Nolelo Join the beta

Privacy policy

Effective

The short version. Nolelo stores your learning data so it can sync between your devices. Your writing is counted on your device and the text is discarded. Nolelo uses AI throughout, and each request carries only the text that task needs. No ads, no trackers, and we don't sell or share your data. You can export everything, and delete your account and all synced data, from Settings.

1. Who we are

Nolelo is a personal vocabulary trainer for iPhone, Mac and Apple Watch. It is owned and run by Netpixels Pty Ltd (ABN 39 666 681 009), a company registered in Australia (“we”, “us”). We decide how your personal information is used, which makes us its controller under the GDPR. Contact us at support@nolelo.com.

2. What we collect, and why

We collect only what Nolelo needs to work. The last column is the legal basis we rely on under the GDPR and UK GDPR.

WhatWhyLegal basis
Email address, and your name if you give itYour account, sign-in codes and password resetsContract
PasswordSigning in. It goes from your device to Amazon Cognito over an encrypted connection; our servers never receive it, and Cognito stores it only in a protected, hashed formContract
Your words, with their sentences, meanings, notes and tags; your review history; grammar progress; the corrections you keep; word counts from your writing and speakingSyncing your learning between your devicesContract
Words, sentences and text sent to AIDefining words, preparing practice, giving feedback on what you writeContract
A daily count of your AI requestsEnforcing the daily limitLegitimate interests: keeping the service affordable and available
IP address, account identifier, request times and error codesSecurity, stopping abuse, fixing faultsLegitimate interests: keeping the service secure and working
Emails you send usBeta invitations and supportLegitimate interests: answering you; contract once you use the app

You don't have to give us any of this, but without an account Nolelo can't sync, and without the email address we can't create one. You can use Nolelo without an account; everything then stays on your device and AI features are off.

We don't collect your location, contacts, photos, advertising identifiers or browsing history, and we don't ask for sensitive information such as health or religion. Please don't put sensitive information into text you send to AI.

3. What stays on your device

Nolelo can count the words you use when you write or speak, so it can tell when a word you saved has become one you actually use. The counting happens on your device and the text and audio are discarded there; only the counts are kept, and they sync to your own devices. Speech is transcribed by Apple's on-device speech recognition and the audio is never sent anywhere.

Also kept on your device only: your settings, reminders, and a record of which first-run steps you completed.

The Apple Watch app gets a short list of due cards from your iPhone, never from our servers, and sends your answers back to your iPhone.

4. AI features

AI is part of how Nolelo works. It defines a word when the dictionary has no entry for it, writes example sentences and practice prompts, gives feedback on the sentences you write, improves a text when you ask it to, and finds the grammar mistakes in your corrections and practice answers.

Some of this happens on its own. When you save a word the dictionary doesn't know, for example, Nolelo sends the word and the sentence you saved it from. Text you write is sent when you use a feature that works on it, such as submitting a practice answer or improving a text. Speaking feedback uses counts, such as filler words and pace, never a recording or a transcript. The word counts from your writing and speaking described in section 3 are not sent to AI.

Every request goes through our server to Google's Gemini API, and carries only what that task needs. There is no API key on your device.

We use Google's paid Gemini API service. Under Google's terms for that service, Google doesn't use your text to improve its products, and keeps prompts and responses only for a limited period to detect abuse.

Some answers about a word, such as its definition or how it's used, are cached and shared between users so the same question isn't asked twice. Only answers made from the word alone are shared; nothing you wrote is.

AI answers can be wrong. They are learning aids, not facts to rely on.

5. Dictionary lookups

When you save a word, your device looks it up in the Free Dictionary API (dictionaryapi.dev), sending only the word, and may play a recorded pronunciation from it. As with any website, that service receives your IP address. It is a free service run independently of us; we have no agreement with it, and it doesn't publish where it is hosted.

6. Who processes your information

These companies process information for us, only to provide Nolelo:

CompanyWhat forWhere
Amazon Web ServicesAccount and sign-in (Cognito), sync storage, our server, email deliverySydney, Australia
Google (Gemini API)AI featuresUnited States and elsewhere
Free Dictionary APILooking up the word you saveNot published by the service
Apple (TestFlight)Delivering the beta. Apple shares your tester email and name, device model and system version, crash reports, and feedback you choose to sendUnited States
CloudflareServing this websiteGlobal network
Cloudflare and Google (Gmail)Receiving and answering the emails you send usGlobal network; United States and elsewhere

We don't sell your personal information or share it for advertising, including as “sale” and “sharing” are defined in California law. We disclose information to others only when the law requires it, to protect people's safety or our rights, or as part of a sale or merger of Nolelo, in which case this policy continues to apply.

We don't look at your synced data, except when you ask us to help with a problem, to investigate a fault or abuse, or when the law requires it.

7. International transfers

Your synced data is stored in Australia. Text sent to AI is processed by Google, including in the United States. Where the law requires safeguards for these transfers, we rely on the European Commission's standard contractual clauses in our providers' data processing terms, their certification under the EU–US Data Privacy Framework, and, for Australian privacy law, reasonable steps to make sure overseas recipients handle your information consistently with the Australian Privacy Principles.

8. How long we keep it

WhatHow long
Account and synced dataUntil you delete your account
Database backupsUp to 35 days after deletion, then overwritten. Backups are used only to recover from failures
Server logs30 days
Record that an account was deleted24 hours, to stop your other devices writing to it
AI request countsKept with your account, and deleted with it
Emails you send usUp to 2 years after the conversation ends
Text sent to GoogleAs section 4 describes

9. How we protect it

Data is encrypted in transit and at rest. Each account's data lives in its own partition, and every request must carry a valid sign-in token for that account. On iPhone and Mac, sign-in tokens are kept in the system keychain. Each part of our server can reach only the data it needs, and only the AI service can use the AI key. If a breach puts you at risk, we will tell you and the regulators as the law requires.

10. Exporting and deleting your data

Settings → Export saves a copy of your words and reviews to a file you can keep or take elsewhere.

Settings → Delete account removes your account and every row synced under it, then erases Nolelo's data on that device. A device still signed in elsewhere keeps its local copy until you sign out there or remove the app, but it can no longer sync. Signing out erases the account's data from that device. If you can't reach the app, email us and we will delete your account for you.

11. Your rights

Wherever you live, you can ask us for a copy of your information, to correct it, or to delete it. Most of this you can do yourself in the app; for anything else, email support@nolelo.com. We reply within 30 days and don't charge. We may need to confirm the request comes from the account holder.

In the EU, EEA and UK you also have the right to restrict or object to our processing, to data portability, and to withdraw consent where we rely on it. You can complain to your local data protection authority (in the UK, the Information Commissioner's Office).

In Australia you can use Nolelo without giving your name. As a small business, Netpixels isn't covered by the Privacy Act, but we follow the Australian Privacy Principles all the same, and we'll answer any complaint in writing.

In the United States, residents of states with consumer privacy laws have similar rights to know, correct and delete, and we honour them for everyone. We won't treat you differently for using them.

Nolelo does not make decisions about you by automated means that have legal or similarly significant effects. Scheduling your reviews and estimating your grammar level are learning aids only.

12. Children

Nolelo is not meant for anyone under 16, and we don't knowingly collect information from children under 13. If you believe a child has given us information, email us and we will delete it.

13. This website

nolelo.com is a static site on Cloudflare Pages. It sets no cookies, stores nothing in your browser, and runs no analytics. Cloudflare processes your IP address to deliver the page; everything on it, fonts included, comes from nolelo.com itself. Because nothing on the site tracks you, we treat every visitor the same, whether or not their browser sends a Do Not Track signal.

14. Emails

We email you to confirm your address, to reset your password, and about important changes to your account or this policy. We send news about Nolelo only if you ask for it, and every such email lets you unsubscribe.

15. Changes to this policy

When this policy changes we update the date at the top. If a change matters, for example a new kind of data or a new company processing it, we tell you in the app or by email before it takes effect.

16. Contact

Questions, requests and complaints: support@nolelo.com. We reply within 30 days.