Privacy Policy

Pre-release draft · Last updated October 4, 2026

This notice explains how the Verba app and website handle personal information. It describes the current pre-release service.

1. Information we process

Account information: your email address, account identifier, optional profile photo, display name or nickname, and information needed to sign in and recover your account. Your display name does not have to be your legal name.
Your library: wordlist titles, saved words and translations, language pairs, and the information needed to synchronise your library.
Content and corrections: descriptions and text you submit for language features, and corrections you make to words or translations. Corrections may be associated with your account to investigate errors.
Access and usage information: Plus or bonus-code entitlement information, expiry information where applicable, and counters needed to enforce generation and sharing limits.
Learning information: language preferences, learning progress, learning-day records and account activity needed to provide your learning features.
Support messages: your message, account and contact information, and any attachments you choose to send.
Technical and security information: connection information, including IP addresses, service and error logs, and records needed to prevent abuse and protect account access.

We do not currently display advertising or use a dedicated behavioural-analytics service.

2. Why we use this information

We use it to provide sign-in and account recovery, save and synchronise your wordlists, provide translations and word suggestions, manage access and limits, investigate translation corrections, respond to support requests, and protect the service against abuse.

Where applicable data-protection law requires a legal basis, we rely on performance of our agreement for requested features, legitimate interests for proportionate security and service quality, and legal obligations where relevant. Optional processing that requires consent must be separately agreed to; accepting this notice is not consent to unrelated uses.

3. Service providers and disclosure

Hosting, account and storage providers: information needed to operate, secure and maintain your account and the service.
Translation and text-generation providers: the words, descriptions, language information and relevant wordlist content needed to fulfil your request.
Email and support-delivery providers: recipient addresses and message content needed to send service emails and handle feedback.
Pronunciation-information providers: relevant words and language information used for pronunciation lookups.
App-store providers: information they process under their own notices when you make or manage a store purchase. Verba does not collect your full payment-card details for an App Store purchase.

Text you submit for language features may contain personal information and may be processed by the relevant service provider. Avoid including sensitive or confidential information. Contact us if you need further information about the providers involved in processing your data.

We do not sell personal information or share it for targeted advertising. We may disclose information when legally required, to respond to a lawful request, or when necessary and legally permitted to protect users and the service.

4. Sharing a wordlist

Anyone who obtains a wordlist sharing link can view or import its shared title, words, translations and language information. Do not share confidential information. Editing or deleting the original list does not automatically update shared content or remove copies saved by others. To request removal of a shared link, contact us and include the link.

5. Local storage and security

The app uses device storage for sign-in, preferences and learning features. Removing the app does not by itself delete your account or information stored by the service.

We use access controls and the security features of our infrastructure providers. No service can guarantee absolute security. Do not send passwords or verification codes in support messages.

6. International processing

Service providers may process information outside Ukraine or your country of residence. Applicable international-transfer arrangements, including any required adequacy decision or contractual safeguards, are still being reviewed before public release. We do not promise that all information stays in one country. Contact us for information about the destinations and safeguards applicable to your data.

7. Retention and deletion

Account and library information is retained while your account is maintained. Retention of support, correction and security records depends on the time needed to handle the request, investigate an issue, protect the service or meet applicable legal obligations. Separate retention periods for these records and backup copies are still being finalised before public release.

You can request account deletion in the app's settings. A confirmed request schedules deletion after a 24-hour cancellation period. To keep your account, sign in before that period ends and explicitly cancel deletion in the prompt or settings. Signing in alone does not cancel the request. Once deletion begins, it cannot be cancelled; completion may take additional processing time.

Deletion removes your sign-in account, personal library and associated account records handled by the deletion process. Shared links, copies saved by recipients, support correspondence and separately retained records may require additional handling. Contact hello@verba.study to request removal of remaining personal information or shared links. Any lawful retention exceptions will be explained in response to your request.

Deleting your account does not cancel an App Store subscription. Cancel renewal through Apple's subscription settings to avoid further charges. Account deletion is not delayed until a subscription ends.

8. Your privacy rights

Depending on applicable law, you may request access, correction, deletion or a portable copy of your personal data, restriction of processing, or object to processing based on legitimate interests. If a use relies on consent, you may withdraw that consent without affecting earlier lawful processing. These rights may have legal limitations.

Send requests to hello@verba.study. We will respond within the time required by applicable law. Where GDPR applies, this is normally within one month, with extensions permitted in specified circumstances. You may also complain to the relevant data-protection authority; you do not have to contact us first.

9. Children and young users

The minimum registration age and any required parental-consent arrangements are still being finalised before public release. This draft does not authorise use contrary to applicable child-privacy laws. Parents or guardians with concerns about a child's information can contact hello@verba.study to request assistance or removal.

10. Who is responsible for your data

Verba is operated by Vitalii Lutsiv (Луців Віталій), an individual based in Ukraine, who is responsible for the personal data described in this notice. For privacy questions or requests, email hello@verba.study.

This notice covers the Verba app and website. Services you visit through external links have their own privacy notices.

11. Changes and contact

We will update this notice when our practices change and show the revision date here. Where legally required, we will provide additional notice or obtain consent before a material change takes effect.

Privacy contact: hello@verba.study.