WordFlow — Privacy Policy

1. Introduction

This Privacy Policy explains how CODELUMA LLC ("Company," "we," "us," or "our") collects, uses, discloses, and safeguards information in connection with your download, installation, access, and use of the WordFlow mobile application (the "App").

By downloading, installing, accessing, or otherwise using the App, you acknowledge that you have read, understood, and voluntarily agree to be bound by this Privacy Policy in its entirety. If you do not agree with any part of this Privacy Policy, you must not download, install, or use the App, and must uninstall it from your device.

2. Eligibility & Children's Privacy

The App is intended for general audiences. However, because the App displays third-party advertisements, it is not directed at children under the age of 13 (as defined under COPPA) or under 16 where GDPR applies. We do not knowingly collect personal information from such children without verifiable parental consent.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us using the details in Section 17. We will take reasonable steps to delete such information promptly.

It is the sole responsibility of any parent or guardian to supervise and manage a minor's use of the App, including through device-level parental controls and app store age settings.

3. Information We Collect

3.1 Information Stored Locally on Your Device

WordFlow stores your learning progress — including which words you have marked as known or unknown, your current position in the word list, and session statistics — exclusively on your device using local storage (AsyncStorage). This information never leaves your device and is not transmitted to our servers or any third party.

3.2 Information Collected Automatically

When you use the App, the following information is collected automatically by the App and by integrated third-party advertising and analytics SDKs:

• Advertising Identifiers: Apple's Identifier for Advertisers (IDFA) on iOS and Google's Advertising ID (AAID) on Android, used to deliver and measure personalized advertisements. On iOS, this requires your explicit consent via Apple's App Tracking Transparency (ATT) prompt.
• Device Information: device model, operating system and version, language and locale settings, time zone, and screen resolution.
• Usage Information: features accessed, screens viewed, session duration and frequency, and crash or performance diagnostics.
• Technical & Log Information: IP address, app version, and similar technical data generated automatically during use.

We do not collect your name, email address, phone number, payment information, or any other directly identifying personal information. The App does not require registration or account creation.

4. How Information Is Collected

Technical, usage, and advertising identifier data described in Section 3.2 is collected automatically by the App and by third-party SDKs integrated for advertising and analytics purposes. These SDKs operate under their own privacy policies, which we encourage you to review:

• Google AdMob / Google Analytics (Firebase): policies.google.com/privacy
• Meta Audience Network (if integrated): facebook.com/privacy/policy

5. How We Use Information

We and our service providers use the information described above to:

• operate, maintain, and improve the App and its vocabulary learning features;
• deliver, personalize, and measure third-party advertisements shown within the App;
• analyze how users interact with flashcard mechanics in order to improve the educational experience;
• detect, investigate, and prevent technical errors, crashes, and unauthorized activity;
• comply with applicable legal obligations and lawful requests from public authorities; and
• provide customer support and respond to inquiries.

6. Advertising

The App displays third-party advertisements from the moment of first launch. Advertising is provided by third-party networks, which may include Google AdMob and similar industry-standard mobile advertising platforms. These providers collect and process your advertising identifier, IP address, device information, and app usage data to:

• deliver personalized or interest-based advertisements;
• measure advertising performance and prevent ad fraud; and
• generate aggregated, anonymized usage statistics.

These third-party advertising providers act as independent data controllers for the data collected through their SDKs. We do not control their data processing practices beyond our integration choices.

6.1 App Tracking Transparency (iOS)

On iOS 14.5 and later, the App will present Apple's App Tracking Transparency prompt before accessing your IDFA. If you decline, the App will continue to display advertisements, but they will not be personalized based on your activity across other apps and websites.

6.2 Your Advertising Choices

• iOS: Settings → Privacy & Security → Tracking — manage which apps may request to track you. You may also reset your IDFA here.
• Android: Settings → Privacy → Ads — reset or delete your Advertising ID, or opt out of interest-based ads.
• Industry opt-out tools: Digital Advertising Alliance (optout.aboutads.info) or the Network Advertising Initiative (optout.networkadvertising.org).

Opting out of personalized advertising will not stop ads from being displayed; it means the ads you see will be less relevant to your interests. It will not affect any of the App's vocabulary learning features.

6.3 Consent

By downloading and using the App, you acknowledge and, to the extent required by applicable law, consent to the collection, processing, and use of your information for advertising purposes as described in this Section 6. Where required (for example, for users in the EEA, UK, or Switzerland), consent will be collected through an in-app consent management platform (CMP) before any advertising identifiers are accessed.

7. Local Data & Your Control Over It

Your learning progress is stored entirely on your device. You may reset all progress at any time from within the App. Uninstalling the App will permanently delete all locally stored data. We have no ability to recover this data on your behalf.

8. Sharing & Disclosure of Information

We do not sell your personal information for monetary consideration. However, sharing your advertising identifier and related data with advertising partners as described in Section 6 may constitute a "sale" or "sharing" of personal information under certain laws, such as the CCPA/CPRA. You may opt out of such sharing as described in Section 6.2.

We may otherwise disclose information:

• to service providers and vendors performing services on our behalf (analytics, advertising, support);
• to comply with applicable laws, regulations, legal process, or governmental requests;
• to protect the rights, property, or safety of the Company, our users, or others;
• in connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets; and
• with your consent or at your direction.

9. Legal Bases for Processing (GDPR / UK GDPR)

If you are located in the European Economic Area, the United Kingdom, or a jurisdiction with similar requirements, we process personal information on the basis of: (a) your explicit consent for advertising-related processing, which you may withdraw at any time; (b) our legitimate interests in operating, securing, and improving the App; and (c) compliance with a legal obligation.

10. Your Privacy Rights

Depending on your place of residence, you may have the right to:

• request access to, and a copy of, the personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• request restriction of, or object to, certain processing;
• request data portability in a structured, commonly used format;
• withdraw consent at any time, without affecting prior lawful processing;
• (California residents) opt out of the "sale" or "sharing" of personal information, including cross-context behavioral advertising; and
• lodge a complaint with a competent data protection supervisory authority.

To exercise these rights, contact us at [email protected]. We aim to respond within 30 days under GDPR and 45 days under CCPA, subject to permitted extensions.

11. International Users & Applicable Law

The App may be downloaded and used worldwide, including in jurisdictions governed by the GDPR, UK GDPR, Turkey's KVKK, CCPA/CPRA, Canada's PIPEDA, Brazil's LGPD, Australia's Privacy Act 1988, and other applicable laws. It is your sole responsibility to determine whether your use of the App is lawful in your jurisdiction.

12. Data Retention

Learning progress data exists only on your device for as long as the App is installed. Advertising and analytics data collected by third-party SDKs is retained in accordance with those providers' own policies. Any information we directly hold is retained only as long as necessary for the purposes described in this Policy or as required by law.

13. Data Security

We implement reasonable technical and organizational measures to protect information from unauthorized access, loss, or alteration. You are solely responsible for maintaining the security of your device, including keeping your operating system updated and using device-level authentication.

14. International Data Transfers

Information collected by third-party advertising and analytics SDKs may be transferred to and processed in countries other than your country of residence, including the United States. Where required, those providers rely on appropriate safeguards such as standard contractual clauses. By using the App, you acknowledge and accept such transfers.

15. Third-Party Links & Services

The App may reference or display content from third-party services. We are not responsible for the privacy practices of any third party and encourage you to review their policies before interacting with them.

16. Changes to This Privacy Policy

We may update this Policy from time to time. The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the App after any update constitutes acceptance of the revised Policy. It is your responsibility to review this Policy periodically.

17. Contact Us

For questions, concerns, or data requests regarding this Privacy Policy:

CODELUMA LLC

1111B S Governors Ave STE 39133, Dover, DE 19904, United States

Email: [email protected]