Privacy Policy – Phrase Ace

Last Updated: February 18, 2026

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

Account required. Data collected and shared with third parties.

Phrase Ace requires you to create an account to use the app. We collect your name, email address, user ID, advertiser ID, crash logs, and your approximate location inferred from IP address. This data may be used and shared with third parties for app functionality, analytics, advertising, marketing, developer communications, fraud prevention, personalization, and account management.

The app is supported by advertising. We work with third-party ad networks (including Google AdMob, ironSource LevelPlay, 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

Phrase Ace requires you to create an account to use the app. We collect the following information directly from you and your device:

Account & Personal Information:

  • Name: Your name as provided during account creation
  • Email Address: Used for account identification, communications, and support
  • User ID: A unique identifier assigned to your account

Device & Technical Information:

  • Advertiser ID: Google Advertising ID (AAID) on Android and Identifier for Advertisers (IDFA) on iOS
  • Crash Logs: Diagnostic data including crash reports and performance logs to help us identify and fix issues
  • Approximate Location: Country/city-level location inferred from your IP address
  • Device Information: Device type, model, operating system version, mobile network information, and language settings
  • IP Address: Used to infer approximate location, support ad serving, and prevent fraud

Usage & Interaction Data:

  • Ad Interaction Data: Information about ads shown, viewed, or clicked within the app
  • App Usage Information: How you interact with the app, including session data, features used, and learning activity

How We Use Your Data: The information we collect may be used and shared with third parties for the following purposes:

  • App Functionality: To enable features, authenticate users, and provide the core learning experience
  • Analytics: To understand how the app is used, monitor performance, diagnose bugs, and make improvements
  • Advertising & Marketing: To display ads, target marketing communications, and measure ad performance
  • Developer Communications: To send news, notifications about updates, security alerts, or new features
  • Fraud Prevention, Security & Compliance: To monitor for fraudulent activity, ensure security, and comply with applicable laws
  • Personalization: To customize your experience, including recommended content and suggestions based on your learning habits
  • Account Management: To create, maintain, and manage your user account and verify your credentials

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. Data Storage & Permissions

The app stores data both locally on your device and on our servers:

  • On your device: Favorites, learning progress, cached content, and basic in-app settings
  • On our servers: Account information (name, email, user ID), learning progress, streaks, review history, favorites, and notification preferences
  • With third parties: Ad preferences and frequency capping data (managed by our advertising providers)

The app may request permissions including storage and internet access to support app features. You can change permissions in your device settings at any time.

To delete your account and all associated data, visit Settings > Delete Account in the app, or email contactus@velastrallc.com. See our Delete Account page for details.

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: Your data (including name, email, user ID, advertiser ID, crash logs, and approximate location inferred from IP address) may be shared with the following third-party partners for app functionality, analytics, advertising, marketing, developer communications, fraud prevention, security, compliance, personalization, and account management purposes:

  • Google AdMob – Advertising services (collects and processes advertising data as described in Section 3)
  • ironSource LevelPlay (Unity) – 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 your account information and associated data for as long as your account is active. When you delete your account, all data is permanently deleted immediately. Advertising partners retain data according to their own retention policies (typically 30-90 days for ad interaction data). See our Delete Account page for details.

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 Your Account: Delete your account and all associated data through Settings > Delete Account in the app, or by emailing contactus@velastrallc.com. See our Delete Account page for details
  • 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. 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 LevelPlay, 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.

  • Account Security: Your account credentials and personal information are stored securely using industry-standard encryption and access controls
  • Local Storage: Data stored on your device (favorites, progress, settings) is protected by your device's built-in security features and operating system permissions
  • Third-Party Security: Our advertising partners (Google AdMob, ironSource LevelPlay, 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 LevelPlay, 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

To exercise your data rights, you can use in-app controls at Settings > Legal > Privacy Choices to withdraw consent for personalized advertising, delete your account through Settings > Delete Account, or contact us at contactus@velastrallc.com. See our Delete Account page for details.

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

Back to Home