# Nounly Privacy Policy
**Effective date:** July 3, 2026
**Last updated:** July 3, 2026
This Privacy Policy explains how Nounly ("Nounly," "the App," "we," "us," or "our") collects, uses, stores, and discloses information when you use the Nounly mobile application. It is written to describe precisely what the App does — not generic boilerplate — so please read it carefully.
By using Nounly, you agree to the practices described in this Policy. If you do not agree, do not use the App.
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## 1. Who we are
Nounly is developed and published by Innovium ("we," "us," "our"). For any privacy question, request, or complaint, contact us at:
**info@innovium.digital**
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## 2. Summary (non-binding overview)
- Nounly has **no user accounts, no login, and no server of its own**. Almost everything you create (your word collection, photos, streaks, settings) is stored **only on your device**.
- When you scan or select a photo of an object, that photo and your language selections are sent to a **third-party AI service provider** to identify the object and generate learning content (translations, example sentences, mnemonics, etc.).
- Purchases and subscriptions are processed by **RevenueCat** and the **Apple App Store**.
- We do **not** use analytics, advertising, crash-reporting, or tracking SDKs of any kind. We do not build advertising profiles and we do not sell your data.
- We do not knowingly direct the App at, or collect data from, children under 13.
The sections below give the full detail. Where the summary and the detailed sections differ, the detailed sections control.
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## 3. Information we collect and how it is used
### 3.1 Photos and images you capture or select
When you take a photo with your camera or choose an image from your photo library to add a word to your collection:
- The image is processed **on your device** to remove its background (this happens locally using an on-device model; the original photo does not leave your device for this step).
- The resulting image is sent to our **third-party AI service provider's API** as a base64-encoded image, together with your selected native and target language names, so that the provider's AI model can identify the object and generate the associated vocabulary content (translation, part-of-speech data, example/context sentences, plural form, grammatical gender, a mnemonic, a fun fact, and related word suggestions).
- The processed/background-removed image ("sticker") is then stored **only on your device**, inside the App's local storage. It is not uploaded to, or retained by, any server we operate, because we do not operate one.
- If you save a word card to your Photos library or share it (via the share sheet), that copy is handled by your device's operating system, not by us.
**Third party involved:** We use a leading third-party AI service provider to power object identification and vocabulary generation. Photo and text content sent to this provider is subject to that provider's own data usage and retention practices, which we do not control. Reputable AI API providers generally do not use API-submitted content to train their models by default and retain it only for a limited period (e.g., for abuse and safety monitoring) before deletion — but you should not assume this without checking, since practices vary and can change. We identify our specific AI provider and link to its privacy policy on request at **info@innovium.digital**. We do not attach your name, email, or any account identifier to these requests — they are sent as anonymous API calls.
### 3.2 Word, language, and learning data
The App generates and stores, entirely on your device via local device storage (not a server):
- Your saved word collection: native word, translated (target) word, category, adjectives, verbs, example sentences, context sentences, plural form, grammatical gender, mnemonics, fun facts, related word suggestions, and spaced-repetition scheduling data (review dates, ease factor, repetition count).
- Your chosen native and target languages.
- If our object-identification result is wrong and you manually correct the object's name, that corrected text is stored locally on your device only and is not sent to our AI service provider or any other third party.
When you change your target language for an existing word, or when older entries need additional detail, the existing word text (not a photo) is sent to our AI service provider again for translation/enrichment, under the same terms described in Section 3.1.
### 3.3 Voice and speech data
- **Pronunciation practice (speech-to-text):** When you use the pronunciation-practice feature, your device's microphone is activated and your speech is processed by your device's **operating-system-level speech recognition service** (e.g., Apple's on-device or server-assisted speech recognition on iOS, or the equivalent Android system service) to check your pronunciation. Nounly's own code does not record, transmit, or store your voice audio — the audio is handled by the OS speech recognition API and only a text/accuracy result is returned to the App. Apple's or Google's handling of this audio is governed by their own privacy policies, not ours.
- **Text-to-speech (word playback):** Word pronunciation playback uses your device's built-in text-to-speech engine entirely on-device. No audio or text is transmitted anywhere for this feature.
### 3.4 Purchases and subscriptions
Nounly offers an optional paid subscription/entitlement, processed through:
- **RevenueCat, Inc.**, which manages subscription state and receipt validation. RevenueCat receives an anonymous, RevenueCat-generated device/purchaser identifier and your App Store transaction/receipt data. We do not send RevenueCat your name, email address, or any other directly identifying information, and the App does not create a RevenueCat account tied to any personal identifier — the identifier is anonymous and device-scoped.
- **Apple's App Store** (and, where applicable, other platform app stores), which processes the payment itself. We never see or store your payment card details — these are handled entirely by Apple.
See RevenueCat's [Privacy Policy](https://www.revenuecat.com/privacy) for how it handles this data.
### 3.5 App Store review prompts
The App uses the operating system's native "Request Review" prompt (via Apple's `SKStoreReviewController` / the Android equivalent) at certain usage milestones (e.g., after onboarding, after your first scan, after 30 scans, after 120 scans). The App only stores, locally on your device, boolean flags and a scan counter to decide when to show this prompt. No data about your review, or whether you left one, is collected or transmitted by us — Apple/Google control the review flow entirely and do not report back to the App whether you rated it.
### 3.6 Device permissions
The App requests the following device permissions, used only for the stated purpose and never for any hidden or secondary purpose:
| Permission | Purpose |
|---|---|
| Camera | Take a photo of an object to add it to your word collection. |
| Photo Library (read) | Select an existing photo of an object to add it to your word collection. |
| Photo Library (add) | Save generated word-card images back to your Photos so you can share them. |
| Microphone | Capture your voice for pronunciation practice. |
| Speech Recognition | Convert your spoken pronunciation into text for accuracy scoring, via the OS speech recognizer. |
You can revoke any of these permissions at any time in your device's Settings; doing so will disable the corresponding feature but will not affect the rest of the App.
### 3.7 Data we do **not** collect
We do not collect, and the App contains no code to collect:
- Your name, email address, phone number, or physical address.
- Precise or approximate location data.
- Contacts, calendar, health, or financial data (beyond the App Store purchase flow described in 3.4, which we do not see).
- Advertising identifiers (IDFA/AAID) — the App does not integrate any advertising SDK and does not use Apple's App Tracking Transparency framework because it does not track you across apps or websites.
- Analytics or usage telemetry sent to us or any analytics vendor — the App does not integrate Firebase Analytics, Crashlytics, Sentry, Mixpanel, Amplitude, PostHog, or any comparable service.
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## 4. Where your data is stored
With the exception of the transient API calls described in Sections 3.1, 3.2, and 3.4, **all of your data is stored locally on your device** (using the operating system's local app storage and local file storage). We do not operate any backend server or database, and there is no cloud sync, account system, or cross-device backup provided by Nounly itself. If your device performs its own OS-level backup (e.g., iCloud or Android backup) that includes app data, that backup is controlled by you and your device manufacturer/OS provider, not by us.
Because there is no Nounly-operated server, we have no ability to access, view, or export your word collection, photos, or settings — they exist only on your device unless you choose to export or share them yourself.
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## 5. How long we keep data
- **Locally stored data** (your word collection, images, settings, streaks, XP, review-prompt flags) remains on your device until you delete individual words, use the App's "Reset Progress" function (which permanently deletes all saved images and all locally stored data), or uninstall the App.
- **Data sent to our AI service provider** is retained according to that provider's own policies, described in Section 3.1 — we do not control or extend that retention.
- **Data sent to RevenueCat/Apple** for purchase processing is retained according to their own policies, described in Section 3.4.
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## 6. Legal basis and your rights
Depending on your location, you may have rights to access, correct, delete, or export your personal data, or to object to or restrict certain processing (for example, under the EU/UK GDPR or U.S. state privacy laws such as the CCPA).
Because nearly all of your data lives only on your device:
- **Access and export:** Your word collection and settings are visible directly within the App at all times.
- **Deletion:** You can delete individual words in-app, use "Reset Progress" in Settings to erase all locally stored App data and images at once, or uninstall the App to remove all locally stored data.
- **Data sent to third parties:** To request deletion of data already transmitted to our AI service provider or RevenueCat, contact us at **info@innovium.digital** and we will make a reasonable effort to assist, or request our AI provider's contact details directly from us.
We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising as those terms are defined under U.S. state privacy laws, because we do not engage in advertising or data brokerage of any kind.
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## 7. Children's privacy
Nounly is not directed at children under 13 (or the equivalent minimum age in your jurisdiction), and we do not knowingly collect personal information from children under that age. The App does not include an age-verification or parental-consent mechanism. If you are a parent or guardian and believe your child has provided personal information (including a photo) to the App, please contact us at **info@innovium.digital** so we can advise on deletion options; because we do not operate a server, any locally stored data can be removed immediately via the device itself.
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## 8. International data transfers
Because photos and word text are sent to our third-party AI service provider (and purchase data to RevenueCat/Apple) as described above, your data may be processed on servers located outside of your country of residence, including in the United States. By using the App, you acknowledge this transfer. These providers are responsible for implementing appropriate safeguards for cross-border transfers under their own privacy programs.
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## 9. Security
We take reasonable measures to protect the data the App handles, including transmitting data to our AI service provider and RevenueCat over encrypted (HTTPS/TLS) connections. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security. Because locally stored data resides on your device, its security also depends on your own device security settings (passcode, encryption, etc.).
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## 10. Third-party services this App uses
For your convenience, the third parties the App transmits data to, and the App does not integrate any other data-receiving third party besides these:
1. **A third-party AI service provider** — object identification, translation, and vocabulary content generation. We do not publish this provider's identity in this Policy, but will disclose it on request at **info@innovium.digital**.
2. **RevenueCat, Inc.** — subscription and purchase management (anonymous purchaser ID and receipt data only). [revenuecat.com/privacy](https://www.revenuecat.com/privacy)
3. **Apple Inc.** (App Store, in-app purchase processing, native review prompts, and — on iOS — on-device/system speech recognition). [apple.com/legal/privacy](https://www.apple.com/legal/privacy/)
We do not use any advertising network, analytics platform, or crash-reporting service.
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## 11. Changes to this Policy
We may update this Privacy Policy as the App's features change. If we make material changes, we will update the "Last updated" date above and, where appropriate, notify you within the App. Continued use of the App after changes take effect constitutes acceptance of the revised Policy.
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## 12. Contact us
If you have questions, concerns, or requests regarding this Privacy Policy or your data, contact:
**Innovium**
Email: **info@innovium.digital**