Privacy Policy
Effective date: 2026-10-08
1. Who we are
Verbalaizer (the website verbalaizer.com and the Verbalaizer mobile app) is operated by Private Enterprise "WRC KRONOS" (ПРИВАТНЕ ПІДПРИЄМСТВО "ВРК КРОНОС"), registered in Ukraine, ЄДРПОУ code 30103264 ("we", "us"). We are the controller of the personal data described in this policy.
Privacy questions and requests: support@verbalaizer.com or our contact form.
2. What we collect and why
Your account
Email address, name (if you give it or sign in with Google), password (stored only as a secure hash), your Google account ID if you use "Continue with Google", interface language and lesson preferences (the language you practise, the explanation language, your level). Why: to create and run your account. Legal basis: performance of our contract with you.
Your voice
When you speak in a lesson, the app or website records your voice through the microphone only while you are speaking to the tutor, and only after you allow microphone access. The audio is sent over an encrypted connection to our server and passed on to Google for speech recognition and the tutor's reply. We do not store recordings of your voice. Legal basis: contract.
Lesson content
The text of your conversation with the tutor (what you said, as recognised, and the tutor's replies), corrections, suggested replies and a short summary of the lesson. During a lesson this is kept on our server so the lesson can continue after a short disconnection. Transcripts you choose to save stay in your account until you delete them. Why: to provide the lessons and let you review them. Legal basis: contract.
Usage and limits
Lesson times, minutes spoken and the cost of the AI and speech services each lesson used. Why: to apply the minutes included in your plan, prevent abuse and keep our accounts. Legal basis: contract and our legitimate interest in preventing abuse.
Purchases
For purchases on the website (Paddle, Gumroad license keys, partner or school codes) and subscriptions in the app (Google Play, managed through RevenueCat): what you bought, when, its status and an order or transaction ID. We never receive your card details. Legal basis: contract and legal obligations (accounting and tax).
Reports
If you report a tutor reply, we store that reply, the reason you chose, your optional comment and the lesson languages. Why: to review AI content and improve the tutor. Legal basis: our legitimate interest in keeping the service safe.
Learning quiz and plans
Your answers to the learner-type quiz and the learning plan built from them, if you use them. Legal basis: contract.
Messages and emails
Messages you send through the contact form, and the emails we send you (address confirmation, password reset and, if you subscribe, the newsletter). You can unsubscribe from the newsletter at any time. Legal basis: contract; consent for the newsletter.
Website visits
When you arrive through a link with campaign parameters, we record the campaign, the page, the referring page, your IP address, country and browser type. Why: to understand which campaigns bring visitors. Legal basis: legitimate interest.
Cookies
We use necessary cookies to keep you signed in (a session cookie and an optional 30-day "remember me" cookie) and to remember your language and your cookie choice. The website also uses Google Analytics and Microsoft Clarity, loaded through Google Tag Manager, to measure how the site is used; Clarity records how pages are used (clicks, scrolling, mouse movement) to show us where the site is hard to use. The app uses no advertising or analytics tools and shows no ads.
3. AI-generated content
The tutor's replies, corrections and suggestions are generated by artificial intelligence (Google Gemini). They can be inaccurate. Please do not rely on them for anything important, and use the "Report" link next to any reply that is wrong or offensive.
4. Who processes your data for us
We use these service providers. They process data only to provide their service to us.
| Provider | What for | Data |
|---|---|---|
| Google (Gemini API, Cloud Text-to-Speech) | Speech recognition, tutor replies and the tutor's voice | Voice audio and lesson text during a lesson |
| Google (Sign-In) | "Continue with Google" | Name, email address, Google ID |
| Google Play, RevenueCat | Subscriptions in the app | Purchase and subscription status, an app user ID |
| Paddle, Gumroad | Website payments and license keys | Purchase details (they handle payment details themselves) |
| Hetzner Online | Server hosting in the EU | All data stored on our server |
| Google (Gmail) | Sending emails and receiving contact-form messages | Email address and email content |
| Google Analytics, Microsoft Clarity | Website measurement | Cookie IDs, pages visited, clicks and scrolling, device data |
Google Gemini is used under Google's paid API terms: Google does not use our prompts or its responses to improve its products, and keeps them only for a limited time to detect abuse.
We do not sell your personal data and do not share it for advertising.
Some providers are in the United States or other countries outside Ukraine and the EU. Where the law requires it, these transfers rely on adequacy decisions or standard contractual clauses offered by the provider.
5. How long we keep data
| Data | Kept |
|---|---|
| Account and preferences | Until you delete your account |
| Voice audio | Not stored |
| Lesson state during a lesson | Up to 30 minutes after the lesson connection ends |
| Saved transcripts | Until you delete them or your account |
| Minutes and cost records | For accounting; anonymised when you delete your account |
| Purchase records | As long as accounting and tax law requires; without your name or email after account deletion |
| Reports of tutor replies | As long as needed to review them and improve the tutor |
| Website visit records | As long as needed to evaluate our campaigns; unlinked from your account when you delete it |
| Free-minute fingerprint after account deletion | Until the end of that month |
When you delete your account, we delete your personal content and anonymise the account. To prevent misuse of free speaking minutes, we keep a one-way, keyed fingerprint of the email address and Google ID together with the minutes used that month. It cannot be turned back into your email address and is deleted once that month is over. Purchase records are kept without your name or email where the law requires it.
6. Your rights
Depending on where you live (including under the EU GDPR and the Law of Ukraine "On Personal Data Protection"), you can ask to access, correct, delete or export your data, to restrict or object to processing, and to withdraw consent at any time. Write to support@verbalaizer.com. You can also complain to your data protection authority (in Ukraine: the Ukrainian Parliament Commissioner for Human Rights).
You can delete your account yourself at any time in the app or on the website: how to delete your account.
7. Children
Verbalaizer is not intended for children under 13. If you are younger than the age of digital consent in your country (16 in some EU countries), use Verbalaizer only with the consent of a parent or guardian. When a school provides access, the school is responsible for obtaining any required consent. If you believe a child under 13 has given us personal data, contact us and we will delete it.
8. Security
All connections to Verbalaizer are encrypted (HTTPS). Passwords are stored as hashes, sign-in tokens in the app are kept in the phone's secure storage, and access to our systems is limited to people who need it.
9. Changes to this policy
We will publish any change on this page with a new effective date, and tell you in the app or by email before an important change takes effect.