language learning and is not intended for the storage of sensitive or special categories of data. This includes, but is not limited to: passwords of third-party services, financial details, health data, or any other confidential or sensitive information. However, we reserve the right to collect, store, use and dispose of User’s personal information on the terms defined by this Policy.

Children’s Privacy

Our Application is not intended for anyone under the age of 13, or under the higher minimum age required for consent to the processing of personal data in your jurisdiction (up to 16 in certain member states of the European Union). We do not knowingly collect personal information from children below the applicable minimum age. If we discover such data, we will delete it from our servers promptly. If you are a parent or guardian and believe your child has provided personal information to us, please contact us so we can take the necessary steps. You can contact us at: [email protected].

Acceptance of the Privacy Policy

By this Privacy Policy, we inform you about how we process your personal data: how we collect, use, and share the data that you may provide to us while using our Application. By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy and the way we handle your information as described here.

Legal Bases for Processing

• 1. Clause “a” of paragraph 1, Article 6 GDPR: Your consent of processing for Your personal data for the purposes stated in this Policy.
• 2. Clause “b” of paragraph 1, Article 6 GDPR: in case the processing of Your personal information is required for the performance of a contract to which You are the subject.
• Article 6(1)(c) GDPR: compliance with a legal obligation to which we are subject, for example retention of transaction records for tax and accounting purposes.
• Article 6(1)(f) GDPR: our legitimate interests, including securing the Service, preventing fraud and abuse, analyzing and improving the Service, and defending legal claims, provided such interests are not overridden by your rights and freedoms.

What Data We Collect

For a better experience while using our Application, we may require you to provide us with certain personally identifiable information, including:

Personal Identification Data

Name and email address.

Account and Transaction Details

Preferences related to your account, transaction records (e.g., purchased subscriptions and payment amounts), and any additional information you choose to provide. Note that payments are processed by the app store through which you obtained the App (currently Google Play); we do not receive or store your full payment card details.

Usage, Log, and Device Data

Information about App usage (e.g., visit frequency, session duration, features used, screens viewed, and actions taken within the App), IP address (which may indicate your general location), device type, unique device identifiers (including, where you have given any required consent, the advertising identifier), language settings, operating system and version, time zone, and the date and time of your use of the App.

Content You Provide

Words, translations, notes, learning goals, and other content you enter into the App.

How We Collect Your Data

We collect data through:

Direct Input from You

When you enter words, translations, or other details in text fields; provide your email address for account creation; or answer questions about your learning goals.

Account Sign-In

When you create an account with your email address or sign in with Google, we receive basic information such as your email address and, where provided, profile details. The App may also offer additional sign-in methods (for example, Facebook Login). If you choose to use such a method, we receive the account information you authorize through that provider.

Automated Means

Usage data (e.g., how you use the App), device details (e.g., device type, operating system, IP address), ad interactions (e.g., views and clicks), crash and diagnostics data, Remote Config and App Check signals, and transaction information for purchases.

Purposes of Data Usage

We use your data to:

• Support, operate, maintain, secure, and improve the Service.
• Enable you to access and use the requested services, including sending technical notifications, updates, and support communications.
• Process transactions and deliver related confirmations or receipts.
• Provide customer service and support.
• Provide AI-assisted language learning features (such as translations, definitions, and examples).
• Inform you about services, features, surveys, promotions, and updates relating to the App.
• Manage survey entries and rewards.
• Analyze usage trends and activities to improve the Service and, where permitted, for marketing or advertising purposes.
• Detect and prevent fraud, unauthorized access, or illegal activities.
• Personalize the Service to align with your preferences.
• Show advertising and manage advertising consent where applicable.

Third-Party Services

We use a set of trusted third-party services to ensure the App functions correctly, to analyze performance, and to improve the user experience. These services may collect and process certain data on our behalf as processors, or, in some cases, as independent controllers under their own privacy policies.

Authentication (Identity Providers)

We currently support email/password sign-in and Google Sign-In. The App may also offer other identity providers (for example, Facebook Login) when enabled in your version of the App. When you create an account or sign in, we collect your name (where provided) and email address to create and maintain your account.

Data collected:

• Name and email address.
• Language preference and unique user identifier.
• Time zone and calendar settings.

We only access data that you explicitly authorize through the applicable consent or credential flow. The purpose of this processing is account creation and security.

Firebase Services

We use Google Firebase services, including Authentication, Firestore, Cloud Functions, Remote Config, App Check, Google Analytics for Firebase, and Crashlytics. These services process device identifiers, usage data, and crash and diagnostics data to operate the App, protect it against abuse, understand how it is used, and diagnose and fix errors. For more information, see Google’s privacy documentation for Firebase.

AI-Assisted Features

Certain features of the App (such as translations, definitions, and example sentences) are provided using Google’s AI services (Firebase AI / Gemini). The text you enter for these features (for example, words or phrases to be translated or explained) is transmitted to and processed by Google to generate the response. We do not use your content to train our own generalized AI or machine learning models.

Advertising

The free version of the App may display advertising served by Google AdMob. AdMob may collect and process your device’s advertising identifier, IP address, and ad interaction data (e.g., views and clicks) to serve and measure ads. Where required by applicable law (for example, in the European Economic Area and the United Kingdom), we use the Google User Messaging Platform (UMP) to ask for your consent before personalized advertising is shown; if you do not consent, non-personalized ads may be shown instead. You can change your advertising consent choices in the App’s settings and limit ad personalization in your device settings.

Optional Sign-In Providers (e.g., Facebook Login)

We may enable additional sign-in options, including Facebook Login via the Facebook SDK (Meta Platforms). These options may not be available in all versions of the App or in all regions.

If Facebook Login (or a similar option) is available and you choose to use it:

• We receive the basic account information you authorize (typically name and email address) to create or link your App account.
• Meta may process data under its own privacy policy and terms as an independent controller or as otherwise described by Meta.

How We Use Google User Data

Google User Data (data received via Google APIs, including Google Sign-In) is used solely for:

• User authentication.
• Providing and improving the user experience within the Application.

We do not use Google User Data for:

• Advertising purposes.
• Selling data to third parties.
• Building advertising profiles.
• Training generalized AI or machine learning models.

The Application’s use and transfer to any other app of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Data Sharing Practices and Disclosure

We will not use or share your information with anyone except as described in this Privacy Policy.

We do not sell Google User Data or any other personal data to third parties.

We may share limited data with trusted third-party service providers strictly as necessary to operate the Application (such as cloud hosting, analytics, billing, and infrastructure providers), and only to the extent required for Service functionality, for the following purposes:

• To facilitate our Service.
• To provide the Service on our behalf.
• To perform Service-related services.
• To assist us in analyzing how our Service is used.

These service providers are authorized to use your personal data only as necessary to provide services to us and are required to maintain appropriate data protection and security standards.

We may also disclose personal data where required by law, court order, or a binding request of a competent authority, or where necessary to establish, exercise, or defend legal claims.

Data Protection and Security

We implement industry-standard security measures to protect user data, including:

• Encryption in transit (TLS/HTTPS).
• Restricted access controls.
• Secure cloud infrastructure.
• Authentication and authorization safeguards.

Security Limitations

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it as described in this Privacy Policy. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

International Data Transfers

Primary storage

Our primary data storage is hosted in the European Union (see “Data Storage Practices” below). Some of our service providers (including Google and, where enabled, Meta) are located in, or may transfer data to, the United States and other countries outside the European Economic Area.

Transfers outside the EEA/UK/Switzerland

Where personal data of users in the European Economic Area, the United Kingdom, or Switzerland is transferred to countries that do not provide an adequate level of data protection, such transfers are carried out on the basis of appropriate safeguards, in particular the European Commission’s adequacy decisions (including the EU-U.S. Data Privacy Framework, where the recipient is certified) and/or standard contractual clauses approved by the European Commission.

Data Storage Practices

For information storage we use Google Firebase services, with Cloud Functions in the region europe-west3 (Frankfurt, Germany) (referred to as “our servers” together with the related Firebase/Google infrastructure used by the App). Data retention periods are described in the “Data Retention” section above.

Google User Data is retained only for as long as necessary to provide the Service functionality. You may at any time:

• Revoke the App’s access to your Google account through your Google security settings.
• Request deletion of your data.
• Delete your Application account within the App.

Your Data Protection Rights

We aim to ensure you are aware of your data protection rights, which may apply depending on applicable law. These include:

Right to Access

Request confirmation of whether we process your personal data and obtain a copy of it. The first copy is provided free of charge; a reasonable fee may be charged only for additional copies or for requests that are manifestly unfounded or excessive.

Right to Rectification

Request correction of inaccurate or incomplete data. Note that you can edit most user-provided data (e.g., words, translations, notes) directly in the App. For data processed by third-party services acting as independent controllers (e.g., Google), please also refer to their policies.

Right to Erasure

Request deletion of your data under certain conditions, including by deleting your account in the App.

Right to Restrict Processing

Request limitations on data processing under specific circumstances, where feasible given our reliance on third-party services.

Right to Object

Object to data processing under certain conditions, such as for analytics or advertising purposes.

Right to Data Portability

Request transfer of your data to another entity or to yourself under specific conditions, limited to data you have provided directly to us.

Right to opt out

Request the suspension of personal information processing. This may result in suspension and/or termination of your User’s Profile within the Application.

To exercise your data protection rights, contact us at: [email protected].

Links to Other Sites

The Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the privacy policy of every site you visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

Contact Us

For questions, requests, and other issues concerning this Privacy Policy, contact us at: [email protected].

Changes to This Privacy Policy

We may modify this Privacy Policy from time to time, including to comply with legal requirements and to reflect changes in our data processing practices. We will notify you by updating the Privacy Policy within the App and indicating the date of the latest revision; where required by law or where the changes are material, we may additionally notify you by email or through an in-App notice. Your continued use of the App after such updates signifies your acceptance of the revised Privacy Policy. You are fully responsible for any violation of this Policy and any resulting consequences, including any harm or loss to us. We recommend that you review this Privacy Policy periodically.

Miscellaneous

GDPR / UK GDPR

For users from the European Union - we comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (“GDPR”). For users in the United Kingdom, we comply with the GDPR as enshrined in the Data Protection Act 2018. We have not appointed a Data Protection Officer (DPO) as we do not fall into the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

Cookies

The Application Administration does not collect, store, process, or otherwise use cookies during the operation of the Application. The functioning of the Application does not require the use of cookies, and therefore information about the User’s actions is not recorded using such tools.