Privacy Policy

Last Updated: November 19, 2025

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

Turkey, Ankara

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: Pages visited, time spent, features used (e.g., "Word Wizard", "Chat"), and learning progress (streaks, CEFR levels).
Device Data: IP address, browser type, operating system, and device identifiers.
Analytics Data: We use Umami Analytics to collect anonymized usage statistics, including page views, navigation patterns, and performance metrics. IP addresses are anonymized and no personally identifiable information is collected.
Cookies: We use essential cookies for authentication (maintaining your session).

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: To analyze website usage, improve user experience, and understand how users interact with our Service.
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.
Umami Analytics	Website analytics and performance monitoring (anonymized data only).

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.
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: Turkey, Ankara

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