Privacy Policy
Last Updated: August 26, 2026
This Privacy Policy describes how Phrasium ("we", "us", or "our") collects, uses, and discloses your personal information when you use our website and AI-powered language learning services (the "Service").
We are committed to protecting your privacy and ensuring compliance with applicable data protection laws, including the GDPR, CCPA, and KVKK (Turkish Personal Data Protection Law).
1. Data Controller
The data controller for your personal information is:
Phrasium
1434 St. 11/10
Seker Neighborhood, Etimesgut
Ankara 06790
Turkey
Email: [email protected]
2. Age Restriction
Our Service is strictly intended for individuals who are 18 years of age or older.
We do not knowingly collect or solicit personal information from anyone under the age of 18.
If you are under 18, you are not authorized to use the Service or send any information about yourself to us. If we discover that we have collected personal information from a child under 18, we will delete that information immediately. If you believe that a minor under 18 may have provided us with personal information, please contact us at [email protected].
3. Information We Collect
We collect different types of information to provide and improve our Service:
3.1. Information You Provide
- Account Data: When you sign up, we collect your name, email address, and profile picture (if using Google OAuth).
- User Content: Any text, documents (PDF, DOCX, TXT), audio recordings, or images you upload to the Service for language analysis, translation, or flashcard generation.
- Communication Data: Content of messages you send to us for support or feedback.
3.2. Information Collected Automatically
- Usage Data: Information about how you interact with the Service, including pages visited, features used, and learning progress metrics.
- Device Data: IP address, browser type, operating system, and device identifiers.
- Analytics & Advertising Data: We use PostHog for product analytics and error tracking, and Meta Pixel (Meta Platforms, Inc.) to measure conversion events, optimize advertising campaigns, and evaluate marketing performance. No analytics or marketing events are dispatched without your prior consent.
- Cookies & Consent Tiers: We categorize our cookies into three distinct tiers:
- Essential Cookies: Strictly necessary for authentication, security, session management, and core features. These cannot be disabled.
- Analytics Cookies: First-party usage analytics, error tracking, session recording, and feature usage analysis. Disabled by default until you opt in.
- Marketing Cookies: Conversion measurement and ad performance evaluation. Disabled by default until you opt in.
You may review or modify your cookie consent choices at any time via the Cookie Preferences link in the website footer.
3.3. Payment Information
We do not store your credit card or banking information. All payments are processed by our Merchant of Record, Polar.sh. We only receive a confirmation of your subscription status and transaction metadata (e.g., date, amount).
4. How We Use Your Information
We use your data for the following specific purposes:
- Service Delivery: To create your account, authenticate you, and provide access to features like AI Chat and exercises.
- AI Processing: Your inputs (text and audio) are processed to generate language learning content.
- Communication: To send transactional emails (verification codes via Resend, subscription updates).
- Analytics & Marketing: To understand onboarding, activation, subscription conversion, return usage, and product reliability; to segment aggregated product metrics; and to measure advertising campaign effectiveness via Meta Pixel.
- Legal Compliance: To comply with applicable laws and regulations, including verifying age eligibility if necessary.
5. Data Sharing and Processors
We do not sell your personal data. We share data only with the following third-party service providers ("Processors") necessary to operate the Service:
| Provider | Purpose |
|---|
| OpenAI | AI text generation, translation, and speech-to-text transcription. |
| Cloudflare R2 | Secure storage of user-uploaded files and media. |
| Polar.sh | Merchant of Record, payment processing, and subscription management. |
| Resend | Delivery of transactional emails (OTP, notifications). |
| Neon | Database hosting and management. |
| PostHog | Product analytics and error tracking. |
| Meta Platforms, Inc. | Conversion measurement, advertising performance analytics, and campaign optimization (Meta Pixel). |
6. Your Data Rights
Regardless of your location, we grant you the following rights regarding your data:
- Right to Access: Request a copy of the personal data we hold about you.
- Right to Deletion (Erasure): Request the permanent deletion of your account and all associated data. When you delete your account, your personal data, uploaded resources, and associated analytics profiles are permanently deleted from our servers.
- Right to Portability: Request your data in a structured, machine-readable format.
7. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes via email or by posting the new policy on this page.
8. Contact Us
If you have questions about this Privacy Policy, please contact us at:
- Email: [email protected]
- Address: 1434 St. 11/10
Seker Neighborhood, Etimesgut
Ankara 06790
Turkey
