Effective date: August 21, 2026 · Last updated: September 13, 2026
This Privacy Policy explains how Velastra LLC ("Velastra," "we," "us," or "our") collects, uses, and shares information in connection with the Phrase Ace mobile application (the "App") and the Phrase Ace website (together, the "Services").
This policy takes effect on August 21, 2026 and replaces all prior versions. It does not apply to third-party services that you access separately, or to Apple's and Google's own handling of information under their respective privacy policies.
For the terms governing your use of the App, see our Terms of Service.
This summary is for convenience only. The full policy below controls.
Phrase Ace requires an account. Depending on how you use the App, we collect the following categories of information:
Phrase Ace does not access the Apple Identifier for Advertisers (IDFA) or use any advertising identifier.
Events describing how you use the App, such as:
We do not receive or store your payment card number, bank details, or billing address. Those are handled by Apple and Google. See Section 10.
We use this information to understand which of our own campaigns and links bring people to Phrase Ace. It is not used to build advertising profiles or to target you across other companies' apps or websites.
This information is stored on your device and, where the feature is available, synchronized with your account so it is available when you sign in again or on another device.
We do not use your information for third-party advertising, targeted advertising, advertising measurement, or to build advertising profiles about you.
We use the service providers below to operate Phrase Ace. They process information on our behalf and under our instructions, for the limited purposes described here. They are not permitted to use your information for their own cross-app advertising purposes, and they do not become the owners of your data.
Other disclosures. We may also disclose information:
We do not disclose your personal information to third parties for their own independent marketing purposes.
Apple defines "tracking" as linking user or device data collected from an app with user or device data collected from other companies' apps, websites, or offline properties for targeted advertising or advertising measurement purposes, or sharing user or device data with a data broker. Phrase Ace does neither.
The identifiers described in this policy are used for first-party analytics, account functionality, subscription entitlement, and notification delivery only. Using an analytics provider inside our own app is not cross-app tracking, and we do not describe it as such.
We want to be precise about this, because it is the point most privacy policies get wrong.
As a result, Mixpanel may receive:
We therefore do not claim that our analytics data is anonymous or "not linked to you." For signed-in users, it is linked. This information is used for first-party product analytics and app functionality — not for advertising, and not for tracking you across other companies' apps or websites.
Not all data in the App leaves your device. The distinction matters, so here it is plainly:
| Stored on your device | Transmitted to our service providers |
|---|---|
| Cached lesson and phrase content | Account details (email, name where held, account ID) → Supabase |
| App settings and preferences | Learning progress, streaks, favorites, and review history, where account synchronization applies → Supabase |
| Learning progress and favorites held locally between syncs | Usage events and profile properties → Mixpanel |
| Session state and tokens used to keep you signed in | Subscription and entitlement data → RevenueCat, Apple, Google |
| — | Push token and basic device information → OneSignal (only if you enable notifications) |
Data held only on your device is governed by your device's own security and can be removed by deleting the App. Deleting the App does not by itself delete your account or the data synchronized to your account — see Section 11.
Phrase Ace offers paid subscriptions. All purchases are processed by the Apple App Store or Google Play under their own terms and privacy policies. Refunds are handled by Apple or Google in accordance with their policies.
We do not receive or store your payment card number, financial account details, or billing address. We receive only the subscription information described in Section 3(d), which we use through RevenueCat to determine whether your subscription is active.
We keep personal information for as long as your account is active, and for as long as we need it for the purposes described in this policy or to meet legal, accounting, or security obligations.
Deleting your account. You can delete your account from inside the App (Settings → Delete Account), or by emailing us at contactus@velastrallc.com from the address associated with your account. See our Delete Account page for step-by-step instructions.
When you delete your account, we delete your account record and the learning data associated with it — including progress, streaks, favorites, review history, and notification preferences — from our production systems, and we instruct our service providers to delete the personal information they hold on our behalf.
Please be aware of the following limits, which we state honestly rather than promising a clean erasure we cannot deliver:
Deleting the App from your device does not delete your account. Cancelling a subscription does not delete your account, and deleting your account does not automatically cancel a subscription — cancel through the App Store or Google Play as described in our Terms of Service.
We take reasonable technical and organizational measures designed to protect personal information, including encryption of data in transit over HTTPS/TLS, authentication and access controls on our backend, and reliance on established infrastructure providers.
No system is completely secure. We cannot guarantee the security of information transmitted over the internet or stored on any system, and we do not claim that our Services are impenetrable. We also do not claim any security certification or audit that we have not obtained.
You play a part too: use a strong, unique password, keep your device and sign-in credentials secure, and tell us promptly at contactus@velastrallc.com if you believe your account has been compromised.
Velastra LLC is based in the United States. Our service providers and infrastructure providers may store and process information in the United States and in other countries where they or their sub-processors operate.
If you are located outside the United States, your information will be transferred to, and processed in, countries whose data protection laws may differ from those of your own country.
Where such transfers are subject to European Economic Area, United Kingdom, or Swiss data protection law, we rely on transfer mechanisms recognized under applicable law, such as the European Commission's Standard Contractual Clauses and the equivalent UK and Swiss mechanisms, as incorporated into our agreements with our service providers. You may contact us at contactus@velastrallc.com for further information about the safeguards applicable to a specific transfer.
To be clear about what does not exist: the App does not currently include an in-app toggle to opt out of product analytics. If you wish to object to or opt out of analytics processing, please email us at contactus@velastrallc.com and we will handle your request manually.
Privacy rights depend on where you live. The rights described below apply to the extent applicable law grants them to you. To exercise any of them, email contactus@velastrallc.com from the address associated with your account, or use the in-App controls where available. We will not discriminate against you for exercising a privacy right. We may need to verify your identity, and we will respond within the timeframe required by applicable law.
If the GDPR or UK GDPR applies to our processing of your information, you may have the right to access your data; to have inaccurate data corrected; to have data erased; to restrict or object to processing; to data portability; and, where processing is based on consent, to withdraw that consent at any time without affecting processing already carried out. You also have the right to lodge a complaint with your local supervisory authority.
Our legal bases. Where the GDPR or UK GDPR applies, we rely on:
If you object to analytics processing carried out on the basis of our legitimate interests, contact us and we will stop that processing for you unless we have compelling legitimate grounds that override your interests.
If you are a resident of California or of another United States state with a comprehensive consumer privacy law, you may have the right to know what personal information we collect and how we use and disclose it; to access or obtain a copy of it; to correct it; to delete it; and to be free from discrimination for exercising these rights. Some states also provide a right to appeal a decision on your request; if we decline a request, our response will tell you how to appeal where that right applies.
We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act, as amended, or the equivalent provisions of other state laws. We therefore do not offer a "Do Not Sell or Share My Personal Information" mechanism, because there is nothing to opt out of. We also do not use or disclose sensitive personal information for purposes that would trigger a right to limit its use.
The categories of personal information we collect, the sources, the purposes, and the categories of recipients are set out in Sections 3 through 6 of this policy. You may use an authorized agent to submit a request where applicable law permits.
If the law of your jurisdiction grants you privacy rights not listed above, contact us and we will honor those rights to the extent they apply.
Phrase Ace is not directed to children under 13.
Children under 13 may not use the App. Users aged 13 to 17 should use the App only with the permission of a parent or legal guardian.
We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without the consent required by law, we will delete it.
Parents and guardians: if you believe a child under 13 has provided us with personal information, contact us at contactus@velastrallc.com and we will take steps to delete it promptly.
Because Phrase Ace contains no third-party advertising and does not track users across other companies' apps or websites, we do not use children's information for advertising purposes of any kind. Where you are located in a jurisdiction that sets a higher age of digital consent than 13, that higher age applies to processing that depends on consent.
The Phrase Ace website is an informational site. It does not require an account and does not set advertising cookies.
We use Mixpanel to understand how the website is used. On the website, Mixpanel records:
The identifier is stored in your browser's local storage, not in a cookie. Website analytics are not linked to your Phrase Ace account, are not used for advertising, and are not used to track you across other companies' sites.
If you visit from the European Economic Area, the United Kingdom, or Switzerland, website analytics are off until you choose "Allow analytics" in the prompt shown on your first visit; declining keeps them off. To make that decision, our hosting provider looks at the country your connection appears to come from and stores only the result ("regulated" or "unregulated") in a small functional cookie for 30 days. You can change your choice at any time using the Analytics Preferences link in the site footer, or by clearing site data for phraseace.app in your browser.
Like virtually every website, it is served by a hosting provider that keeps server logs containing information such as IP address, request time, requested URL, referring URL, and browser user-agent string. These logs are used to deliver the site, diagnose problems, and protect against abuse, and are retained for a limited period under the hosting provider's standard retention practices.
The website links to the Apple App Store and Google Play. When you follow those links, Apple's or Google's own privacy policies govern what they collect.
We may update this Privacy Policy from time to time. When we do, we will revise the effective date at the top of the page. If we make material changes, we will provide additional notice through the App, by email, or on this website before the change takes effect, where applicable law requires it or where we otherwise consider it appropriate. Your continued use of the Services after an update takes effect means you have read the revised policy.
Questions, requests, or complaints about this policy or your personal information:
Velastra LLC
8 The Green, Suite B
Dover, DE 19901
United States
Email: contactus@velastrallc.com
Contact: contactus@velastrallc.com