Privacy policy

Last updated 29 September 2026

This privacy notice for Emma Williams (doing business as Pronuntia Apps) ("we", "us" or "our") describes how and why we might access, collect, store, use and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application, Pronuntia, or any other application of ours that links to this privacy notice.
• Use Pronuntia. Pronuntia is a mobile app that teaches British English (RP) pronunciation through short lessons, recorded audio, mouth-position diagrams and quizzes. Some lessons are free; the rest are unlocked with an optional Pro subscription.
• Engage with us in other related ways, such as contacting us for support.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at pronuntia.dev@gmail.com.

Summary of key points

This summary provides key points from our privacy notice. You can find more detail about any of these topics in the table of contents below.

What personal information do we process? When you use our Services, we process personal information depending on how you interact with us and the Services. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? No. We do not process sensitive personal information.

Do we collect any information from third parties? Only your subscription status, which we receive from the Apple App Store or Google Play through our subscription provider, RevenueCat. Learn more about information collected from other sources.

How do we process your information? We process your information to provide and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We share information with the service providers that run parts of our Services, and in specific situations described below. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way is by emailing pronuntia.dev@gmail.com. We will consider and act upon any request in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you disclose to us

In short: we collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services or when you contact us. The personal information we collect is:

• email addresses
• passwords (stored securely by our authentication provider; we never see them)
• the learning goal you choose during sign-up (e.g. work, travel)
• messages you send us for support or feedback, including the device and app details added to those emails

Sensitive information. We do not process sensitive information.

Payment data. Subscriptions are purchased through the Apple App Store or Google Play, which process your payment under their own privacy policies (Apple, Google). We never see or store your card or billing details. We receive only your subscription status (for example, which plan you have and when it renews), via our subscription provider RevenueCat (privacy policy), so we can unlock Pro features and restore your purchases on other devices. To cancel, manage or request a refund for a subscription, use your App Store or Google Play account settings.

Application data. When you use our app, we automatically collect mobile device data: your device model and manufacturer, operating system and version, app version, your account's identifier, and your Internet Protocol (IP) address. This information is needed to keep the app secure and working, and to troubleshoot problems.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to it.

Information automatically collected

In short: some information, such as your IP address and device characteristics, is collected automatically when you use our Services.

We automatically collect certain information when you use the Services. This information does not reveal your specific identity (like your name or contact information). The information we collect includes:

• Log and usage data. Service-related, diagnostic and performance information our servers automatically record when you use the Services: your IP address, device information, the date and time of your activity, and error reports (sometimes called "crash reports").
• Device data. Information about the phone or tablet you use: device model, operating system, system configuration and app version.
• Learning progress. Lessons and sounds you have completed, XP, the days you practised, your recent quiz answers (right or wrong) and your chosen learning goal. Used to show your progress and sync it across your devices.

Information collected from other sources

In short: we receive your subscription status from the app stores.

If you subscribe to Pronuntia Pro, we receive your subscription status (which plan you have, when it renews or ends, and whether a purchase was restored or refunded) from the Apple App Store or Google Play, through our subscription provider RevenueCat. We use it only to unlock Pro features. We do not obtain information about you from public databases, marketing partners, data brokers or social media.

2. How do we process your information?

In short: we process your information to provide and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for the following reasons:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. (Retention period: until you delete your account; backup copies are removed within 30 days of deletion.)
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. (Retention period: until you delete your account; backup copies are removed within 30 days of deletion.)
• To respond to user inquiries and offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. (Retention period: 2 years after your last message, or longer if needed to resolve a dispute.)
• To send administrative information to you. We may process your information to send you account messages, such as password resets and changes to our terms or this notice. (Retention period: until you delete your account.)
• To fulfil and manage your subscriptions. We may process your information to manage your subscription and restore your purchases. (Retention period: until you delete your account. Apple, Google and RevenueCat keep their own purchase records as required for tax and accounting, typically up to 6 years.)
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. (Retention period: up to 90 days.)
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To save and sync your learning progress. We store your learning progress (lessons and sounds completed, XP, practice days, recent quiz answers and your chosen learning goal) so it is saved to your account and available on any device you sign in on. (Retention period: until you delete your account.)

3. What legal bases do we rely on to process your information?

In short: we only process your personal information when we believe it is necessary and we have a valid legal reason (a legal basis) to do so under applicable law, such as to provide you with the Services under our contract with you, to comply with laws, to protect your rights, or for our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission (consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services, or at your request before entering into a contract with you.
• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information to diagnose problems and/or prevent fraudulent activities.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process or settle an insurance claim
• For identifying injured, ill or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When and with whom do we share your personal information?

In short: we share information with the service providers listed below, and in the specific situations described in this section.

Service providers. We share your data with the service providers below, who perform services for us and need access to that information to do that work. Supabase, RevenueCat, Cloudflare and Sentry process it on our behalf under contracts designed to safeguard your personal information: they may only use it as we instruct and must protect it. The Apple App Store and Google Play process payments and beta testing as independent companies under their own privacy policies. Support emails are handled in Google's Gmail.

• Functionality and infrastructure optimisation: Supabase
• Invoicing and billing: RevenueCat, Apple App Store and Google Play
• User account registration and authentication: Supabase
• Website hosting: Cloudflare (Cloudflare Pages)
• Performance and crash monitoring: Sentry
• Testing: TestFlight and Google Play Console
• Customer support email: Gmail

We may also need to share your personal information in the following situation:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Is your information transferred internationally?

In short: we may transfer, store and process your information in countries other than your own.

Our servers are located in Germany and the United States. Your information may be transferred to, stored by and processed by us and the service providers we share it with (see "When and with whom do we share your personal information?" above), including in Germany, the United States, Ireland and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK) or Switzerland, these countries may not have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses. We protect your personal information by using the European Commission's Standard Contractual Clauses (and, for the UK, the UK International Data Transfer Addendum) for transfers between us and our service providers. These clauses require recipients to protect personal information that originates from the EEA or UK in accordance with European data protection laws and regulations. Details of these safeguards can be provided on request.

6. How long do we keep your information?

In short: we keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). Our retention periods for each purpose are listed in "How do we process your information?".

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because it is stored in backup archives), we will securely store it and isolate it from any further processing until deletion is possible.

7. How do we keep your information safe?

In short: we aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

8. What are your privacy rights?

In short: depending on your state of residence in the US, or in some regions such as the European Economic Area (EEA), United Kingdom (UK), Switzerland and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change or terminate your account at any time, depending on your country, province or state of residence.

In some regions (like the EEA, UK, Switzerland and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the details in "How can you contact us about this notice?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us:

• Email: pronuntia.dev@gmail.com
• Post: see "How can you contact us about this notice?"

What happens after you complain:

• We will acknowledge your complaint within 30 days of receiving it.
• We will investigate without unjustifiable or excessive delay.
• We will keep you informed of progress and explain the outcome.

If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office (ICO), the UK supervisory authority:

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: if we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw it at any time by contacting us using the details in "How can you contact us about this notice?" below. This will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, processing conducted in reliance on lawful grounds other than consent.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.
• Delete your account yourself: open the app and go to Settings → Delete my account. To change your email address or ask us to delete your data, contact us.

When you delete your account, we delete your account and information from our active databases. Copies may remain in backups for up to 30 days. We may keep some information where needed to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at pronuntia.dev@gmail.com.

9. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. We do not track you across other apps or websites in any case.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

10. Do United States residents have specific privacy rights?

In short: if you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. For a complete inventory of all personal information we process, see "What information do we collect?".

For category D we receive only your subscription status; payment details stay with Apple or Google. For category F, "network activity" means your activity within our app (your learning progress and server logs); we do not collect your browsing history or activity on other websites or apps.

We may also collect other personal information outside of these categories where you interact with us in the context of:

• receiving help through our customer support channels;
• taking part in an optional customer survey (for example, when cancelling a subscription); and
• facilitating the delivery of our Services and responding to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A: as long as the user has an account with us
• Category D: as long as the user has an account with us
• Category F: as long as the user has an account with us

Sources of personal information

Learn more about the sources of personal information we collect in "What information do we collect?".

How we use and share personal information

Learn more about how we use your personal information in "How do we process your information?".

Will your information be shared with anyone else? We may disclose your personal information to our service providers under a written contract between us and each service provider. Learn more in "When and with whom do we share your personal information?".

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category D. Commercial information
• Category F. Internet or other electronic network activity information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "When and with whom do we share your personal information?".

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending on the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question and, depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to exercise your rights

To exercise these rights, email us at pronuntia.dev@gmail.com; use the app (Settings → Contact support, which sends us an email, or Settings → Delete my account to delete your account and data yourself); or use the contact details at the bottom of this notice.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request verification

When we receive your request, we will need to verify your identity to determine that you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information we already hold, we may ask you to provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide written and signed permission from you to submit the request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at pronuntia.dev@gmail.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine the Light" law

California Civil Code Section 1798.83, also known as the "Shine the Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit it in writing using the contact details in "How can you contact us about this notice?".

11. Do other regions have specific privacy rights?

In short: you may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services, in particular to:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the details in "How can you review, update or delete the data we collect from you?".

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the details in "How can you review, update or delete the data we collect from you?".

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator:

The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za

12. About the Pronuntia app

Your device: the app stores your progress and sign-in session on your device so it works offline and keeps you signed in. This storage is necessary for the app to work and is not used for tracking or advertising.

No recordings: the app does not use your microphone or camera and does not record your voice.

Subscriptions and account deletion: you can delete your account at any time in the app (Settings → Delete my account); this deletes your account and learning progress. Deleting your account does not cancel an App Store or Google Play subscription. To stop being charged, cancel the subscription in your App Store or Google Play account settings.

Age: the app is intended for people aged 13 and over. If you are under 13, please do not use it. If we learn that we hold information about a child under 13, we will delete it.

13. Do we make updates to this notice?

In short: yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this notice. If we make material changes, we may notify you either by prominently posting a notice of the changes or by sending you a notification directly. We encourage you to review this privacy notice regularly to stay informed about how we are protecting your information.

14. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at pronuntia.dev@gmail.com or contact us by post at:

15. How can you review, update or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update or delete your personal information, email pronuntia.dev@gmail.com, or delete your account yourself in the app (Settings → Delete my account).

This privacy policy was created using Termly's Privacy Policy Generator.