Privacy Policy – Phrase Ace

Last Updated: December 24, 2024

Table of Contents
1. Quick Summary2. What We Collect3. Advertising & Third-Party Tools4. On-Device Data & Permissions5. Payments6. Sharing & Service Providers7. Your Choices8. Children's Privacy9. Security10. International Users11. Changes to This Policy12. Contact Us

1. Quick Summary

No accounts. No cloud sync. Limited analytics.

Phrase Ace stores preferences like favorites on your device. We do not build personal profiles or track you across other apps or websites.

The app is supported by advertising. We work with third-party ad networks (including Google AdMob, ironSource, AppLovin, Start.io, and Facebook Audience Network) that collect and use advertising identifiers and device information to display ads.

This Privacy Policy explains how Velastra LLC handles information for the Phrase Ace app and related pages. For the terms governing use of the app, please see our Terms of Service.

2. What We Collect

We do not collect personal information such as your name, email address, or account credentials. Phrase Ace does not require registration or login.

However, our third-party advertising partners collect the following information:

  • Advertising Identifiers: Google Advertising ID (AAID) on Android and Identifier for Advertisers (IDFA) on iOS
  • Device Information: Device type, model, operating system version, mobile network information, and language settings
  • IP Address: Used to derive approximate location (country/city level) for ad serving and fraud prevention
  • Ad Interaction Data: Information about ads shown, viewed, or clicked within the app
  • App Usage Information: How you interact with the app to help determine relevant advertisements

Analytics & usage data (aggregated, non-personal): To improve quality and understand which features are used, we rely on privacy-respecting analytics provided by app stores (Apple App Store Analytics and Google Play Console). These may include:

  • App version, device model, and operating system version
  • Session counts, screens or features opened, basic performance metrics (e.g., crashes, if you opt in at the OS level)
  • Coarse, aggregated region or language information (when available in store dashboards)

3. Advertising & Third-Party Services

The app is supported by advertising. We work with third-party ad networks that collect and use information to display ads. Ads may be personalized (based on your interests) or non-personalized (contextual).

Third-Party Advertising Networks & Services:

What Information Ad Networks Collect:

  • Advertising Identifiers: Google Advertising ID (AAID) on Android and Apple's Identifier for Advertisers (IDFA) on iOS – unique, user-resettable identifiers for advertising purposes
  • Device Information: Device type, model, operating system version, screen size, mobile network information
  • IP Address: Used to derive approximate geographic location (country/city level) for ad targeting and fraud prevention
  • Ad Interaction Data: Which ads were shown, viewed, clicked, or interacted with
  • App Activity: Information about how you use the app to help determine relevant advertisements

Personalized vs. Non-Personalized Ads:

  • Personalized ads are tailored to you based on your advertising ID, interests, and previous ad interactions across apps and websites
  • Non-personalized ads are based only on contextual information (like app content you're viewing) and general location, without using your advertising ID for targeting

Additional Ad Partners: The ad networks listed above may work with additional advertising partners and demand sources. These partners operate under their own privacy policies and may also collect device and interaction data.

4. On-Device Data & Permissions

To function, the app stores limited data locally on your device, such as:

  • Favorites, learning progress, and basic in-app settings
  • Ad preferences and frequency capping data (managed by our advertising providers)

This information remains on your device and is not transmitted to our servers. The app may request standard permissions (e.g., storage, internet access) strictly to support the features you choose to use. You can change permissions in your device settings.

Note: Uninstalling the app or resetting your device may delete locally stored data. We cannot restore it because we never receive it.

5. Payments

Phrase Ace offers a single, lifetime unlock (one-time purchase) that removes ads. Payments are processed by:

  • Apple App Store (iOS)
  • Google Play Store (Android)

We do not receive your full payment details. Pricing, taxes, refunds, and receipts are governed by the app store's terms and policies.

6. Data Sharing & Service Providers

We do not sell your data. We do not sell or rent your information to third parties for their independent marketing purposes.

Sharing with Service Providers: Data may be shared with the following third-party partners solely for advertising, analytics, and app functionality purposes:

  • Google AdMob – Advertising services (collects and processes advertising data as described in Section 3)
  • ironSource (Unity LevelPlay) – Ad mediation services (collects and processes advertising data as described in Section 3)
  • AppLovin – Advertising and mediation services (collects and processes advertising data as described in Section 3)
  • Start.io – Advertising services (collects and processes advertising data as described in Section 3)
  • Facebook Audience Network – Advertising services (collects and processes advertising data as described in Section 3)
  • Google Play Services / Apple App Store – App distribution, purchase processing, and aggregated analytics (non-personal)

These service providers operate under their own privacy policies. They may process and store data globally to provide advertising, analytics, and fraud prevention services.

Legal Disclosures: We may disclose information if required by law, legal process, or to protect the rights, property, or safety of Velastra LLC, our users, or others.

Data Retention: We retain aggregated analytics only as long as reasonably necessary for app improvement and performance insights. Local data stored on your device (favorites, progress) remains until you delete it or uninstall the app. Advertising partners retain data according to their own retention policies (typically 30-90 days for ad interaction data).

7. Your Choices & Opt-Outs

Opt Out of Personalized Ads:

  • iOS (iPhone/iPad):
    • Settings > Privacy & Security > Tracking > Disable "Allow Apps to Request to Track"
    • Settings > Privacy & Security > Apple Advertising > Disable "Personalized Ads"
  • Android:
    • Settings > Google > Ads > Enable "Opt out of Ads Personalization"
    • You can also reset your advertising ID: Settings > Google > Ads > Reset advertising ID
  • Google Ads Settings (Web): Visit Google Ads Settings to control personalized ads from Google
  • NAI Opt-Out (Web): Visit NAI Opt-Out to opt out of interest-based advertising from participating networks
  • DAA Opt-Out (Web): Visit DAA Consumer Choice for additional opt-out options

Note: Opting out of personalized ads does not mean you will see fewer ads. You will still see the same number of ads, but they will be less relevant to your interests.

Other Choices:

  • Remove All Ads: Purchase the one-time, lifetime ad-free unlock via in-app purchase to completely disable all advertising
  • App Permissions: Review and manage app permissions (storage, internet) in your device settings
  • Delete Local Data: Clear app data in device settings or uninstall the app to remove all locally stored information (favorites, progress)
  • Limit Analytics: Disable app store analytics sharing:
    • iOS: Settings > Privacy & Security > Analytics & Improvements > Disable "Share iPhone Analytics"
    • Android: Settings > Google > Usage & diagnostics > Disable
  • Questions or Requests: Email contactus@velastrallc.com for privacy-related questions or to exercise your rights

8. Children's Privacy (COPPA Compliance)

This app is NOT directed to children under the age of 13.

Children under 13 should not use this app. Users aged 13-17 should use the app only with permission from a parent or legal guardian.

We do not knowingly collect personal information from children under 13 years of age. The app does not require account creation, and we do not intentionally request, collect, or process personal data from anyone we know to be under 13.

Our third-party advertising partners (Google AdMob, ironSource, AppLovin, Start.io, Facebook Audience Network) may collect advertising identifiers and device information as described in Section 3. Where supported, we configure these services to serve age-appropriate, non-personalized ads when usage suggests a child may be using the app.

Parental Rights: If you are a parent or legal guardian and believe your child under 13 has used the app or that information about your child has been collected, please contact us immediately at contactus@velastrallc.com. We will take steps to delete such information as quickly as possible.

This policy is designed to comply with the Children's Online Privacy Protection Act (COPPA) in the United States and similar laws in other jurisdictions.

9. Data Security

We take reasonable measures to protect information collected through the app, although no system is 100% secure.

  • Local Storage: Data stored on your device (favorites, progress, settings) is protected by your device's built-in security features and operating system permissions
  • No Backend Servers: We do not operate backend servers or databases that store your personal information
  • Third-Party Security: Our advertising partners (Google AdMob, ironSource, AppLovin, Start.io, Facebook Audience Network) and platform providers (Apple, Google) use industry-standard encryption and security measures to protect data transmission and processing
  • HTTPS/TLS: All network communications use encrypted connections (HTTPS/TLS) when transmitting data

Important: While we implement reasonable security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of any information transmitted through or stored by the app.

10. International Users & Data Transfers

Phrase Ace is operated by Velastra LLC, a company based in the United States. Our advertising partners (Google AdMob, ironSource, AppLovin, Start.io, Facebook Audience Network) and platform providers may transfer and process data in the United States and other countries where they or their partners operate.

Data Transfer: By using the app, you acknowledge and consent to the transfer of information to countries outside your country of residence, which may have different data protection laws than your jurisdiction.

European Users (GDPR): If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have certain rights under the General Data Protection Regulation (GDPR), including:

  • Right to access your data
  • Right to correct inaccurate data
  • Right to request deletion of your data
  • Right to object to or restrict processing
  • Right to data portability

Since the app stores data locally on your device and we do not collect personal information directly, most data rights can be exercised by adjusting device settings or uninstalling the app. For questions about your rights or to make a request, contact us at contactus@velastrallc.com.

California Users (CCPA): California residents have rights under the California Consumer Privacy Act, including the right to know what data is collected and to request deletion. Contact us at contactus@velastrallc.com to exercise these rights.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the "Last Updated" date above and may provide additional notice in the app or on our website. Your continued use of the app after an update means you accept the revised policy.

12. Contact Us

Velastra LLC
8 The Green, Suite B
Dover, DE 19901, United States

Email: contactus@velastrallc.com

Contact: contactus@velastrallc.com

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