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Privacy Policy

See also: Terms of Use

SAYAN YAZILIM TEKNOLOJI ANONIM SIRKETI built the How to Say, Vocabulary Builder by Atlas, and Flowo AI apps as Ad Supported freemium apps. These SERVICES are provided by SAYAN YAZILIM TEKNOLOJI ANONIM SIRKETI at no cost and are intended for use as is.

This page is used to inform visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decides to use our Services.

If you choose to use our Services, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Services. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which are accessible at How to Say, Vocabulary Builder by Atlas, and Flowo AI, unless otherwise defined in this Privacy Policy.

Information Collection and Use

For a better experience, while using our Services, we may require you to provide us with certain personally identifiable information. Some information is retained on your device, while certain data—such as voice audio and conversation transcripts may be transmitted to third-party AI services for processing as described in the "Third-Party AI Data Processing (Flowo AI)" section below.

The apps do use third-party services that may collect information used to identify you.

Link to the privacy policy of third-party service providers used by the apps:

  • Google Play Services
  • AdMob
  • Firebase Analytics
  • Crashlytics
  • Facebook Analytics
  • Google Firebase AI (Gemini)
  • OpenAI
  • RevenueCat
  • Amplitude

Log Data

We want to inform you that whenever you use our Services, in the case of an error in the apps, we collect data and information (through third-party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol ("IP") address, device name, operating system version, the configuration of the apps when utilizing our Services, the time and date of your use of the Services, and other statistics.

Cookies

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.

These Services do not use these "cookies" explicitly. However, the apps may use third-party code and libraries that use "cookies" to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of these Services.

Service Providers

We may employ third-party companies and individuals due to the following reasons:

  • To facilitate our Services;
  • To provide the Services on our behalf;
  • To perform Service-related services; or
  • To assist us in analyzing how our Services are used.

We want to inform users of these Services that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

How to Say: AI Practice, Saved Data, and Your Choices

Updated September 28, 2026. This section applies only to How to Say and supplements the shared policy above. It does not change the disclosures for Vocabulary Builder by Atlas or Flowo AI.

AI processing and consent

How to Say uses Google Gemini through Firebase AI Logic to create practice situations, provide conversation replies and coaching feedback, and translate text. Depending on the feature you use, Google receives:

  • The situation description you type and the practice context needed to generate a scene.
  • Microphone audio during voice practice, transcripts of what you say, and relevant conversation messages.
  • Learning context, such as your selected level, target expressions, and practice instructions.
  • Text you ask to translate and your chosen translation language.

We ask for explicit in-app consent before sending your typed custom situation description or starting voice practice. Microphone permission is requested separately when you start speaking. You can decline or withdraw AI data-sharing consent through Profile → AI data sharing. Custom situation generation and speaking practice require that consent; browsing situations and your collection remains available. Withdrawing consent does not itself delete previously saved data.

How to Say uses the paid Gemini API service. Under Google's Gemini API terms for paid services, Google processes prompts and responses on our behalf and does not use them to improve its products or train its models. Google may retain prompts and responses for a limited period for abuse prevention, security, and legal obligations. This is separate from the learning records we save for you.

Account and saved learning data

We use Firebase Authentication to manage sign-in and an account identifier. Depending on your sign-in method and what you provide, account information can include your name and email address.

We store learning data in Google Firebase, linked to your account, to keep your progress and personalize practice. This includes your learning profile and level, practice history and results, saved expressions and situations, and custom situation descriptions and generated scenes. Saved feedback may include your own practice sentence, an explanation, and a suggested improvement. Custom situation records can also retain sentences in which you used an expression. These records may contain personal details if you include them in your descriptions or speech.

Our saved learning records do not include raw microphone recordings or full conversation transcripts. Audio and conversation text are still transmitted to Google for the AI processing described above.

Analytics, diagnostics, and advertising measurement

We use Amplitude and Firebase analytics services to understand feature use and improve the app. Usage information may include account and device identifiers, app and device details, interaction events, purchase events, and approximate location derived from an IP address.

To identify conversations that fail, stall, or do not save, we send Amplitude diagnostic events linked to your account. These include conversation and turn identifiers, the current conversation stage, durations, connection and audio state, error codes, recovery attempts, exits, and save outcomes. These diagnostic events do not include audio recordings, typed situation descriptions, conversation transcripts, or the content of your feedback. We use them for app functionality and analytics, not advertising tracking.

We also use Meta services for advertising measurement. Where Apple's App Tracking Transparency permission is required, the app requests it and uses your choice to control advertiser tracking. You can change that permission in iOS Settings. This permission is separate from AI data-sharing consent.

Purchases

Apple processes App Store payments. We use RevenueCat to manage purchase history, subscription status, and access to paid features, associated with your app account identifier. We do not receive your full payment-card details.

Retention, deletion, and privacy requests

We keep saved learning data so you can return to your practice history and synchronize it with your account. You can delete saved custom situations in the app or delete your account through Profile → Delete account. Account deletion removes the sign-in account and starts server-side cleanup of its saved learning data, custom situations, progress, and account-linked feedback. Cleanup runs in the background and may not finish immediately.

We retain a minimal security record containing an internal account identifier and deletion timestamps to prevent deleted data from being recreated by old sessions. It contains no email address, practice content, or audio.

Deleting your account does not cancel an App Store subscription; manage or cancel subscriptions in your Apple account settings. In-app deletion does not automatically erase historical analytics or purchase records held by service providers. Those records, and provider security logs or backups, are subject to the relevant retention policies and legal obligations. Removing the app alone does not delete your account or its saved server data.

For access, correction, or deletion requests, including data held by our service providers, contact support@atlasvocabulary.com and identify How to Say. We may need to verify account ownership before acting on a request.

Our providers may process data outside your country. Further information is available in Google's Privacy Policy, Firebase's privacy and security information, Amplitude's Privacy Notice, RevenueCat's Privacy Policy, and Meta's Privacy Policy.

Third-Party AI Data Processing (Flowo AI)

The following applies specifically to our app "Flowo AI."

Flowo AI uses third-party AI services to power its language learning features. The AI providers used are:

  1. Google (Gemini AI via Firebase AI Logic) — for real-time voice conversation practice
  2. OpenAI — for text-based conversation responses, speech-to-text transcription, text-to-speech audio, feedback, suggestions, and translations

When you use AI-powered features in Flowo AI, the following data may be sent to these providers for processing:

  • Voice audio recorded during conversation sessions (sent to Google Gemini and/or OpenAI)
  • Text transcripts of your spoken input
  • Conversation messages and context necessary to generate relevant responses

This data is sent to Google and OpenAI solely for the purpose of providing language learning features. These providers act as data processors and process data on our behalf. They do not use your data to train their AI models.

No AI processing occurs until you provide explicit in-app consent. You may decline AI data sharing, in which case AI-powered conversation features will not be available. You can revoke your consent at any time from the app settings.

For more information about how these providers handle data:

  • Google Privacy Policy
  • OpenAI Privacy Policy

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Links to Other Sites

These Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children's Privacy

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at support@atlasvocabulary.com so that we will be able to do the necessary actions.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at support@atlasvocabulary.com.

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