Privacy Policy

Privacy Policy 

Last Updated: November 9, 2025

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1. Introduction

Welcome to WordsPal ("we," "our," or "us"). We are committed to protecting your privacy and ensuring the safety of your personal information. This Privacy Policy explains how we collect, use, store, and protect information when you use our AI-powered English learning service via WhatsApp.

By using our service, you agree to the collection and use of information in accordance with this policy.

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2. Information We Collect

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2.1 Information You Provide

When you use our service, we collect:

• Phone Number: Your WhatsApp phone number (used as your unique identifier)

• Name: Your first name (for personalized interactions)

• Age: To ensure age-appropriate content

• Native Language: To provide translations in your language

• Learning Preferences: Session timing, difficulty level, weekly goals

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2.2 Information Automatically Collected

• Messages: All messages you send and receive through our service

• Learning Progress: Vocabulary items learned, practice session results, points earned

• Usage Data: Session completion rates, response times, engagement patterns

• Timestamps: When you send messages and complete activities

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2.3 Information We Do NOT Collect

• We do NOT collect your full contact list

• We do NOT access other WhatsApp conversations

• We do NOT collect payment information (if service is free/paid via other means)

• We do NOT track your location

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3. How We Use Your Information

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We use collected information to:

• Provide the Service: Deliver personalized AI-powered English lessons

• Personalize Learning: Adapt content to your level, progress, and preferences

• Track Progress: Monitor your learning achievements and vocabulary growth

• Send Notifications: Remind you about practice sessions and provide engagement nudges

• Improve the Service: Analyze usage patterns to enhance our AI and features

• Ensure Safety: Maintain appropriate content for age groups

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4. How We Store Your Information

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4.1 Data Storage

• All data is stored securely on Amazon Web Services (AWS) infrastructure

• Data is stored in DynamoDB databases with encryption at rest

• Messages are stored with a 90-day automatic deletion policy (Time-To-Live)

• Profile and progress data is retained as long as your account is active

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4.2 Data Security

We implement industry-standard security measures:

• Encrypted data transmission (HTTPS/TLS)

• Encrypted data storage

• Secure access controls

• Regular security audits

• No human access to your conversations (fully automated AI system)

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5. Third-Party Services

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5.1 Services We Use

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Our service relies on the following third-party providers:

WhatsApp / Meta

• Purpose: Message delivery

• Data Shared: Phone number, message content

• Privacy Policy: Meta Privacy Policy

Google Gemini AI

• Purpose: Generate AI-powered learning content and responses

• Data Shared: Your messages and learning context (anonymized where possible)

• Privacy Policy: Google Privacy Policy

Amazon Web Services (AWS)

• Purpose: Data storage and infrastructure

• Data Shared: All service data

• Privacy Policy: AWS Privacy Policy

5.2 Third-Party Use

• We do NOT sell your data to third parties

• We do NOT share your data for advertising purposes

• Third parties process data only to provide our service

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6. Children's Privacy

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Our service is designed for students aged 10-18. We take children's privacy seriously:

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6.1 For Users Under 13 (COPPA Compliance)

If you are under 13:

• We collect only the minimum information necessary to provide the service

• We do NOT require more information than needed

• Parents can request access to, update, or delete their child's data

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6.2 Parental Rights

Parents or guardians can:

• Review their child's information

• Request deletion of their child's account

• Refuse further collection of information

• Contact us with privacy concerns

To exercise these rights, contact: contact@wordspal.com

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7. Data Retention

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• Messages: Automatically deleted after 90 days

• Profile Data: Retained while your account is active

• Learning Progress: Retained to maintain your learning history

• Vocabulary Items: Retained to track your word knowledge

Account Deletion: You can request full account deletion by texting "delete my account" or contacting us at contact@wordspal.com.

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8. Your Rights

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You have the right to:

✅ Access: Request a copy of your data

✅ Update: Correct inaccurate information

✅ Delete: Request deletion of your account and data

✅ Export: Request your data in a portable format

✅ Opt-Out: Stop receiving messages by texting "stop"

✅ Object: Object to how we process your data

To exercise your rights, contact: contact@wordspal.com

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9. Data Sharing and Disclosure

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We may share your information only in these circumstances:

• With Your Consent: When you explicitly agree

• Legal Requirements: To comply with laws, regulations, or legal processes

• Safety: To protect the rights, property, or safety of our users

• Business Transfer: If our service is acquired or merged (you'll be notified)

We will NEVER sell your personal information.

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10. International Data Transfers

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Our services use AWS infrastructure which may process data in different regions. By using our service, you consent to your information being transferred to and processed in countries where our service providers operate, including the United States and Europe.

All transfers comply with applicable data protection laws.

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11. Cookies and Tracking

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Our WhatsApp service does NOT use cookies (as it operates via messaging, not web browsers).

If you visit our website:

• We may use minimal cookies for basic functionality

• We do NOT use advertising or tracking cookies

• You can disable cookies in your browser settings

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12. Changes to This Privacy Policy

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We may update this Privacy Policy periodically. When we do:

• We will update the "Last Updated" date

• Significant changes will be announced via WhatsApp message

• Continued use of the service means you accept the updated policy

We encourage you to review this policy periodically.

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13. Contact Us

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If you have questions about this Privacy Policy or our privacy practices:

Email: contact@wordspal.ai

Website: https://wordspal.ai

For parental inquiries or data requests: contact@wordspal.ai

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14. Your Consent

By using our service, you consent to:

• This Privacy Policy

• Collection and use of information as described

• Processing by third-party services listed above

If you do not agree, please do not use our service.

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15. Additional Information for European Users (GDPR)

If you are in the European Economic Area (EEA):

Legal Basis for Processing:

• Contract Performance: To provide the service you requested

• Legitimate Interest: To improve our service and ensure safety

• Consent: For optional features (you can withdraw consent anytime)

Your Additional Rights:

• Right to data portability

• Right to restrict processing

• Right to object to automated decision-making

• Right to lodge a complaint with your data protection authority

Data Controller: Victor Perepelitsky

Contact: contact@wordspal.ai

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16. Additional Information for California Users (CCPA)

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If you are a California resident:

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Your Rights:

• Right to know what personal information is collected

• Right to know if information is sold or disclosed

• Right to opt-out of sale (we do NOT sell data)

• Right to deletion

• Right to non-discrimination

We do NOT sell personal information.

To exercise your rights: contact@wordspal.ai

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Summary (Plain Language)

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What we collect: Your phone number, name, age, messages, and learning progress

Why: To provide personalized AI English lessons on WhatsApp

How we protect it: Secure AWS storage, encryption, 90-day message deletion

Who we share with: Only WhatsApp/Meta (for delivery), Google (for AI), and AWS (for storage)

Your control: You can stop anytime, request your data, or delete your account

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Questions? Contact us at contact@wordspal.com

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