Privacy Policy

Effective date: May 10, 2026

This Privacy Policy is effective as of May 10, 2026 and applies until replaced by a newer version.

This revision was introduced with app version 2.7.0. If you use the legacy app version still installed on some devices, see the previous Privacy Policy for that version.

Privacy Policy for Learn Polish
Effective date: May 10, 2026

Learn Polish ("App", "we", "us", "our") is a language learning app for studying Polish vocabulary with flashcards, manually created dictionaries, imported JSON dictionaries, and optional AI-generated dictionaries. Core learning features are available without a subscription. AI dictionary generation is offered in supported native mobile versions only and requires an eligible subscription. The currently released native mobile version is the iOS app distributed through the Apple App Store; a native Android version may be offered through Google Play in the future.

This Privacy Policy explains what data is processed when you use the App, where it is stored, and what choices you have.

1. Who is responsible for processing personal data

The controller of personal data processed through the App is:

Maksym Kyselov
Email: m.kiselyow@gmail.com
Address: Warszawa, ul. Borsucza 55/11, 02-213, Poland

2. What data is stored locally on your device

Most App learning data is stored locally on your device or browser storage and is not sent to us simply because you use the learning features.

The App may use text-to-speech functionality available on your device to pronounce Polish words. This functionality depends on your device, operating system, installed voices, and language support.

This local data may include:

  • dictionaries,
  • words, translations, examples, and declensions,
  • learning progress and review history,
  • selected dictionaries,
  • interface language,
  • app settings, including theme preference and onboarding state.

You can export this data yourself and import it on another device.

The web or PWA version of the App does not offer subscription-based AI dictionary generation.

3. What data is sent when you use AI dictionary generation or native subscription features

If you use the AI dictionary generation feature in a supported native app, the following data may be sent to our server and to our AI service provider for the purpose of generating a dictionary for you:

  • topic,
  • quantity,
  • additional notes,
  • selected native language,
  • limited technical request data necessary to provide and protect the feature.

When you request AI dictionary generation, the supported native app also sends an anonymous or pseudonymous RevenueCat app user identifier to our server. We use that identifier to check whether an eligible subscription entitlement is active and to apply AI dictionary generation usage limits. For this purpose, our server may query RevenueCat for relevant subscription and entitlement information.

If you purchase, restore, or use subscription features in the currently released native iOS version of the App, subscription-related data may also be processed by Apple App Store and by our subscription infrastructure provider RevenueCat, as needed to validate purchases, determine entitlement status, support restore purchases, and manage subscription access. If an Android version is later released, equivalent processing may involve Google Play.

This subscription-related data may include:

  • an anonymous or pseudonymous app user identifier,
  • purchase, entitlement, subscription, and renewal status information,
  • trial or introductory offer eligibility or status where available from the store,
  • AI dictionary generation usage counts and applicable limit or reset window information,
  • limited technical, device, app, or store-related information needed to validate and manage subscriptions.

Some users with an active eligible legacy subscription may temporarily continue to receive access to AI dictionary generation while that legacy subscription remains active.

We do not state that your name or email address is sent to RevenueCat unless you separately provide such data through another channel.

4. IP address and security-related processing

When you use the AI dictionary generation feature, we may temporarily process your IP address and limited technical request metadata in order to:

  • prevent abuse,
  • apply request limits,
  • protect the service from excessive or automated traffic,
  • control the operating costs of the AI feature.

We do not use this information for advertising or user profiling.

5. Why we process data

We process data only as needed to operate the App and provide the AI generation feature.

We may process data for the following purposes:

  • to provide the AI dictionary generation feature you request,
  • to enable and manage subscriptions in supported native mobile versions of the App,
  • to validate purchases, restore purchases, and recognize eligible active legacy subscription access where applicable,
  • to determine whether access to the AI dictionary generation subscription feature is active, expired, canceled, in trial, or otherwise available through the relevant store,
  • to protect the App and prevent abuse,
  • to record and enforce technical and subscription usage limits on AI generation,
  • to respond if you contact us for support,
  • to comply with legal obligations where required.

6. Legal bases

Where applicable under data protection law, we rely on the following legal bases:

  • performance of a requested service or subscription arrangement - when you ask us to generate an AI dictionary or when we verify your entitlement to use that subscription feature,
  • legitimate interests - for security, abuse prevention, rate limiting, and cost control,
  • legal obligation - where processing is required by law.

7. AI notice

The AI generation feature creates content automatically.

AI-generated content:

  • may contain inaccuracies or mistakes,
  • may be incomplete,
  • may resemble existing materials,
  • should be reviewed by you before use.

Please do not enter personal data, sensitive data, passwords, or confidential information into AI prompts.

8. Service providers

We may use third-party service providers strictly as needed to operate the App, including:

  • hosting and infrastructure providers such as Vercel,
  • AI service providers such as OpenAI used to generate dictionaries,
  • subscription infrastructure providers such as RevenueCat for native subscription management, entitlement validation, and restore purchases,
  • data infrastructure providers such as Upstash Redis, where configured, for pseudonymous AI generation usage-limit records.

These providers may process the data necessary to perform their services.

In the currently released native iOS version, purchases are processed by Apple App Store, not directly by us. If a native Android version is later released, purchases in that version may be processed by Google Play.

9. International transfers

Some service providers may process data outside your country. Where required, such transfers are made subject to applicable legal safeguards.

10. Data retention

10.1 Local learning data

Your learning data stays on your device until you delete it, reset the App, clear storage, or uninstall the App.

10.2 AI request and security data

We try to minimize retention.

For the current implementation:

  • short anti-abuse request counters may be kept temporarily for approximately 1 minute,
  • IP-address-based weekly request-limit records may be kept temporarily for approximately 7 days,
  • pseudonymous subscription usage-limit records associated with a RevenueCat app user identifier may be kept until the current weekly limit window and the applicable monthly subscription period expire.

10.3 Subscription-related data

In the currently released native iOS version, limited subscription-related records may be processed and retained by Apple App Store and RevenueCat in accordance with their own systems and retention practices. If an Android version is later released, Google Play may process and retain equivalent records. We process subscription-related information only to the extent needed to operate subscription functionality, verify access to AI dictionary generation, apply usage limits, restore purchases, respond to support requests, or comply with legal obligations.

Most learning data remains local on your device and is separate from subscription status data.

If you contact us by email, we may process the contact details and message you provide in order to respond to you.

11. Your rights

Where applicable under data protection law, you may have the right to:

  • request access to personal data we process about you,
  • request correction of inaccurate personal data,
  • request deletion of personal data,
  • request restriction of processing,
  • object to certain processing,
  • request data portability,
  • lodge a complaint with a competent supervisory authority.

These rights are not absolute and depend on the circumstances and applicable law.

Because most App data is stored locally on your device, you can directly access, export, and delete much of your data yourself inside the App or by clearing device or browser storage.

Because subscription purchases in supported native mobile versions are processed through Apple App Store or, if an Android version is released, Google Play, some billing, purchase, cancellation, refund, and store-account related data may be controlled by those platforms and not directly by us. Deletion of local App data does not by itself cancel a subscription or erase store-side purchase records.

To contact us about rights requests, use: m.kiselyow@gmail.com

12. How to delete your data

Because most App data is stored locally on your device, you can delete it by:

  • using the App's Reset App / Delete Local Data function,
  • clearing browser or app storage,
  • uninstalling the App.

This removes local dictionaries, progress, and settings from your device.

If you have an active subscription in a supported native mobile version, deleting local App data or uninstalling the App does not automatically cancel your subscription. Subscription management and cancellation must be handled through the applicable Apple App Store or Google Play account settings.

13. Children

The App is not specifically directed to children. If use by a child requires parental or guardian consent under applicable law, such consent must be obtained by the user or their parent or guardian.

14. Native subscriptions and AI dictionary generation

The currently released native iOS version may offer one monthly auto-renewing AI Dictionary Generation subscription for access to AI-generated dictionary creation. A native Android version may be offered later through Google Play under similar terms.

The current AI Dictionary Generation offering may include up to 20 AI dictionary generations per monthly subscription period, with up to 30 words per generated dictionary, together with shorter-period technical usage limits used to operate and protect the service.

Users with an eligible active legacy subscription may continue to access AI dictionary generation while that legacy subscription remains active.

A 7-day free trial or other introductory offer may be available where supported by the relevant store configuration and applicable store eligibility rules.

Subscription pricing, trial availability, introductory offers, billing terms, and feature availability may vary by platform, store, country, or region.

Subscriptions automatically renew unless canceled by the user through the applicable Apple App Store or Google Play account settings.

The App may provide a restore purchases function in the native version to help recover subscription access associated with the relevant store account or supported subscription record.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version will be made available in the App or on the website, and the effective date will be updated.

16. Contact

If you have questions about this Privacy Policy, contact:

Maksym Kyselov
Email: m.kiselyow@gmail.com
Address: Warszawa, ul. Borsucza 55/11, 02-213, Poland

v2.7.1