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Privacy Notice

Last updated: January 1, 2026

1. Who we are

This Privacy Notice explains how Witty English ("Witty English", "we", "us", "our") processes personal data in connection with the Wordly vocabulary-learning service (the "Service"). Witty English is the data controller for personal data processed through the Service, except for payment-related personal data, for which our Merchant of Record, Paddle, is a separate controller.

2. Personal data we collect

  • Account data: name, email address, and (for social sign-in) profile photo and provider ID from Google or other identity providers you choose.
  • Authentication data: hashed credentials, session tokens, and sign-in timestamps.
  • Learning content: decks, words, sentences, and practice history you create in the Service.
  • Support communications: messages you send us and any information you include.
  • Usage and telemetry data: pages visited, actions taken, feature usage, error and diagnostic logs.
  • Device and technical data: IP address, browser type, operating system, device identifiers, referrer, and language preference.
  • Purchase data: subscription status and entitlement returned by Paddle. Card and billing details are collected and processed by Paddle, not by us.

3. Why we use your data and our legal basis

  • Provide the Service (create your account, save your decks, sync across devices, run AI features): performance of a contract.
  • Customer support: performance of a contract and legitimate interest in helping our users.
  • Security, fraud prevention, and abuse detection: legitimate interest in keeping the Service safe, and legal obligation where applicable.
  • Product improvement and analytics (understanding aggregate usage, fixing bugs): legitimate interest.
  • Billing and tax compliance: performance of a contract and legal obligation. Handled by Paddle as Merchant of Record.
  • Marketing communications (if we ever send them): your consent, which you can withdraw at any time.

4. Who we share data with

  • Merchant of Record — Paddle for sale of the product, subscription management, payments, invoicing, and tax compliance.
  • Hosting and infrastructure providers (cloud hosting, database, and authentication providers) that store and serve the Service.
  • AI providers that generate definitions, examples, and feedback from the prompts you send.
  • Analytics and error-monitoring tools that help us understand usage and diagnose issues.
  • Professional advisers (legal, accounting) where reasonably necessary.
  • Authorities where required by law, court order, or valid legal process.

We do not sell your personal data.

5. International transfers

Your data may be processed in countries outside your own, including in the United States and other jurisdictions where our providers operate. Where required, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses or adequacy decisions.

6. Data retention

We keep account and learning content for as long as your account is active. If you delete your account or ask us to erase your data, we will delete or anonymise it within a reasonable period, except where we must keep it to comply with legal obligations (for example, tax records), resolve disputes, or enforce our agreements. Diagnostic logs are typically kept for a short rolling window and then deleted.

7. Your rights

Depending on where you live, you may have the right to:

  • access the personal data we hold about you;
  • rectify inaccurate or incomplete data;
  • erase your data ("right to be forgotten");
  • restrict or object to certain processing;
  • data portability;
  • withdraw consent where processing is based on consent;
  • lodge a complaint with your local supervisory authority.

To exercise these rights, contact us through the in-app support flow. We aim to respond within one month.

8. Security

We use appropriate technical and organisational measures to protect your data, including encryption in transit, access controls, and regular review of our systems. No online service can be guaranteed to be 100% secure; please use a strong password and keep your credentials confidential.

9. Cookies and similar technologies

We use a small number of essential cookies and local storage entries so you can stay signed in, keep your theme and language preferences, and continue where you left off. We may also use privacy-friendly analytics to understand how the Service is used. You can clear cookies and local storage from your browser at any time; doing so will sign you out and reset preferences stored on your device.

10. Children

The Service is not directed to children under 13 (or the equivalent minimum age in your jurisdiction), and we do not knowingly collect personal data from them. If you believe a child has provided us with personal data, please contact us so we can delete it.

11. Changes to this notice

We may update this Privacy Notice from time to time. When we do, we will update the "Last updated" date above and, for material changes, notify you through the Service.

12. Contact

For privacy questions or requests, contact Witty English through the in-app support flow. For anything related to a purchase, please also contact Paddle at paddle.net.