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Ellaword

Privacy Policy

Draft — not yet in force.

This document is being prepared for Ellaword AB, a Swedish company currently being formed. It has not yet been reviewed by a lawyer and does not yet bind anyone. Passages awaiting legal review are marked in the text. If you are relying on this, contact us first.

Last updated: 2026-09-07

1. Who we are

Ellaword is a Swedish language-learning application (iOS app and supporting website and API). This Privacy Policy explains what personal data we collect, why, how we protect it, and the rights you have over it.

The data controller responsible for your personal data is Ellaword AB, a limited company (aktiebolag) registered in Sweden. You can contact us about privacy at support@ellaword.com.

[AVUKAT — the organisationsnummer and registered office are filled in src/lib/legal.ts once Bolagsverket has registered the company; until then this policy is not in force, see the notice above.]

2. Information we collect

We keep the data we collect to the minimum needed to run the service:

  • Account data: your username, email address, and a securely hashed password (we never store your password in plain text), plus whether your email is verified.
  • Profile & preferences: avatar, theme, caption and display settings.
  • Learning data: your word lists, known/learned words, review history, accuracy counters, and gamification data (XP, streaks, active days, league standing, collected reward cards). This is the core of the product and is used to personalise your learning.
  • Subscription data: your subscription status and the identifiers Apple gives us for your purchase (transaction id, product id, environment, renewal/cancellation status). We never receive or store your card or payment details — all payment is handled by Apple.
  • Content you provide: the subtitle or text you bring in to generate word lists — pasted, scanned from a page, or imported from a YouTube video's subtitle track — and any cover images you upload.
  • Scanned pages (camera and photo library): if you use page scanning, the app asks for camera or photo-library access so you can photograph a page or pick one you already took. You mark which parts of the page to read, and only those parts are cropped and read. The text is recognised on your device, and the picture is never uploaded to us — the crops are held in the app's own temporary storage and deleted once they have been read, or when you discard the scan. Photos already in your library are never modified or deleted. Only the recognised text reaches our servers, where it is treated exactly like text you paste in yourself.
  • Device & notification data: a push-notification token so we can send you reminders and friend notifications (if you enable them).
  • Technical logs: standard server logs (such as request metadata) that we keep on our own servers to operate and secure the app.
  • Analytics data: to understand how the app is used and to improve it, we collect pseudonymous product-analytics through Google Firebase / Google Analytics (GA4). This is tied only to a device-level identifier (GA4's app-instance id) and includes device and app metadata (model, operating system, app version, language and country-level location) and a fixed set of usage events. It does not include your name, email, account id, the text you paste, titles, URLs, or purchase receipts. Analytics is on by default and you can turn it off in the app at any time — see “Analytics and your choices” below.

3. How and why we use your data

We use your data to:

  • create and secure your account, and authenticate you (necessary to perform our contract with you);
  • provide the learning experience and personalise your review schedule and progress (contract);
  • process and verify your subscription and unlock paid features (contract);
  • send you service emails such as verification and account-recovery messages (contract);
  • send optional push notifications you have enabled (your consent / legitimate interest);
  • understand how the app is used and improve its reliability through privacy-preserving analytics you can turn off (see “Analytics and your choices”);
  • keep the service secure, prevent abuse, and improve it (legitimate interest).

We do not show you ads, build advertising profiles, or track you across other apps and websites, and we do not sell your personal data.

4. Payments

Subscriptions are purchased through Apple's In-App Purchase system. Apple processes the payment and manages your billing; we only receive confirmation of your entitlement and the transaction identifiers needed to verify it. We do not see or store your payment-card information.

5. Service providers we share data with

We use a small set of trusted providers who process data only on our behalf and only to deliver or improve the service. We do not use advertising trackers or ad networks, and we do not sell your personal data.

  • Apple — subscription purchases, payment, and subscription status notifications.
  • Google Cloud Platform — hosting, database, and file storage. Your data is stored in the European Union (Sweden region).
  • Google Firebase / Google Analytics (GA4) — pseudonymous product-usage and reliability analytics (no name, email, or account identifier). Google processes this data, and some of it may be processed outside the EU/EEA — see “Analytics and your choices”.
  • Mailjet — sending transactional email (verification, account recovery, and privacy-request emails).
  • Expo / EAS — mobile app delivery and push-notification delivery.
  • Cloudflare — hosting of this website (static; it does not collect your personal data).
  • Google ML Kit — the text recognition behind page scanning. It runs entirely on your device: neither the picture nor the recognised text leaves your phone through it, and we receive no data from it. It is named here so the absence is stated rather than assumed.
  • YouTube (Google) — when you import a YouTube video, the app fetches that video's subtitle track, and its thumbnail image, directly from YouTube from your device rather than through our servers. That request is made by your phone, so YouTube receives it as it would any visit: your IP address, and the identifier of the video you chose. We do not send YouTube your account, your email, or anything else about you, and we receive nothing from YouTube about you — only the subtitle text, which is then treated exactly like text you paste in yourself. Listed here because it is a connection your device makes, not one our servers make on your behalf.
  • Gravatar (Automattic) — used only as a fallback avatar image on profile screens. Your phone requests the image, so Gravatar sees the request; we send it nothing about you.

6. Analytics and your choices

We use Google Firebase / Google Analytics (GA4) to understand how people use Ellaword and to improve the product. We have configured it to be privacy-preserving:

  • We collect a fixed set of product-usage events (such as completing onboarding, selecting a source, starting or finishing practice, viewing coverage, and paywall / purchase steps), together with device and app metadata and country-level location.
  • Analytics is tied only to a device-level, pseudonymous identifier(GA4's app-instance id). We never send your name, email, account id, the text you paste, titles, URLs, or purchase receipts, and we do not link analytics to your account.
  • We do not use analytics for advertising: there is no ad tracking, no Google Signals, and no advertising identifier (IDFA).
  • Analytics is on by default, and you can turn it off at any time with the “Share usage analytics” toggle in the app's settings — this is how you object to and opt out of analytics. Your choice is remembered on your device; because it is stored on the device, reinstalling the app returns it to the default (on).
  • Turning analytics off stops further collection and resets the analytics identifier on your device. It does not delete analytics data already collected on Google's servers, which is kept for about 2 months and then removed automatically. Deleting your account likewise does not erase analytics already collected, because it is not linked to your account.
  • Google may process some of this analytics data outside the EU/EEA (for example in the United States). [AVUKAT — which safeguard to cite: EU–US Data Privacy Framework, with Standard Contractual Clauses as a fallback.]

[AVUKAT — lawful basis and consent model for analytics that is on by default (legitimate interest with opt-out vs. opt-in consent) under Swedish LEK ch. 9 / ePrivacy; a written legitimate-interest assessment is expected. This one may not be a wording change: if the answer is opt-in, the app's default has to change, which is code. Public launch with analytics on by default is gated on it.]

7. Where your data is stored

Your account and learning data are stored on Google Cloud servers in the European Union (Sweden — the Stockholm region). That is where the database, the files you upload, and the application itself run.

Beyond that, data reaches other parties in three different ways:

  • Processors acting for us: Mailjet sends transactional email; Expo / EAS delivers the app and push notifications; Apple handles subscriptions; Cloudflare hosts this website. Each receives only what its job needs — an email address, a push token, a subscription identifier.
  • Google Firebase / Google Analytics: pseudonymous product analytics, tied to a device-level identifier and never to your account.
  • Connections your own device makes: importing a YouTube video, or loading a fallback avatar, contacts YouTube or Gravatar from your phone directly rather than through our servers — so those parties see your IP address as they would on any visit.

[AVUKAT — the list above is factual and complete as measured in the code. What is still a legal judgement: which of these involve a transfer outside the EU/EEA, and which safeguard to cite for each (adequacy decision, EU–US Data Privacy Framework, Standard Contractual Clauses). The device-side connections in particular may be a different question than the processor relationships, since we neither contract with those parties nor send them anything ourselves.]

8. How long we keep your data

We keep your personal data for as long as your account is active. When you delete your account (see below), we permanently remove your personal data after a 14-day grace period during which you can still cancel the deletion. Product analytics is an exception: it is not linked to your account and is removed on Google's own retention schedule (about 2 months), as described in “Analytics and your choices” above.

9. Your rights

Depending on where you live (including under the EU/EEA GDPR), you have the right to access, correct, delete, export, restrict, or object to the processing of your personal data, and to withdraw consent where processing is based on consent.

  • Export your data: request a copy of your data from within the app; we provide a downloadable file.
  • Delete your account: request deletion from within the app or use our account deletion page. You confirm by email, and after a 14-day grace period your account and personal data are permanently deleted. You can cancel during the grace period.

You can also contact us at support@ellaword.com to exercise any of these rights. If you are in the EU/EEA, you have the right to lodge a complaint with your local data protection authority.

10. Children

Ellaword is not directed to children under 16. We do not knowingly collect personal data from children under that age. If you believe a child has provided us personal data, please contact us and we will delete it.

[AVUKAT — 16 is drafted as the single number that holds across the EU, not because it is the Swedish one. Sweden sets the GDPR Art. 8 age of digital consent at 13, but the app is distributed through the App Store across the EU and the applicable age is that of the member state the child is in — 16 in Germany and the Netherlands, 15 in France. A single 13 would therefore be wrong in several markets, and per-country gating does not exist in the app. Confirm, or decide to build the gating and lower it.]

11. Security

We protect your data with measures including hashed passwords, authenticated access, encryption in transit, and storage within the European Union. No method of transmission or storage is completely secure, but we work to protect your information.

12. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and change the "Last updated" date above.

13. Contact

If you have any questions about this Privacy Policy or your data, contact us at support@ellaword.com.