Privacy Policy for LexiqOn

1. Introduction

Welcome to LexiqOn, an AI-powered vocabulary learning application developed by **LLC NorsKod** (DUNS: 933923014).

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use the LexiqOn mobile application ("App"). By using LexiqOn, you agree to the practices described in this policy.

Contact Information:
LLC NorsKod
Address: 720021, Kyrgyzstan, Bishkek, Ibraimova 42, 78
Email: hello@lexiqon.online
Website: https://lexiqon.online

2. Information We Collect

2.1. Information You Provide Directly

**Vocabulary Test Data**
- Your answers to vocabulary questions
- Test scores and results
- Learning preferences and settings

**Voice Recordings (Optional - Paid Feature)**
- Audio recordings of your speech during voice analysis sessions
- These recordings are processed in real-time and **not permanently stored**

**User Settings**
- App preferences and configurations
- Notification settings
- Theme preferences

2.2. Automatically Collected Information

**Device Information**
- Device model and type (e.g., iPhone 15 Pro)
- Operating system version (e.g., iOS 17.2)
- App version number
- Device language settings
- Screen resolution

**Usage Data**
- Features you use within the App
- Time spent on different activities
- Test completion rates
- Learning session frequency
- Crash reports and error logs

**Learning Progress Data**
- Vocabulary size estimates
- Test history and scores
- Achievements and milestones
- Streak data
- XP and level progression

2.3. Subscription Information

**Payment Data (Processed by Apple)**
- Subscription type (Monthly, Quarterly, Annual)
- Purchase date and renewal date
- Transaction ID (provided by Apple)

**Note:** We do not collect or store your credit card information. All payment processing is handled securely by Apple.

2.4. Information We Do NOT Collect

We do not collect:
- Your real name (unless you provide it voluntarily)
- Email address (unless you contact support)
- Phone number
- Physical address
- Social Security Number or government ID
- Precise location data (GPS coordinates)
- Photos or camera access
- Contacts from your device
- Browsing history outside the App

3. How We Use Your Information

We use collected information for the following purposes:

3.1. Provide the Service
- Assess your vocabulary size using AI algorithms
- Generate personalized learning recommendations
- Track your learning progress over time
- Provide test results and analytics
- Sync data across your devices via iCloud (if enabled)

3.2. Improve the App
- Analyze usage patterns to improve features
- Fix bugs and technical issues
- Optimize performance and user experience
- Develop new features based on user behavior

3.3. AI-Powered Features
- Process voice recordings through OpenAI's Whisper API for speech-to-text
- Analyze speech patterns using OpenAI's GPT models
- Generate vocabulary recommendations based on your level

3.4. Communications
- Send important updates about the App
- Respond to your support requests
- Notify you about new features (if you opt-in)
- Send subscription renewal reminders

3.5. Legal Compliance
- Comply with applicable laws and regulations
- Enforce our Terms of Service
- Protect against fraud or security threats

4. Data Storage and Security

4.1. Local Storage
All your learning data is primarily stored **locally on your device** using:
- iOS UserDefaults (for settings and preferences)
- Core Data (for test results and progress)
- Keychain (for secure credential storage)

4.2. iCloud Sync (Optional)
If you enable iCloud sync:
- Your learning progress is backed up to Apple's iCloud servers
- Data is encrypted during transmission and storage
- You can disable iCloud sync at any time in Settings

4.3. Voice Data Processing
When you use the Voice Analysis feature ($4.99 add-on):
- Audio is recorded temporarily on your device
- Sent securely via HTTPS to OpenAI's API servers
- Processed in real-time for analysis
- **Immediately deleted** after processing
- **No recordings are permanently stored** on our servers or OpenAI's servers

4.4. Security Measures
We implement industry-standard security measures:
- HTTPS encryption for all data transmission
- Secure authentication for API requests
- Regular security audits and updates
- Access controls to limit data exposure
- Encrypted backups (via iCloud)

**However, no method of transmission or storage is 100% secure.** While we strive to protect your data, we cannot guarantee absolute security.

5. Third-Party Services

LexiqOn uses the following third-party services:

5.1. OpenAI API

**Purpose:** Voice analysis and speech processing
**Data Shared:** Voice recordings (temporary), text transcriptions
**Privacy Policy:** https://openai.com/privacy

OpenAI processes voice data according to their privacy policy. Voice recordings are:
- Sent securely via HTTPS
- Processed in real-time
- **Not used for training AI models** (per OpenAI's API terms)
- Deleted immediately after processing

5.2. Apple Services

**App Store / In-App Purchases**
- Payment processing
- Subscription management
- Transaction receipts

**iCloud (Optional)**
- Data backup and sync across devices
- Privacy Policy: https://www.apple.com/legal/privacy/

**Apple Push Notification Service (APNs)**
- Delivery of app notifications
- Device tokens (anonymized)

5.3. Analytics (Future)
We may integrate analytics services in the future (e.g., Firebase Analytics). If we do:
- We will update this Privacy Policy
- You will be notified in-app
- Analytics will be anonymized

6. Data Sharing and Disclosure

6.1. We Do NOT Sell Your Data
We **never** sell, rent, or trade your personal information to third parties for marketing purposes.

6.2. Service Providers
We may share data with trusted service providers who help us operate the App:
- OpenAI (for voice analysis)
- Apple (for payments and iCloud)

These providers are bound by confidentiality agreements and may only use your data to provide services to us.

6.3. Legal Requirements
We may disclose your information if required by law:
- To comply with legal processes (e.g., subpoena, court order)
- To protect our rights, property, or safety
- To prevent fraud or security threats
- To enforce our Terms of Service

6.4. Business Transfers
If LLC NorsKod is acquired, merged, or sold, your data may be transferred to the new owner. You will be notified of any such change.

7. Your Privacy Rights

7.1. Access Your Data
You can view all your data stored in the App:
- Go to **Profile → Settings → Data Management**
- View test history, progress, and settings

7.2. Delete Your Data
You have the right to delete your data at any time:
- **Local Data:** Settings → Clear All Data
- **iCloud Data:** Disable iCloud sync and delete from iCloud Settings
- **Complete Deletion:** Uninstall the App

7.3. Export Your Data
Premium users can export their data:
- Go to **Profile → Settings → Export Data**
- Choose format: PDF or CSV
- Share via email or save to Files

7.4. Opt-Out of Notifications
Control notifications:
- **In-App:** Settings → Notifications → Disable
- **Device Level:** iOS Settings → LexiqOn → Notifications → Off

7.5. Disable iCloud Sync
- Settings → iCloud Sync → Off
- Existing iCloud data will remain until manually deleted

7.6. Request Data Deletion
Contact us at support@lexiqon.online to request:
- Complete data deletion from our systems
- Information about what data we have
- Correction of inaccurate data

**Response Time:** We will respond within 30 days.

8. Children's Privacy

LexiqOn is designed for users aged **13 and older**. We do not knowingly collect personal information from children under 13.

If you believe a child under 13 has provided us with personal information:
- Contact us immediately at support@lexiqon.online
- We will delete the information as soon as possible

**Parental Consent:** If you are between 13-18, ensure you have parental consent before using the App.

9. International Data Transfers

9.1. Data Processing Locations
Your data may be processed in:
- **Kyrgyzstan** (where LLC NorsKod is based)
- **United States** (OpenAI servers)
- **Apple's global servers** (various locations for iCloud)

9.2. Data Protection
We ensure appropriate safeguards for international transfers:
- Standard contractual clauses
- Adherence to GDPR principles (where applicable)
- Encryption during transmission

9.3. Your Rights
If you are in the **European Economic Area (EEA)** or **UK**:
- You have additional rights under GDPR
- Contact us for GDPR-specific requests
- Right to lodge a complaint with your data protection authority

10. Data Retention

10.1. Local Data
- Stored on your device indefinitely until you delete it
- Automatically deleted when you uninstall the App

10.2. iCloud Data
- Retained as long as iCloud sync is enabled
- Deleted when you disable sync and remove from iCloud

10.3. Voice Recordings
- Processed in real-time via OpenAI API
- **Immediately deleted** after processing
- **Retention period: 0 days** (not stored)

10.4. Support Communications
- Emails and support tickets retained for 2 years
- Used only for customer service purposes

11. Cookies and Tracking

### 11.1. The App Does NOT Use:
- Cookies
- Web beacons
- Cross-site tracking
- Advertising identifiers (IDFA)

### 11.2. Device Identifiers
We use anonymized device identifiers only for:
- Crash reporting
- App performance monitoring
- Preventing fraud

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be communicated via:
- In-app notification
- Update to this page with new "Last Updated" date
- Email (if you've provided one)

**Material changes** will be highlighted and require your acceptance.

**Continued use** of the App after changes constitutes acceptance of the updated policy.

**Version History:**
- **v1.0** - October 8, 2025: Initial version

13. Your Consent

By using LexiqOn, you consent to:
- This Privacy Policy
- Processing of your data as described herein
- Use of third-party services (OpenAI, Apple)

**You can withdraw consent** by:
- Stopping use of the App
- Deleting your data (Settings → Clear All Data)
- Uninstalling the App

14. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights:

14.1. Right to Know
Request details about what personal information we collect and how we use it.

14.2. Right to Delete
Request deletion of your personal information (with certain exceptions).

14.3. Right to Opt-Out
We do **not** sell personal information, so no opt-out is necessary.

14.4. Non-Discrimination
We will not discriminate against you for exercising your CCPA rights.

**To exercise your rights:** Contact hello@lexiqon.online

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, please contact us:

**LLC NorsKod**
Address: 720021, Kyrgyzstan, Bishkek, Ibraimova 42, 78
Email: hello@lexiqon.online
Website: https://lexiqon.online
DUNS: 933923014

**Response Time:** We typically respond within 48-72 hours.

16. Compliance

This Privacy Policy complies with:
- Apple App Store Guidelines
- iOS Privacy Requirements
- GDPR (General Data Protection Regulation) principles
- CCPA (California Consumer Privacy Act)
- COPPA (Children's Online Privacy Protection Act)
*Last updated: October 8, 2025*
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