Privacy Policy

Effective date: 10 November 2026

In short: LearnScramble has no account and doesn't ask for your name, email or phone number. Your settings, progress and the words you've learned stay on your iPhone. To create new words and pictures, the app sends your job, your two languages and the words you've already practised to our server, which asks OpenAI — only after you agree to it in the app — and keeps new words and pictures in a common word library on Google Firebase, without anything that identifies you. The app signs in to our server with a random ID, not with your name or email. If you report a wrong picture or word, only the word, your job and — for a word — the correction you typed are sent. If the app crashes or something goes wrong, a short technical report is sent so we can fix the problem. The pronunciation test uses the microphone and Apple's speech recognition only after you allow them; we never receive your voice. Usage statistics are sent only if you switch them on. We don't show ads, don't track you across apps and don't sell data. LearnScramble is run from Ontario, Canada; the services we use store and process data in the United States (see section 7).

Who is responsible
Data stored on your iPhone
Data sent to other services
What we don't collect
Why we use data (legal bases)
How long data is kept
International transfers
Your rights
Security and data breaches
Children
Changes to this policy
Contact

1. Who is responsible

LearnScramble is provided by Max Gabriel, a sole proprietor operating under the registered business name PawIT, Ontario, Canada ("we", "us"). We are responsible for your personal information under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), and we are the "controller" under the EU and UK General Data Protection Regulation (GDPR).

Person in charge of privacy (privacy officer; for Québec, the person in charge of the protection of personal information): Max Gabriel, owner, support@learnscramble.com. This person makes sure we follow this policy and answers privacy questions, requests and complaints.

2. Data stored on your iPhone

This data is created by you while using the app. It stays on your device and is not sent to us.

What	Details	Why
Your setup	The language you speak, the language you learn, your job (from the list), speech speed, chosen voice per language, daily reminder on/off and time, whether you finished the setup and the "How to play" tutorial, when you agreed to sending your job to OpenAI, and whether usage statistics are on.	To remember your choices between launches.
Learning progress	For each word you've answered: the word's English name, the language you practised it in, how many times you were right and wrong, and when you last answered it — and the word itself: the job it belongs to, the word in both languages, its picture and the picture's link.	To show your scores and progress, avoid repeating words, and show your words in "My words" and repeat them, also without internet.
Pronunciation results	For each word you've tested in the pronunciation test: how many times you said it right on the first try and how many times you needed more tries. No recordings and no text of what you said.	To show your pronunciation score and put the words that are hardest for you to say first.
Listening results	For each word you've tested in the listening test: how many times you tapped the right picture and how many times you tapped another one. The test uses no microphone and sends nothing.	To show your listening score and put the words you miss most first.
Free-word counter	How many of your 10 free words you've used. Kept in the iPhone's secure storage (Keychain).	To give 10 free words once. It stays on your iPhone even after you delete the app, so the free words can't be taken again by reinstalling.
Days in a row	The last day you played and how many days in a row you've played.	To show your streak, and to skip the reminder on days you've already played.
Daily reminders	The reminders planned for the next 7 days. They are scheduled by iOS on your iPhone; no server is involved.	To remind you at your chosen time, only on days you haven't played.

You can delete your answers and saved words for one language with Settings → Progress → Reset progress, and all app data with Settings → Delete my data or by deleting the app (except the free-word counter, see above). Delete my data also deletes the random sign-in ID (section 3), and the app starts over like a new install. Unlocked professions are kept by Apple with your purchases and come back with Restore purchases. The data may also be included in your own iPhone backups.

Spoken words are produced by your iPhone's built-in text-to-speech, on the device. For the pronunciation test, see "Apple — speech recognition" in section 3.

For troubleshooting, the app also writes short technical messages to the iPhone's own system log. Your job is marked private there, so iOS hides it outside of development tools. These messages stay on the iPhone; only the last few steps, without your job or words, are included in a crash or error report (see section 3).

3. Data sent to other services

OpenAI — creating words and pictures

We ask first. Before any request is sent, the app asks you to agree: on the setup screen ("I agree"), or once in a separate question if you set up the app before this question existed. Without your agreement the app can't create words, so no game starts and nothing is sent. The same explanation stays visible in Settings → Legal and support.

When the app needs new words, it sends a request to our server (Google Cloud Functions for Firebase, in the United States), which sends OpenAI, L.L.C. (United States):

your job (as chosen from the list);
the language you speak and the language you learn;
the English names of words you've already practised in that language, so they aren't repeated;
for new pictures: a short description of the object to draw.

The app talks only to our server; OpenAI's key is kept on the server, never in the app. Pictures are downloaded straight from the word library (Google Cloud Storage).

OpenAI doesn't receive your name, your random sign-in ID or any device identifier; our server sends only the items listed above. OpenAI receives our server's address, not your iPhone's. According to OpenAI's policies, data sent through its API is not used to train its models by default and may be kept for a limited time (currently up to 30 days) to monitor abuse.

Google Firebase — the shared word library

Words and pictures are stored in a library shared by all LearnScramble users, on Google Firebase (Cloud Firestore and Cloud Storage), operated by Google LLC / Google Ireland Ltd. Only our server writes to it; the app itself can't change it. The server:

reads words that already exist (by their English name), so known words and pictures are reused instead of created again;
adds new words: the English name, the word in your two languages, and a link to the picture;
marks which jobs a word is used for, by the job's common English name (for example "cook"), so the same words and pictures can be offered to the next learner with that job instead of being created again;
saves new pictures (images of objects drawn by OpenAI, never photos of you).

Nothing that identifies you is stored with these words — only the English job names they belong to, shared by everyone with that job. When your iPhone downloads pictures or calls our server, Google receives your IP address and technical information (such as the app and SDK version and device type) needed to deliver the service. Google Cloud also keeps a technical log of each request to our server — the time, the IP address, the app version and short notes such as the word, job and language codes involved — for 30 days, so we can find and fix problems. Data location: the United States (Cloud Firestore: Google's “nam5” United States multi-region; Cloud Storage: United States multi-region). See section 7 for how transfers outside the EU are protected.

Google Firebase — the list of jobs people learn for

To see which jobs are used most, our server counts them in a list on Google Firebase (Cloud Firestore). When you start learning for a job (once per job on your iPhone), its English menu name (for example "electrician") is counted.

The list stores only the English job name, how many times it was chosen, and when it was first and last seen — nothing that identifies you or your iPhone.

Google Firebase and OpenAI — reporting a wrong picture

If a picture doesn't show its word, you can tap the flag on the picture and confirm. The app then sends our server the word's English name, your job's English name and the link of the picture you saw. The server asks OpenAI to describe the object again for your job and draw a new picture, which is sent to your iPhone and kept there with the word — only you see it. The report is added to a list of reported pictures (word, jobs, number of reports, the picture you saw, the new picture and its description, times), and we receive a daily email with the new reports. After checking, we may use the new picture in the shared word library for everyone. To count how many different people reported a word, the server keeps a one-way code made from your random sign-in ID (it can't be turned back into the ID); nothing else about you is stored with a report. To stop misuse, the server also counts how many pictures each random sign-in ID reported today (overwritten every day).

Google Firebase and OpenAI — reporting a wrong word or translation

If a word or its translation is wrong, you can type the correct version and send it (Wrong word? after an answer, or the flag in "My words"). The app then sends our server the word's English name, your job's English name, your two language codes, the word and translation you saw, what you typed instead and, if you wrote one, your short note. The server asks OpenAI whether the current translation is right for your job, as a second opinion. The report is added to a list of reported words (word, language, jobs, the current text, the corrections and notes people typed, OpenAI's opinion, number of reports, times), and we receive a daily email with the new reports. After checking, we may correct the word in the shared word library for everyone. Please don't write personal details in the note. As for pictures, the server keeps only a one-way code made from your random sign-in ID with a report, and word reports count toward the same daily limit.

Google Firebase — random sign-in ID and daily counts

So that only the LearnScramble app can use our server, the app signs in to Firebase Authentication (Google) anonymously, without any screen: Firebase gives the app a random ID. It isn't linked to your name, email, phone number or Apple ID. Firebase deletes each anonymous ID 30 days after it was created, and the app then gets a new one.

With that ID our server keeps two small records: today's date with how many pictures and words you've reported today, and today's date with how many new pictures were drawn for you today. Both are overwritten every day. They limit reports (10 a day) and new pictures (100 a day, see the Terms) to protect the service from misuse; they don't contain your job, your words or your answers. If someone reaches the picture limit, our server emails us a one-way code made from the random ID (it can't be turned back into the ID), so we can spot misuse.

Apple and Firebase App Check — proving requests come from the real app

Each request to our server carries a short-lived token from Firebase App Check (Google). On a real iPhone, the token comes from Apple's App Attest, which confirms that the request comes from a genuine copy of LearnScramble on a genuine Apple device. It contains no personal information and isn't used to identify you.

Firebase Crashlytics — crash and error reports

The app sends a report to Firebase Crashlytics (Google) the next time you open it if it crashed, or if something went wrong without a crash — for example when new words couldn't be loaded because there was no internet. A report contains:

where in the app's code the problem happened, the type of error (for example "no internet" or "server busy") and a short technical description of it from iOS or the server;
the language you speak and the language you learn;
the app's last technical steps before the problem, such as "round finished" or "10 words loaded" — counts and steps only;
the iPhone model, iOS version, app version, free memory and disk space, and whether the app was in the foreground;
a random installation ID created by Firebase, so repeated problems on the same iPhone are counted once. It isn't linked to your name, your Apple ID or any other identifier.

Reports don't contain your job, the words you practise or your answers. We use them only to find and fix bugs. Crashlytics keeps them for 90 days, after which Google starts removing them from its systems.

Google Analytics for Firebase — usage statistics (only if you switch it on)

"Share usage statistics to help improve the app" is off until you turn it on, on the setup screen or in Settings → Legal and support. You can turn it off again at any time. Only while it's on, the app sends Google Analytics for Firebase:

which parts of the app are used, for example "setup finished", "round finished", "review started", "free words used", "unlock screen shown", "profession unlocked" (with the product's name) or "picture reported", with simple details such as the number of review words or the type of error when words couldn't be loaded;
the language you speak and the language you learn (sent when you finish the setup);
which job from the menu you chose;
the iPhone model, iOS version, app version, app language and approximate country (from the IP address);
a random app-instance ID created by Firebase, so visits from the same iPhone can be counted. The app doesn't use the advertising identifier (IDFA).

The statistics are about how the app is used, not about who you are. They don't include the words you practise or your answers. Analytics keeps them for 2 months.

Apple — speech recognition for the pronunciation test (only when you use it)

The pronunciation test checks how you say a word. It uses the microphone and Apple's speech recognition, and only after you allow both in the iOS questions that appear the first time you tap Tap to speak. You can change this at any time in iOS Settings → Privacy & Security → Microphone and → Speech Recognition; everything else in the app works without them.

The microphone is on only while the button shows Listening…: from your tap until you stop speaking, at most a few seconds.
What you say is turned into text by Apple's speech recognition (Apple Inc. / Apple Distribution International). Depending on your iPhone and language, iOS does this on your iPhone or sends the audio to Apple's servers; Apple handles it under its own Privacy Policy (see also iOS Settings → Privacy & Security → Speech Recognition).
The app compares that text with the word on your iPhone. We don't receive, record or keep your voice or the text, and nothing about the test is sent to our server, OpenAI or Google. Only the results described in section 2 stay on your iPhone.

Apple

Purchases: professions are unlocked with one-time purchases through Apple's App Store, and restored there. Apple processes your payment; we don't receive your payment details. The app only asks Apple which professions you own. See Apple's Privacy Policy.
Notifications: if you allow them, daily reminders are local notifications scheduled on your iPhone; no notification server or push token is used.

Our service providers' own policies

Each service above handles data under its own rules too:

OpenAI: Privacy Policy · How API data is handled · Data Processing Addendum
Google (Firebase, Crashlytics, Analytics): Google Privacy Policy · Privacy and security in Firebase · Firebase Data Processing and Security Terms
Apple (App Store, notifications, speech recognition): Apple Privacy Policy

4. What we don't collect

No account, name, email address or phone number. (The app's anonymous sign-in uses a random ID only, see section 3.)
No location, contacts, photos or camera. The microphone is used only during the pronunciation test, while it's listening, and we never receive or keep recordings (see section 3).
No advertising, no advertising identifier, no tracking across other apps or websites.
No usage statistics unless you switch them on (see section 3).
We don't sell or rent data to anyone.

5. Why we use data (consent and legal bases)

We collect only what the app needs for the purposes below and don't use data for anything else without asking you again.

In Canada we rely on your consent. We ask for it expressly before your job and languages are sent to OpenAI ("I agree"), before usage statistics are sent (off until you switch it on), and — through iOS — before the microphone and speech recognition are used for the pronunciation test. For what the app needs to work and stay secure — the random sign-in ID, App Check, crash and error reports, the free-word counter and the daily report and picture counts — your consent is implied when you use the app after reading this policy; none of it is sensitive or identifies you by name. You can withdraw your consent at any time: switch statistics off in Settings, or stop using the app and delete it. Without the consent to send your job to OpenAI the app can't create words.

In the EU/EEA and the UK the legal bases are:

To provide the app you asked for — creating words and pictures for your job and languages, remembering your settings and progress (performance of a contract, Art. 6(1)(b) GDPR).
To keep the free words fair and the service working and secure — the free-word counter, the daily report and picture counts, the random sign-in ID and App Check (legitimate interests, Art. 6(1)(f) GDPR).
To fix wrong pictures and words you report (legitimate interests, Art. 6(1)(f) GDPR). A report holds only a one-way code of your random sign-in ID, to count reporters, and — for a word — the correction and note you typed.
To improve the job menu by counting jobs in English, without anything that identifies you (legitimate interests, Art. 6(1)(f) GDPR).
To build the shared word library so words and pictures are reused for all learners (legitimate interests, Art. 6(1)(f) GDPR). It contains no personal data.
The pronunciation test only if you allow the microphone and speech recognition (consent, Art. 6(1)(a) GDPR) — you can withdraw it at any time in iOS Settings.
Reminders only if you allow notifications (consent, Art. 6(1)(a) GDPR) — you can switch them off at any time in the app or in iOS Settings.
Crash reports to keep the app working and fix bugs (legitimate interests, Art. 6(1)(f) GDPR).
Usage statistics only if you switch them on (consent, Art. 6(1)(a) GDPR) — you can switch them off at any time in Settings.

6. How long data is kept

On your iPhone: until you reset your progress or delete the app. The free-word counter stays in the Keychain until the iPhone is erased.
Shared word library: for as long as the service runs; it contains no personal data.
Random sign-in ID: deleted by Firebase 30 days after it was created. Daily counts on the server: today's date with the number of pictures and words reported and of new pictures drawn only, overwritten every day. Alert emails about the picture limit (with the one-way code) are kept in our mailbox for up to 12 months.
Server logs: 30 days, then deleted automatically by Google Cloud.
Reported pictures and words: the list of reports, the pictures drawn for them, the replaced pictures, and the corrections and notes typed for words, for as long as the service runs; the one-way reporter codes are kept with them. The daily report emails are kept in our mailbox.
OpenAI: according to OpenAI's API data policy (see above).
Pronunciation test: we keep no recordings or text. Your results stay on your iPhone until you reset your progress or delete the app. Audio sent to Apple for recognition is handled under Apple's policy.
Crash reports and usage statistics: for the periods given in section 3.
Emails to support: for as long as needed to answer you, then deleted after 12 months.

7. International transfers

We are in Ontario, Canada, but the service providers we use — Google (Firebase) and OpenAI — store and process data in the United States, and may use other countries for support or backups. While it is there, the data is subject to the laws of those countries and may be accessed by their courts, law enforcement and national security authorities. We choose providers that protect data under written agreements (their data processing terms) and send them only what is listed in section 3. If you live in Québec: your information is communicated outside Québec, to these providers in the United States, for the purposes in this policy.

For people in the EU/EEA and the UK these transfers are protected as follows: Google is certified under the EU–U.S. Data Privacy Framework (with its UK Extension and the Swiss–U.S. framework) and also offers the European Commission's Standard Contractual Clauses in its Firebase data processing terms. OpenAI relies on the European Commission's Standard Contractual Clauses (with the UK Addendum for UK data) in its Data Processing Addendum.

8. Your rights

Because the app has no account and keeps your data on your iPhone, most of it is already under your control (see section 2). For anything else, write to the person in charge of privacy (section 1). We answer within 30 days, free of charge. We may ask a question to make sure a request really comes from you. Because we don't know your name, we usually can't link the little data on our server to you: it's tied only to a random sign-in ID that Firebase deletes after 30 days, or to nothing at all.

Everyone, including in Canada: you can ask what personal information we hold about you, how it's used and who it was shared with, ask us to correct it, and withdraw your consent (see section 5). If we can't give access, we tell you why.
Québec: also the right to have your information deleted or de-indexed where the law allows, and to receive it in a structured, commonly used technological format.
EU/EEA and UK: also the rights to erasure, to restrict processing, to object to processing based on legitimate interests, and to data portability.

Complaints. Please contact us first — we want to fix it. You can also complain to:

the Office of the Privacy Commissioner of Canada (priv.gc.ca);
in Québec, the Commission d'accès à l'information du Québec (cai.gouv.qc.ca);
in the EU/EEA or the UK, the data protection authority where you live or work.

9. Security and data breaches

We protect data with safeguards suited to how sensitive it is: all connections are encrypted (HTTPS); only our server can write to the word library, and phones can't read or change the database directly; the OpenAI key is kept in Google's Secret Manager, never in the app; only the genuine app can call our server (App Check); and access to our Firebase, Google Cloud and OpenAI accounts is limited to the people who run LearnScramble. No method is perfectly secure, but we keep data to the minimum described here.

If a breach of security safeguards involving your personal information creates a real risk of significant harm, we will tell you and the Office of the Privacy Commissioner of Canada (and, for Québec residents, the Commission d'accès à l'information) as soon as possible, as the law requires. We keep a record of every breach.

10. Children

LearnScramble is made for adults learning the language of their workplace. It is not directed at children under 16, and we don't knowingly collect personal information from them. If you are a parent or guardian and think a child has used the app, write to us and we'll help remove any data we can link to them.

11. Changes to this policy

If we change what the app collects — for example if accounts or business access codes are added — we'll update this page and the effective date before the change reaches the app. If a change means using your data for a new purpose, we'll ask for your consent again in the app.

12. Contact

Questions, requests and complaints about privacy: the person in charge of privacy, Max Gabriel, at support@learnscramble.com.