Privacy Policy

01Who we are

Spellsketch is made by TODO: legal name (individual or company), based in Taiwan (“we”, “us”). We decide how your personal data is used, which makes us the data controller under the GDPR and the collector under Taiwan’s Personal Data Protection Act.

Questions about privacy: support@spellsketch.com · Postal address: TODO: address · Phone: TODO: phone.

Our representative in the European Union: TODO: name and contact. In the UK: TODO: name and contact.

02What this policy covers

The Spellsketch app for iPhone and iPad, including beta versions on TestFlight; this website, spellsketch.com; and emails you send us.

03What we collect

A description is about the picture, so we never need personal details in it. Please don’t include a full name, address, school or phone number, and use a nickname rather than a real name. We don’t ask for any of these, and nothing a learner says is ever shown publicly. Our content check looks for harmful content; it doesn’t find or remove personal details. If you notice one, email us and we’ll delete that description.

04What we don’t collect

• No real names, birthdays or ages, photos, contacts or location. Members use a nickname and an avatar from the app.
• No voice recordings. When you speak, your device’s on-device speech recognition turns it into text. The audio stays on your device; we only receive the text, which you can edit before you send it.
• No tracking. We don’t use the advertising identifier (IDFA) or other device identifiers, and we don’t track you across other companies’ apps or websites.
• No third-party analytics, advertising or crash-reporting tools in the app. Usage events go only to our own servers. We see crash reports only if you’ve chosen to share analytics with app developers in your iOS settings, and they come to us through Apple.
• No cookies on this website, and no analytics.

05How we use it

We use your data only for the purposes below. If you’re in the European Economic Area, the UK or Switzerland, the legal basis for each is in brackets.

• To run Spellsketch: sign you in, choose pictures, judge which details a description covers, show the matching picture, give feedback, keep each member’s progress, settings and Spell Book, and manage your subscription. (Performance of our contract with you.)
• To keep it safe: check descriptions against our content rules before they are used, set reasonable-use limits, and protect the service from abuse. (Our legitimate interest in a safe service, and legal obligations.)
• To improve Spellsketch: look at usage events and results in aggregate, such as how many tries a picture takes or which kinds of detail people miss most, and fix results you report as wrong. (Our legitimate interest in improving the service.)
• To improve the judging model: see the next section. (Legitimate interest.)
• To answer you when you contact us. (Legitimate interest, or our contract with you.)
• To meet legal duties, such as keeping purchase records. (Legal obligation.)

We don’t sell personal data, share it for advertising, or build advertising profiles. Scoring is automatic, but it only affects practice results; it never makes decisions with legal or similarly significant effects on anyone.

Account and member IDs, and IP addresses. We use these only to run Spellsketch: to sign you in, keep each member’s data separate, send the app its pictures, count reasonable-use limits, keep the service secure, fix errors, and count things like how many tries a picture takes. They are never used to contact anyone, to build a profile of a person, or for advertising, and they are never shared for those purposes.

Choosing what to review. When a learned word is due for review, we pick a picture that includes it. This uses only that member’s own progress in Spellsketch; it isn’t used for anything else.

06Improving the judge

Judging gets fairer when we can check it against real descriptions.

• We may copy the text of descriptions, with the results, into the sets we use to test and improve judging. Before copying, we remove the account, email, nickname and member, so the copies can’t be traced back to anyone.
• People on our team may read these copies to label them. They are never published or given to anyone else.

07Who processes it for us

We share data only with service providers that help us run Spellsketch, under agreements that let them use it only on our instructions and require them to keep it secure. None of them may use it for their own purposes. We don’t give your data to anyone else, and we add a provider to this list before it receives any data:

We may also disclose data when the law requires it, or to protect someone’s safety. If Spellsketch is ever transferred to someone else, this policy keeps applying to your data, and we’ll tell you before anything changes.

08Where it is stored

We are based in Taiwan. We are setting up our database, file storage and servers in Tokyo, Japan, with Supabase and Google Cloud. If we choose a different region, we’ll update this section before your data is stored there.

Some providers, such as AI services, Apple, Google and our email provider, may process data in other countries, including the United States. When data from the European Economic Area, the UK or Switzerland goes to a country that doesn’t have an adequacy decision, we rely on the European Commission’s Standard Contractual Clauses or an equivalent safeguard in our agreement with the provider. You can ask us for a copy.

09How long we keep it

We keep data until you no longer need it:

• Members, descriptions, results, learned words and usage events: as long as the member exists, because they are that member’s progress and Spell Book. Deleting a member deletes that member’s data.
• When you delete your account: we delete it and everything in it right away: members, descriptions, results, Spell Books, usage events and files. Copies in our encrypted backups are gone within 30 days.
• Trying without an account: merged into your account when you sign in.
• Server logs: up to 30 days.
• Copies held by our AI services: see section 7.
• Support emails: up to 12 months after the conversation ends.
• Website purchase records: as long as tax and accounting law requires.
• Copies for improving judging (section 6) don’t identify anyone, and we keep them as long as they help us test and improve judging.

Deleting your account doesn’t cancel an App Store subscription. Cancel it in your Apple account settings; see Support.

10Your rights and choices

Wherever you live, you can ask us to:

• show you the data we hold about you, or send you a copy in a common format;
• correct it;
• delete it;
• stop or limit using it, or object to how we use it;

In the app, you can edit and delete members and delete your account. For anything else, email support@spellsketch.com. We may ask you to confirm that the account is yours, for example by writing from the email address on the account. We reply within 15 days to requests to see or copy your data and within 30 days to other requests; if we need longer, we’ll tell you why.

The account holder can make these requests for every member of the account; see section 11.

If you’re in the European Economic Area, the UK or Switzerland, you can also complain to your local data protection authority.

11Accounts and members

The account

• Only adults can create an account. The account holder signs in, chooses the plan and is responsible for the account.
• An account can have up to three members (one on the free plan). A member (a profile in the app) is a nickname and a built-in avatar for someone who practices; the account holder decides who uses each one.

What each member has

• Their own descriptions and results, progress, Spell Book and practice settings (timer, one-word hints, voice speed and level).
• These are stored with the account in our database (section 8) and used only as described in sections 5 to 7.

Who can see it

• Anyone signed in to the account can switch between its members, see each member’s sentences, pictures, progress and settings, and change the settings. Nobody outside the account can see them.

Deleting

• Deleting a member deletes everything in it. Deleting the account deletes all its members (section 9).
• The account holder can also ask us by email to show, correct or delete anything in a member, or to delete a single description. We’ll check the request comes from the account holder, for example by replying to the account’s email address.

Every member gets the same safety standard: descriptions are checked before they’re used, pictures are made in advance and reviewed, there is no open-ended image generation, no chat or social features, no ads and no third-party tracking.

12Security

Data is encrypted in transit and, with our providers, at rest. Our servers check that each request reaches only its own account’s data, and only the people who run Spellsketch can access our systems.

13Changes to this policy

When we change this policy, we post the new version here and update the date at the top. For important changes, we tell you in the app before they take effect.

14Contact us

TODO: legal name, Taiwan · support@spellsketch.com

This policy is also available in 繁體中文. If the two differ, the English version applies.