Privacy policy

Welcome to Vebulo! Vebulo is owned and operated by Oleksandr Kovalenko. Vebulo values your privacy and the protection of your personal data. This privacy policy describes what information we collect from you, how we collect it, how we use it, how we obtain your consent, how long we keep it in our systems, and, where necessary, with whom we share it.

By using the platform, you agree to the practices described in this privacy policy. Your use of the platform is also subject to our terms and conditions. In this privacy policy, the word "platform" refers to the Vebulo mobile app and the Vebulo website together, unless they are referred to individually; "we", "us", "our", and "Vebulo" refer to Oleksandr Kovalenko, the individual operator of Vebulo; and "you" and "user" refer to you, the user of Vebulo.

This privacy policy may change from time to time. Your continued use of the platform after we make changes is deemed acceptance of those changes, so please check the policy periodically for updates. This privacy policy has been developed and is maintained in accordance with applicable national and international laws and regulations on privacy and personal data protection, in particular Organic Law 3/2018 of December 5 on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD) and the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679).

1. General information

The personal data of users collected and processed through the platform:

• Vebulo mobile app (available on Google Play and the App Store)
• Website (https://vebulo.com)

Is under the responsibility and charge of:

• Oleksandr Kovalenko
• Calle de Jose Manuel Bobes 10 Portal C 1, 33690 Llanera (Asturias), Spain
• Email: [email protected]

2. How we obtain your consent

By using the Vebulo platform, you acknowledge and accept that we collect, process, and store your personal data as set out in this privacy policy. Consent is considered freely given, specific, informed, and unambiguous when you perform any of the following activities:

• Visit and browse the Vebulo website.
• Download and install the Vebulo app from Google Play or the App Store.
• Create an account on the platform.
• Add phrases, topics, or other learning content to your library.
• Purchase a subscription through the payment methods available in the app stores.
• Use any of the features available on the platform, including translation, audio generation, and the Listen, Shadow, and Recall practice modes.
• Contact us through official channels, including email or other enabled means.

The processing of personal data collected through these activities is based on your express consent under the GDPR and the LOPD-GDD. You may revoke your consent at any time, without retroactive effect, through the mechanisms available on the platform or by contacting us directly through the contact details in this policy.

3. Types of data collected

When you use Vebulo, you provide different types of personal data as a result of using the available features, creating an account, purchasing a subscription, and communicating with us. The data collected may include the following:

Account data: the email address and password you provide when creating an account. Passwords are stored in hashed form. We also store your chosen native language, learning languages, and app language preference.

Learning content: the phrases you add to your library, in your native language and their translations in your target languages, the topics you organize them into, and your practice progress for each phrase (such as learning status and session history). Your phrases may include personal information if you choose to write it; you control what you add.

Subscription data: information needed to manage your subscription, such as the plan you selected, the store the purchase was made through, the purchase date, and the entitlement status. Payments are processed by Google Play or the App Store. We never receive or store your card details.

Usage data: information about actions performed in the app, such as the number of phrases added, practice sessions completed, features used, and frequency of use.

Automatically collected data: technical information collected automatically when you access the website or use the app, such as IP address, device type, operating system, time zone, app version, date and time of access, and error and crash reports.

Microphone and speech data: if you grant microphone permission, the app uses your device's built-in speech recognition to transcribe phrases you speak into the phrase field. The recognition runs through your device's operating system. Vebulo does not record, transmit, or store your voice audio; only the recognized text reaches our servers, and only if you save it as a phrase.

Contact and communication data: information you provide when you contact us, such as your name, email address, the subject of your inquiry, and the content of your message.

4. How long we keep your data

Personal data provided through the platform is kept for as long as necessary to fulfill the legitimate purposes described in this policy and/or until you stop using our services or request deletion of your data. We may keep personal data for a longer period where you have consented to such processing, as long as that consent is not withdrawn. We may also be obliged to keep personal data for a longer period where required to comply with a legal obligation or by order of an authority. Once the retention period has elapsed, personal data is deleted. Accordingly, the rights of access, erasure, rectification, and data portability cannot be exercised after the retention period has expired.

When you delete a phrase, its associated data is removed. When you delete your account, your personal data and learning content are removed from our systems, except where we are required to keep limited records to meet legal obligations.

5. Purposes of data collection

Data collected through Vebulo is used exclusively to make the platform work, deliver the learning features, improve the user experience, and keep the system secure and reliable. The legitimate purposes per data category are:

• Account data: to identify you as a user, sign you in, sync your library and progress across devices, communicate with you about your account, and prevent unauthorized or fraudulent activity.
• Learning content: to provide the core features of the app, including translating your phrases, generating audio for them, and running the Listen, Shadow, and Recall practice modes. Your phrases are processed only to deliver these features.
• Subscription data: to verify and maintain your subscription entitlement, unlock paid features, and resolve issues related to purchases.
• Usage data: to adapt features to user needs, detect problems, ensure features work as intended, and improve the learning experience.
• Automatically collected data: to ensure technical compatibility with your device, prevent security incidents, diagnose errors, and maintain expected performance.
• Contact and communication data: to respond to inquiries, support requests, complaints, or suggestions, and to maintain effective communication regarding your account and the platform.

6. How we share information

Our users' personal information is an important and fundamental part of how the platform works. We will never sell your personal information to third parties. We share user information only and exclusively as described below.

Translation and audio services. To deliver the core features, the text of your phrases is sent to Google Cloud Translation to produce translations and to Google Cloud Text-to-Speech to generate audio. Only the phrase text needed for these operations is sent; it is not accompanied by your identity.

Hosting and storage. Account data and learning content are stored on infrastructure hosted by DigitalOcean. Generated audio files are stored in Firebase (Google) storage. The website is served through Cloudflare.

Error monitoring. Vebulo uses Sentry to detect and diagnose technical errors, crashes, and performance problems in the app and on our servers. Sentry receives technical information such as device type, operating system, app version, and the technical context of an error. Error reports are used solely to fix problems and keep the platform stable.

Subscription management. Vebulo uses RevenueCat to manage subscriptions purchased through the app stores (Google Play and the App Store). RevenueCat verifies, organizes, and keeps a record of in-app purchases without access to sensitive payment details, which are processed directly by the payment services of the corresponding store.

Email delivery. We use an email delivery provider to send transactional messages such as account verification and password reset emails. Your name and email address may be shared with this provider solely for delivery.

Newsletter and email communications. By using our services, you authorize us to send you relevant information about Vebulo by email. You can unsubscribe at any time using the unsubscribe option in the footer of each email or by contacting us.

Business transfers. If Vebulo is incorporated into a company, merged, or acquired by another entity, your information would most likely be transferred. We will send you an email or place a prominent notice on our platform before your information becomes subject to another privacy policy.

Protection of Vebulo and others. We disclose personal information when we believe it is appropriate to comply with the law, enforce or apply our terms and conditions and other agreements, or protect the rights, property, or safety of Vebulo, our users, or others.

With your consent. Other than as set out above, you will receive notice when information that personally identifies you may go to third parties, and you will have an opportunity to choose not to share it.

7. Protection of your data

We grant access to your personal information only to those external services that have a legitimate need to know it and in accordance with this privacy policy. We adhere to industry-recognized security standards to protect your personal information, both in transit and at rest. However, no method of transmission over the Internet or electronic storage is infallible and 100% secure. Therefore, while we strive to apply commercially viable data protection methods, we cannot guarantee the absolute security of your personal information. We commit not to sell, distribute, or transfer your personal data to unauthorized third parties unless we have your explicit consent or are required to do so by law.

8. Data breach notifications

In the event of a security breach compromising the confidentiality of our users' personal data, we commit to notifying those affected in a timely manner. Notification will be made through the contact means provided by the user on our platform. We will take all reasonable measures to protect the information and remedy any situation that endangers the security of your data.

9. International data transfer

Vebulo may transfer users' personal data outside their country of origin due to the use of hosting, storage, and processing services provided by third parties operating servers in different countries. These transfers are necessary to ensure continuous operation of the platform. Although Vebulo is operated from Spain, the technology infrastructure used may mean data is stored or processed in jurisdictions whose data protection laws differ from those of the European Union.

We commit to ensuring that all international transfers of personal data comply with applicable data protection regulations, including appropriate safeguards such as standard contractual clauses and assessment of the adequacy of data protection in the receiving country. By using Vebulo, you consent to the transfer, storage, and processing of your data on servers located outside your country of residence, acknowledging that such transfers are necessary for the operation of the platform.

10. Rights

Users who provide information through our platform, as data subjects, have the right to access, rectify, download, or delete their information, as well as to restrict and object to certain processing. While some of these rights apply generally, others apply only in certain limited circumstances:

• Access and portability: to access and know what information is stored on our servers, send us a request through our contact details.
• Rectification, restriction, and erasure: you can rectify, restrict, or delete a large part of your information directly in the app, or by request through our contact details.
• Right to be informed: on request, you will be informed about what data we collect, how it is used, how long it is kept, and whether it is shared with third parties.
• Objection: where we process your information based on legitimate interests or the public interest, you may object to that processing in certain circumstances. We will stop processing unless we have compelling legitimate grounds or legal reasons to continue.
• Withdrawal of consent: where you have previously given consent, you may withdraw it at any time. In certain cases we may continue processing after withdrawal if we have a legal basis to do so.
• Complaint: if you wish to file a complaint about our use of your information, and without prejudice to any other right you may have, you may do so before the Spanish supervisory authority (Agencia Espanola de Proteccion de Datos, AEPD).
• Rights related to automated decision-making, including profiling: you may request a copy of automated processing activities if you believe data is being processed unlawfully.

You may exercise these rights at any time and without limitation by sending your request through our contact details. Requests will be handled and answered within a maximum of 10 business days.

11. Children's online privacy

We comply with national and international data protection regulations regarding the protection of minors' personal data. Vebulo is not directed at children under 13, and we do not knowingly collect any information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take immediate steps to delete it.

12. Third parties

Except where expressly included in this privacy policy, this document addresses only the use and disclosure of information that Vebulo collects from you. Vebulo does not control the privacy policies of third parties, and you are subject to those policies where applicable. Vebulo is not responsible for the privacy or security practices of other websites, platforms, or services, including those linked from our platform. Please review the privacy policies of third-party websites, platforms, or services you access through Vebulo.

13. Changes to this privacy policy

We reserve the right to modify this privacy policy at any time. Changes will be communicated to our users and published on the platform. Continued use of our platform after such changes implies acceptance of them.

14. Contact

If you have questions or concerns about this privacy policy or the processing and security of your data, please contact us using the contact information below:

Oleksandr Kovalenko, Calle de Jose Manuel Bobes 10 Portal C 1, 33690 Llanera (Asturias), Spain. Email: [email protected].