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Vocab Builder Privacy Policy

Last Updated: March 12, 2025
Effective Date: March 12, 2025

Table of Contents

  1. Introduction
  2. Definitions
  3. Data Collection
  4. Data Processing Locations
  5. Third-Party Platforms
  6. Google Workspace API Usage
  7. Data Usage
  8. Data Sharing and Disclosure
  9. Cookies and Tracking Technologies
  10. Your Rights
  11. Children's Privacy
  12. Security
  13. Data Retention
  14. Changes To This Privacy Policy
  15. Contact Us

1. Introduction

Welcome to Vocab Builder. This Privacy Policy is designed to help you understand how Vocab Builder (the "App"), developed and operated by Unlocked Learning (ADMANAGE LIMITED) ("we," "us," or "our"), collects, uses, shares, and safeguards your information when you use our mobile application and related services (collectively, the "Services").

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy or our practices with regard to your personal information, please contact us at raph@admanage.ai.

By downloading, accessing, or using the Vocab Builder app, you agree to the collection and use of information in accordance with this policy. This Privacy Policy applies to all users of our Services globally, though certain provisions may apply differently depending on your location and applicable laws.

Please read this Privacy Policy carefully as it will help you understand what we do with the information that we collect.

2. Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for you to access our Services or parts of our Services.
  • App refers to Vocab Builder, the mobile application provided by Unlocked Learning (ADMANAGE LIMITED).
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to ADMANAGE LIMITED, London, United Kingdom.
  • Developer refers to Unlocked Learning, the developer account name under which the App is published.
  • Device means any device that can access the Service such as a mobile phone, tablet, or computer.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the App and any related services provided by Unlocked Learning (ADMANAGE LIMITED).
  • Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

3. Data Collection

3.1 Information You Provide to Us

We may collect several types of information from and about users of our App, including:

  • Account Information: When you register for an account, we collect your name, email address, username, password, and profile information.
  • User Content: Information you provide when using the App, such as vocabulary lists, study notes, learning progress, and other content you create or upload.
  • Communications: Records and copies of your correspondence if you contact us, including email addresses and support requests.
  • Transaction Information: Details of any purchases or subscriptions you make through the App, including payment information, billing address, and transaction history.
  • Survey Responses: Information you provide when responding to surveys or questionnaires about the App.

3.2 Information We Collect Automatically

When you use the Vocab Builder app, we automatically collect certain information, including:

  • Device Information: Information about your mobile device and internet connection, including device type, operating system, unique device identifiers, IP address, mobile network information, and device settings.
  • Usage Information: Details of your visits to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use within the App.
  • Performance Data: Information about App performance, including crash reports, app features used, and other diagnostic data.
  • Location Information: With your consent, we may collect precise or approximate location information from your device.
  • Learning Analytics: Data about your learning patterns, progress, strengths, and areas for improvement to enhance your vocabulary learning experience.

3.3 Information from Third Parties

We may receive information about you from third parties, including:

  • Social Media Platforms: If you choose to link your account with a social media platform, we may receive information from that platform, such as your profile information.
  • Analytics Providers: We work with analytics providers to help us understand how users interact with our App.
  • Marketing Partners: We may receive information from marketing partners to provide you with relevant content, promotions, and advertisements.

In addition, we may use third-party services such as Facebook and TikTok APIs that collect, monitor, and analyze information to increase our app's functionality. These third-party service providers have their own privacy policies addressing how they use such information.

4. Data Processing Locations

To support our global operations and provide you with the best experience, we store and process data in various locations around the world, including:

  • United Kingdom: Our primary data processing location where our headquarters are based.
  • European Economic Area (EEA): We maintain servers and processing facilities within the EEA to serve our European users efficiently.
  • United States: Some data processing occurs in the US through our service providers and cloud infrastructure.

When transferring data outside the UK/EEA, we ensure appropriate safeguards are in place through standard contractual clauses and adequacy decisions approved by the relevant authorities. We implement technical and organizational measures to ensure a level of security appropriate to the risk.

By using the Vocab Builder app, you consent to the transfer of your information to these locations, which may have different data protection rules than your country. Regardless of location, we handle your personal data in accordance with this Privacy Policy and applicable laws.

5. Third-Party Platforms

The Vocab Builder app may integrate with various third-party platforms to enhance functionality and user experience. When you connect your Vocab Builder account with these platforms, their privacy policies will also apply to information shared between services:

  • Social Media Integration:

    When you connect with social media platforms like Facebook, Instagram, or TikTok, we may receive profile information, friend lists, and other data according to your privacy settings on those platforms.

    • Meta (Facebook & Instagram) Privacy Policy
    • TikTok Privacy Policy
  • Learning Content Providers:

    We may partner with educational content providers to offer vocabulary lists and learning materials. These partnerships may involve data sharing to personalize your learning experience.

  • Authentication Services:

    We may use third-party authentication services (like Google Sign-In or Apple ID) to simplify the login process. These services provide us with basic account information according to your settings.

We recommend reviewing these platforms' privacy policies to understand how they process your data when you use their services through our app. You can control these integrations through your account settings in the Vocab Builder app.

6. Google Workspace API Usage

Vocab Builder may utilize certain Google APIs to enhance functionality, such as allowing you to import vocabulary lists from Google Docs or save your learning progress to Google Drive. In relation to these integrations, we want to make the following clear:

  • Limited Use Disclosure: Our use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.
  • No AI Training: We do not use Google Workspace APIs, including the Google Drive API, to develop, improve, or train generalized AI and/or machine learning models. Your data is not utilized for these purposes, and we prioritize your privacy and data security.
  • Functional Use Only: We do not retain any Google user data obtained through Workspace APIs for the purpose of developing, improving, or training generalized AI/ML models. Any data collected is used solely for the functionality of our service and is not shared with third-party AI tools for these purposes.

You can revoke Vocab Builder's access to your Google account at any time by visiting your Google Account Permissions.

7. Data Usage

7.1 How We Use Your Information

We use the information we collect about you for various purposes, including:

  • Providing and Improving the App: To deliver the Vocab Builder app and its features, analyze usage patterns, and develop new features and functionality.
  • Personalizing Your Experience: To customize vocabulary lists, learning paths, and recommendations based on your proficiency level, interests, and learning history.
  • Adaptive Learning: To implement spaced repetition algorithms and other learning techniques that adapt to your progress and retention rates.
  • Communication: To communicate with you about your account, respond to inquiries, provide customer support, and send important notices and updates.
  • Marketing and Promotion: With your consent, to inform you about new features, premium offerings, and educational content related to Vocab Builder.
  • Research and Analytics: To conduct research and analysis to improve language learning methodologies and educational outcomes.
  • Security and Fraud Prevention: To detect, prevent, and address technical issues, security breaches, and fraudulent activity.
  • Legal Compliance: To comply with applicable laws, regulations, legal processes, or governmental requests.

7.2 Legitimate Interests

We may process your information for our legitimate business interests, which include:

  • Improving and personalizing the Vocab Builder app and services
  • Developing new products, services, and features
  • Understanding how users interact with our app
  • Marketing and promoting our services (subject to your marketing preferences)
  • Protecting our legal rights and preventing fraud
  • Ensuring the security of our app and infrastructure

We balance our interests with your privacy rights and will not process your data in a way that would override your fundamental rights and freedoms.

8. Data Sharing and Disclosure

8.1 When We Share Your Information

We do not sell, trade, or rent users' personal data to third parties. However, we may share your information in the following circumstances:

  • Service Providers: We share information with third-party vendors, consultants, and other service providers who perform services on our behalf, such as:
    • Cloud hosting and storage providers
    • Analytics and data processing companies
    • Customer support services
    • Payment processors
  • Business Transfers: If Vocab Builder is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our App of any change in ownership or uses of your personal information.
  • Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
  • Protection of Rights: We may disclose information to protect the safety, rights, or property of ADMANAGE LIMITED, our users, or others, and to investigate fraud or respond to a government request.
  • With Your Consent: We may share your information with third parties when you have given us your consent to do so.

8.2 Aggregated and Anonymized Data

We may share generic aggregated and anonymized information with our business partners, trusted affiliates, and advertisers for research, marketing, and analytics purposes. This information cannot reasonably be used to identify you.

For example, we may publish anonymized statistics, trends, and insights about vocabulary learning patterns or create educational content and blog posts using aggregated, anonymous data.

You may opt out of this sharing by contacting us at raph@admanage.ai.

9. Cookies and Tracking Technologies

9.1 Types of Tracking Technologies We Use

Vocab Builder uses various tracking technologies to enhance your experience, analyze app usage, and deliver personalized content:

  • Cookies: Small text files stored on your device that help us recognize you and remember your preferences.
  • Local Storage: Data stored locally on your device to improve app performance and maintain your settings.
  • Analytics Tools: We use services like Google Analytics to collect information about how you use our app.
  • Mobile Device Identifiers: Unique IDs assigned to your mobile device that allow us to recognize your device across sessions.

9.2 How We Use These Technologies

We use tracking technologies for the following purposes:

  • Remembering your login status and preferences
  • Tracking your progress in vocabulary learning
  • Analyzing which features are most popular
  • Measuring the effectiveness of our marketing campaigns
  • Detecting and preventing fraudulent activity
  • Improving app performance and user experience

9.3 Your Choices

You can control tracking technologies in several ways:

  • Device Settings: Most mobile devices allow you to limit tracking through your device settings.
  • App Permissions: You can manage app permissions through your device settings.
  • Opt-Out: You can opt out of certain analytics tracking by contacting us.

Please note that if you disable cookies or other tracking technologies, you may not be able to use certain features of the Vocab Builder app.

10. Your Rights

10.1 Data Protection Rights

Depending on your location, you may have certain rights regarding your personal information. These may include:

  • Right to Access: You can request a copy of the personal information we hold about you.
  • Right to Rectification: You can request that we correct any inaccurate or incomplete information about you.
  • Right to Erasure: You can request that we delete your personal information in certain circumstances (also known as the "right to be forgotten").
  • Right to Restrict Processing: You can request that we restrict the processing of your information in certain circumstances.
  • Right to Data Portability: You can request that we provide you with your information in a structured, commonly used, and machine-readable format.
  • Right to Object: You can object to our processing of your personal information in certain circumstances.
  • Right to Withdraw Consent: Where we process your information based on your consent, you have the right to withdraw that consent at any time.

10.2 How to Exercise Your Rights

To exercise any of these rights, please contact us at raph@admanage.ai. We will respond to your request within 30 days.

To protect your privacy and security, we may need to verify your identity before processing your request. In some cases, we may need to keep certain information for legal or regulatory compliance purposes.

Note: Some data may need to be retained for legal or regulatory compliance purposes, even after you request deletion.

10.3 International Users

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have certain rights under applicable data protection laws, including those listed above.

If you are located in California, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

We will comply with applicable data protection laws when responding to your requests.

11. Children's Privacy

The Vocab Builder app is not intended for children under the age of 13 (or the applicable age of digital consent in your country). We do not knowingly collect personal information from children under this age.

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us at raph@admanage.ai. If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove that information from our servers.

If you are a parent or guardian and wish to review, modify, or delete your child's personal information, please contact us. We will accommodate your request to the extent required by applicable law.

12. Security

12.1 Our Security Practices

We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect your data. Our security practices include:

  • Encryption: All data is encrypted at rest and in transit using industry-standard encryption protocols (TLS/SSL).
  • Secure Infrastructure: We use secure cloud infrastructure with built-in safeguards and regular security updates.
  • Access Controls: Access to your data is strictly limited to authorized personnel who need it to perform their job functions.
  • Authentication: Multi-factor authentication is required for all internal systems that process user data.
  • Regular Audits: We conduct regular security audits and vulnerability assessments of our systems.
  • Penetration Testing: We perform periodic penetration testing to identify and address potential security weaknesses.
  • Incident Response: We have procedures in place to respond to potential data security incidents promptly.

12.2 Your Role in Security

While we implement safeguards to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We encourage you to take steps to protect your personal information, including:

  • Using strong, unique passwords for your Vocab Builder account
  • Not sharing your account credentials with others
  • Logging out of your account when using shared devices
  • Keeping your device's operating system and apps updated
  • Being cautious about connecting to unsecured Wi-Fi networks

12.3 Data Breach Notification

In the event of a data breach that affects your personal information, we will notify you and the relevant supervisory authorities as required by applicable law. We will provide information about the breach, the data affected, and steps you can take to mitigate potential harm.

13. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

  • Account Activity: We retain your account information and user-generated content for as long as your account is active.
  • Legal Obligations: We may retain certain information to comply with legal and regulatory requirements.
  • Operational Needs: We retain information needed for our legitimate business purposes, such as financial record-keeping and fraud prevention.
  • Technical Constraints: Some information may be retained in backup systems for a limited period as part of our disaster recovery procedures.

When you delete your account, we will delete or anonymize your personal information within 90 days, except for information that we are required to retain for legal, regulatory, or legitimate business purposes.

If you have been inactive for an extended period (typically 24 months), we may contact you to confirm your continued interest in our services before taking steps to anonymize your data.

14. Changes To This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, and other factors. When we make changes, we will update the "Last Updated" date at the top of this Privacy Policy and take other appropriate steps to notify you.

For significant changes that materially alter your rights or our use of your information, we will provide prominent notice through the Vocab Builder app or by sending you an email notification. We encourage you to periodically review this Privacy Policy to stay informed about our data practices.

Your continued use of the Vocab Builder app after the effective date of any revised Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the revised policy, please stop using the app and delete your account.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the information below:

Email: raph@admanage.ai

Developer Account: Unlocked Learning

Postal Address: ADMANAGE LIMITED, London, United Kingdom

For data protection inquiries specifically, you can contact our Data Protection Officer at dpo@admanage.ai.

We will respond to your inquiry as soon as possible and within 30 days as required by applicable law.

16. Jurisdiction-Specific Provisions

16.1 European Economic Area (EEA), United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, the following additional provisions apply:

  • Legal Basis for Processing: We process your personal data based on legitimate interests, consent, contractual necessity, or legal obligations as described in this Privacy Policy.
  • Data Controller: ADMANAGE LIMITED is the data controller responsible for your personal data.
  • Supervisory Authority: You have the right to lodge a complaint with your local data protection authority if you believe our processing of your personal data violates applicable law.

16.2 California Residents

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

  • The right to know what personal information we collect, use, disclose, and sell
  • The right to delete certain personal information
  • The right to opt-out of the sale of personal information
  • The right to non-discrimination for exercising your rights
  • The right to limit the use and disclosure of sensitive personal information

To exercise these rights, please contact us using the information in the "Contact Us" section.

Last updated: March 12, 2025

App & Company Details

App: Vocab Builder

Developer Account: Unlocked Learning

Organization Account ID: 6315704737074876705

Developer: ADMANAGE LIMITED

D-U-N-S Number: 231695703

Registration: 15650122

Location: London, United Kingdom

© 2025 ADMANAGE LIMITED. All rights reserved.

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