Privacy Policy

1. Introduction

Vokab ("the app") is a vocabulary learning application available on iOS, macOS, visionOS, and watchOS. The app is developed and operated by Mindroot Ltd, a company registered in England and Wales (company number 16543299), with its registered office at 71-75 Shelton Street, London, England, WC2H 9JQ.

Mindroot Ltd is the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are registered with the Information Commissioner's Office (ICO) under registration number ZB958997.

This Privacy Policy explains what data the app collects, how it is stored, and how it is used.

2. Data We Collect

Vokab collects and stores the following data locally on your device:

• Learning progress, including streak count, words learned, and mastery levels
• Subscription status
• Theme preference (light or dark mode)

When iCloud is enabled, the following data is synced via Apple's CloudKit:

• Learning progress and mastery data
• Category completion status

We do not collect your name, email address, location, IP address, or any other personally identifiable information. The app does not require you to create an account or provide any personal details to use it. Your Apple ID is used solely by Apple for iCloud sync and App Store subscriptions.

3. Legal Basis for Processing

Under UK GDPR Article 6, we process your data on the following lawful bases:

• Contract performance (Article 6(1)(b)) — Processing is necessary to provide the app's core functionality, including saving your learning progress and syncing data across your devices.
• Legitimate interests (Article 6(1)(f)) — Processing is necessary for our legitimate interests in improving the app and ensuring it functions correctly, where those interests are not overridden by your rights.

4. How Your Data Is Stored

Your data is stored in the following ways:

• UserDefaults — Local on-device storage for preferences and progress data.
• App Groups — Local shared storage between the main app and its widgets (e.g., streak count, words learned). This data does not leave your device.
• CloudKit — Apple's cloud database service, which stores your learning progress in your private iCloud database. This data is accessible only to you through your Apple ID. Mindroot Ltd does not have access to your CloudKit data.

We do not operate any external servers or databases. All data processing occurs either on your device or within Apple's infrastructure.

5. Third-Party Services

Vokab does not integrate any third-party analytics, tracking SDKs, or advertising frameworks. The only third-party services involved are those provided by Apple:

• App Store — For app distribution and subscription management.
• CloudKit — For syncing your learning progress across devices.
• App Analytics — Apple's built-in analytics, which Apple manages according to their own privacy policy.

All content within the app, including definitions and audio pronunciations, is bundled directly within the app. The app does not make network requests to third-party APIs during use.

6. Subscriptions and Payments

Vokab offers optional subscription plans that unlock additional features. All subscriptions are managed through Apple's App Store using StoreKit. We do not collect, process, or store any payment or billing information. All payment processing is handled entirely by Apple.

7. Data Retention

Data stored locally on your device (UserDefaults and App Groups) is deleted when you uninstall the app. Data stored in CloudKit persists in your iCloud account and can be managed through your iCloud settings. Mindroot Ltd does not retain any copy of your data.

8. International Data Transfers

CloudKit data may be stored on Apple's servers in various locations globally, in accordance with Apple's infrastructure and policies. Mindroot Ltd does not transfer your data internationally and has no access to your CloudKit data. For information on how Apple handles international data transfers, please refer to Apple's Privacy Policy.

9. Your Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

• Right of access (Article 15) — You can request a copy of your personal data.
• Right to rectification (Article 16) — You can request correction of inaccurate data.
• Right to erasure (Article 17) — You can request deletion of your data.
• Right to restriction of processing (Article 18) — You can request that we limit how we use your data.
• Right to data portability (Article 20) — You can request your data in a portable format.
• Right to object (Article 21) — You can object to processing based on legitimate interests.

Since all data is stored either locally on your device or in your private iCloud account, you can exercise most of these rights directly by managing your device and iCloud settings. To make a formal request, please contact us at team@vokab.net.

10. Complaints

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• Phone: 0303 123 1113
• Website: ico.org.uk

11. Children's Privacy

Vokab is rated 17+ on the App Store due to the inclusion of a sexology vocabulary category. The app is not directed at children under 17. We do not knowingly collect personal information from children.

12. Cookies and Tracking

The Vokab app does not use cookies or any tracking technologies. The Vokab website (vokab.net) uses only localStorage to remember your theme preference (light or dark mode) and does not use cookies or third-party tracking.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be reflected on this page with an updated "Last updated" date. For material changes, we will update the App Store listing to notify users. Continued use of the app after changes constitutes acceptance of the revised policy.

14. Related Documents

Please also review our Terms of Use, which govern your use of the app.

15. Contact Us

If you have any questions about this Privacy Policy, please contact us:

• Email: team@vokab.net
• Post: Mindroot Ltd, 71-75 Shelton Street, London, England, WC2H 9JQ
• Company number: 16543299 (England and Wales)
• ICO registration: ZB958997