Privacy Policy

1. Introduction

Abbika LLC ("we," "us," or "VerbPal") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and website (collectively, the "Service").

We comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) for our European users.

2. Information We Collect

Information Stored on Your Device

VerbPal works without an account. The following stays on your device and is not sent to us:

• Profile: Your first name (optional), learning language, experience level, learning goals, daily goal, and reminder settings
• Learning Data: Your progress, exercise answers, accuracy, streaks, and course progress
• Voice & Pronunciation: In speaking exercises, your speech is recognized on your device to check your pronunciation. Neither the audio nor the recognized text is sent to us or any third party.

Backups

VerbPal keeps a copy of your progress in your own iCloud account (iOS) or, if you connect it, your own Google Drive (Android), so you can restore it on a new device. Android may also include it in your device's backup. These copies are stored by Apple or Google under your account; we cannot access them.

Information We Collect

• Usage Analytics: Which screens you view and which features you use, such as completing an exercise, a game or a lesson, along with your profile answers from onboarding (learning language, experience level, goals, daily goal, whether reminders are on), your progress totals (verbs learned, streak, sessions completed), and whether you have Premium. These are linked to a random identifier created for your installation, never to your name or email address. We do not send your name, even if you give one.
• Device Information: Device type, operating system, app version, approximate location derived from your IP address (country and city), and, on Android, your device's advertising ID (see TikTok below)
• Partner Codes: If you enter a partner's referral code, we record the code against your random identifier so the partner can be credited
• Communications: Messages you send to our support team

Accounts Created Before Version 1.5

Versions of VerbPal before 1.5 (October 2026) required an account. If you created one, we still hold its email address, name, and learning data so that you can sign in and move your progress to your device. When you do, your progress is copied to your device. You can delete the account and its data at any time with Delete my data on the Profile tab, or by contacting us.

Payment Information

Payment processing is handled by RevenueCat and the respective app stores (Apple App Store, Google Play). We do not directly store your payment card details.

3. How We Use Your Information

We use the information we collect to:

• Provide and personalize the VerbPal learning experience
• Schedule your reviews using the SM-2 spaced repetition algorithm
• Check your pronunciation in speaking exercises (your speech is recognized on your device)
• Track and display your progress, streaks, and achievements
• Send you reminders and notifications (if enabled); these are scheduled on your device
• Back up and restore your progress (in your own iCloud or Google Drive)
• Process subscription payments and credit partner referrals
• Respond to your support requests
• Improve our Service through analytics
• Measure the effectiveness of our advertising campaigns
• Ensure the security of our Service

4. Automated Decision-Making

VerbPal uses automated processing to personalize your learning experience. This includes:

• Spaced Repetition Scheduling: Our SM-2 algorithm automatically determines when to show you specific verbs for review based on your past performance
• Exercise Selection: The system selects exercise types and difficulty levels based on your progress and accuracy
• Progress Tracking: Mastery levels are automatically calculated based on your responses

These automated processes are designed solely to optimize your learning experience and do not have legal or similarly significant effects on you. You can contact us if you have concerns about this processing or wish to understand more about how these decisions are made.

AI-Generated Content

Some learning content, such as example sentences, their translations, and course lessons, is generated with AI. It is created in advance and included in the app; none of your data is sent to an AI service.

5. Third-Party Services

We work with trusted third-party services to provide VerbPal:

• RevenueCat: Subscription and payment processing. RevenueCat creates the random identifier for your installation.
• PostHog: Product analytics, as described in section 2, linked to your random identifier
• Convex: Backend services: partner referral codes, and the data of accounts created before version 1.5
• Clerk: Sign-in for accounts created before version 1.5
• TikTok: Advertising measurement, to understand whether our TikTok ad campaigns lead to app installs and subscriptions. The TikTok Business SDK receives app events (app launch, sign-up, onboarding completion, checkout start, and trial or subscription start, including the product and price) along with device information. On Android, this includes your device's advertising ID. On iOS, we do not request permission to track you, and measurement relies on Apple's privacy-preserving SKAdNetwork. We do not send TikTok your name, email address, or learning data. See TikTok's Privacy Policy.

These providers have their own privacy policies and are contractually obligated to protect your data.

Refund Requests to Apple

If you ask Apple for a refund of a VerbPal purchase, Apple may ask us about your use of the app. We, through RevenueCat, may answer with information such as how long you have been a customer, roughly how much you have used VerbPal, and your purchase and refund history with us. We never send your name, email address, or learning content. Apple decides the refund.

Advertising ID Choices

On Android, you can reset or delete your advertising ID at any time in your device settings (Settings > Privacy > Ads, or Settings > Google > Ads, depending on your device). Once it is deleted, apps, including VerbPal, can no longer access it.

6. Data Sharing and Disclosure

We do not sell your personal information. We may share your data only in these circumstances:

• With service providers who help us operate VerbPal (as listed above)
• With advertising partners (TikTok) to measure our ad campaigns, as described above
• If required by law, such as in response to a court order
• To protect the rights and safety of VerbPal, our users, or others
• In connection with a merger, acquisition, or sale of assets (you would be notified)

7. Data Retention

• On your device and in your backup: Kept until you delete them. Delete my data on the Profile tab deletes your progress on the device and your iCloud or Google Drive copy. Uninstalling the app deletes the device copy only.
• Usage analytics: Pseudonymous and linked only to your random identifier. Delete my data does not delete analytics already collected. To have them deleted, contact us and we will delete them within 30 days.
• Accounts created before version 1.5: Kept until you delete them. Delete my data, while signed in, deletes the account and its learning data immediately.
• Purchase records: Kept by RevenueCat and the app stores as required for accounting and legal purposes.

Versions before 1.5 stored the recognized text of speaking exercise answers for up to 90 days. Current versions no longer send it, and the remaining text is deleted automatically.

8. Your Rights

Rights for All Users

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your personal data
• Portability: Request an export of your data in a portable format
• Objection: Object to certain processing of your data
• Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, please contact us using the information below.

California Residents (CCPA/CPRA)

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

• Right to Know: Request details about the categories and specific pieces of personal information we have collected, used, disclosed, or sold about you
• Right to Delete: Request deletion of your personal information, subject to certain exceptions
• Right to Opt-Out: Opt-out of the sale or sharing of your personal information. Note: VerbPal does not sell your personal information
• Right to Limit: Limit the use and disclosure of sensitive personal information
• Right to Non-Discrimination: Not receive discriminatory treatment for exercising your privacy rights

To exercise these rights, please contact us through our Contact Form. We will respond to verifiable consumer requests within 45 days.

Other U.S. State Privacy Rights

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with comprehensive privacy laws may have similar rights to access, correct, delete, and port their personal data, as well as to opt out of certain processing activities. Please contact us to exercise these rights.

9. Children's Privacy

VerbPal is intended for users who are at least 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately.

10. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including the United States. We ensure appropriate safeguards are in place to protect your data, including:

• Standard Contractual Clauses: We use European Commission-approved Standard Contractual Clauses when transferring data from the EEA, UK, or Switzerland
• Data Processing Agreements: We maintain data processing agreements with our service providers that include appropriate data protection obligations
• Security Measures: We implement technical and organizational measures to protect data during transfer and processing

For more information about the safeguards we use, please contact us.

11. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet is 100% secure.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. We encourage you to review this page periodically.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Through our Contact Form
• By visiting our Contact Page

For GDPR-related inquiries, EU residents may also contact your local data protection authority.