VocaX and Privacy

VocaX is designed to protect your information and to let you choose what you share.

What is Personal Data at VocaX?

At VocaX, we firmly believe in and respect fundamental privacy rights and believe that these fundamental rights should not differ depending on the country or region in which you live. Personal data includes any data relating to an identified or identifiable individual: data that can identify you directly (such as the account identifier Apple provides) is personal data, and data that cannot identify you directly but can identify you through reasonable inference (such as your learning records and drill data) is also personal data. The specific basis for processing and the rights you hold under the law are set out in the later sections of this Policy.

Your Privacy Rights at VocaX

Under the applicable law of your location, you may request to be informed of, to access, correct, copy, transfer, restrict the processing of or delete the personal data we actually process, and where processing is based on consent you may withdraw that consent as the law provides. We will not subject you to the discrimination the law prohibits because you exercise your privacy rights as the law allows; the scope of a request, verification and the statutory exceptions are determined by applicable law. You may also make a request through the contact details listed in this Policy.

You can exercise your privacy rights through:

After you sign in, your learning data is in fact stored in your iCloud account, and you can also obtain or delete your iCloud data through Apple’s Data and Privacy portal.

Personal Data Collected by VocaX

We process personal data only to the extent needed to provide the learning features. Learning content is stored mainly on your device or in your iCloud private database; when you use the online AI, content lookup and account security features, the request information needed and pseudonymous security records may be processed through our services in the ways disclosed in this Policy.

Accounts and Sync Credentials

When you use “Sign in with Apple”, Apple provides VocaX with an opaque, stable identifier used to identify your account within this service. It is a pseudonymous identifier that may be linked to an individual, and it is not equivalent to anonymous information. We have not requested your name or email address from Apple, so we cannot obtain your real name, email address or physical address through this identifier; your learning records in the iCloud private database are managed by the Apple account mechanism.

Profile (Optional)

We will ask for your nickname and your profile photo so that the “Account Settings” page of the app can greet you. Both are entirely optional. If you do not provide a nickname, the app will simply call you “you” by default. Your nickname and your profile photo are stored on your device; once you sign in, they sync together with your other learning data to your own iCloud private database and to your other devices; these two are also written into one profile record that is shared by the three apps VocaX, SlateX and CineX and that likewise lives only inside your own iCloud private store — when you sign in with the same iCloud account, all three apps can read it. A local copy of your nickname and your profile photo is also kept in the app’s storage area on this device: it survives signing out, and it is there only so that when you sign back in the screen already has a face for you without waiting for that one read from iCloud; it contains no learning records, and apart from these two display values it holds only an account code used to verify that this kept copy belongs where it came from; it does not appear on your other devices through the app’s synchronization mechanism; deleting your account clears it together with the other records this app leaves on this device. The profile photo lives only on your own device and in your own iCloud private database, and we do not receive it; when an AI learning report is generated, the only things given to the third-party AI provider are this week’s learning statistics, difficult words and wrong answers — the nickname and other identity information are not among them, and the report addresses you with the natural second person of that language. This app also keeps several credentials in the Keychain on this device: the opaque user identifier returned by Sign in with Apple, a marker recording that you have deliberately signed out, and a presence marker recording whether this app already has a shared profile record on this device. All of these stay only in the Keychain on this device; this app does not sync them to your other devices through iCloud Keychain; the sign-in identity among them is submitted along with the requests you send, for abuse prevention and quota checks. None of them contains your name, email address or phone number, and none of them includes, or points to, any media content of yours.

Zero Tracking Commitment and Apple Diagnostics

We do not integrate third-party behavioral tracking components in VocaX. The App may generate diagnostic records on the device for troubleshooting crashes or performance issues; the copies on this device are kept under the cleanup rules that actually apply. If you choose to share App analytics data in Apple’s system settings, Apple may provide us with crash and performance diagnostic information through its mechanism, so that we can troubleshoot failures and improve stability; the scope of that information and how it is retained are determined by this Policy and by Apple’s applicable terms.

Storage of and Access to Learning Data

Your vocabulary learning records, practice statistics and multi-dimensional interaction data are stored on your current device while you are not signed in, and after you sign in they are synced through CloudKit into your iCloud private database. This data is yours to dispose of: we cannot view its content; on the device, this app reads and writes, through the authorized interfaces Apple provides, the records necessary to provide you with the features.

How VocaX Uses Personal Data

We process your personal data in accordance with the personal information protection laws that apply where you are located. The items below state, for each category of processing, its purpose and its legal basis; when a particular law — for example the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) of the United States or the Personal Information Protection Law (PIPL) of China — applies to you, the corresponding processing is carried out on a basis that law recognizes:

Powering our services

VocaX processes your learning progress on your device in order to provide review plans and personalized learning suggestions; after you sign in, the corresponding learning data may sync to your own iCloud private database. Apart from the security, metering and abuse-prevention entries described in the “Data Retention” section of this Policy, we do not otherwise keep your learning content.

On-Device Intelligence

VocaX estimates the memory state of each word on the device from your review performance and generates learning suggestions. When you are not signed in, your learning data is stored on your current device; after you use “Sign in with Apple”, your learning data enters your own iCloud private database through Apple’s synchronization mechanism, and that private database is by default open only to the account owner. When you use translation, grammar analysis and word definitions, the text snippets needed to complete that request are given to a third-party AI provider for processing; an AI learning report is generated when you have turned that feature on and hold a valid subscription, and what is given to that provider includes the learning statistics, difficult words and practice content needed for this report, with no name, email address or phone number attached to the request. We do not ourselves use the request body for training or analysis; the provider’s own processing and retention are covered by the notes under “Training Data Isolation” below and by that provider’s own separate privacy policy.

Speech Evaluation Service

When you use speaking practice, VocaX analyzes the audio captured by the microphone on the device and gives pronunciation feedback. Word practice recordings are stored through CloudKit in your iCloud private database as part of your practice records; sentence practice recordings are used only for pronunciation calibration within that page; any recording that is not saved into your practice records is deleted from the device when a new practice run replaces it or when the cleanup cycle arrives. The recordings are not received by us and are not used to train models; you can delete the saved word practice records together with your account data.

Camera, Photo Library, and Apple Music

The camera and the photo library are used only for the two things that you start yourself: recognizing text on the Search page (using the camera to recognize the text in front of you in real time, or picking a photo from your photo library to recognize the text in it), and choosing the avatar for your account. Recognition is performed on your device by Apple’s Vision framework, and the images themselves are processed only on this device; picking a photo goes through the system’s photo picker, and this app does not request access to your photo library.

Apple Music is used only for ambient playback: we request authorization through Apple’s MusicKit and retrieve the specific background tracks by their track identifiers, which requires you to hold a valid Apple Music subscription of your own. We do not read your personal music library or your listening history.

Improve Learning Experience

We use your learning performance on the device to adjust review recommendations and training intervals, in order to improve the learning features you actually use. The corresponding learning content is stored mainly on your device or in your iCloud private database; other data processing involved in the online AI services and the security features is disclosed separately in the corresponding sections of this Policy.

Security & Compliance

We use the security capabilities provided by the device and by Apple’s account system to protect your learning records, and we take the technical and management measures necessary to reduce the risk of unauthorized access, tampering and disclosure. Data may be affected by the device, your account configuration or events on a third-party platform; the assurances and liability concerned follow the actual processing activity and applicable law.

Generative AI and Third-Party Processing

VocaX’s core definitions, example sentences, and translation features are powered by third-party Large Language Models (LLMs). To provide these services, the specific text snippets needed to complete that request are sent to the provider for processing. Those who receive these texts are the model provider selected for that feature and its associated cloud infrastructure operator; the actual recipient is the provider we have selected for the period, and when the categories of recipients change, we first update the disclosures in this section and only then switch over.

Only the Necessary Text Snippet Is Sent

When you look up a word or translate a sentence, VocaX sends only that specific text snippet.

Training Data Isolation

VocaX does not use your input or output to train, test or fine-tune general artificial intelligence models. The AI vendors that receive text in order to complete a request process that data under their own applicable terms of service and privacy policies, and their retention periods may differ by vendor and by service region. Whether a third party deletes the data after completing the processing, and for how long it keeps it, depends on the terms it publishes itself; we make no commitment about this on your behalf, and we cannot confirm it for them. For the vendors we have selected in order to deliver the features, we perform, under applicable law, the corresponding obligations of selection and management, of notification and of transfer arrangements; those obligations are not reduced or exempted by the vendors’ own documentation.

Notice About Sensitive Information

We screen third-party providers for compliance, but the text needed to complete the feature is handled by them. Please do not submit highly sensitive information such as credit card numbers, passwords or health records into the AI input box when the feature you are using does not need it.

De-identification

Before a request is handed to a third-party AI provider, VocaX assembles only the content necessary to complete that request: the only things submitted along with the request are the sign-in identity code mentioned above, the installation code of this device of yours and your network address — the network address is used only for the rate-limiting and abuse-prevention decision for that request; the request contains neither your name nor your email address, nor any other learning content from your account. The third-party AI provider still sees the text content needed to complete the feature. We do not keep the request body, and we do not use it for training or analysis.

Content Filtering and Child Protection

While we employ rigorous prompt engineering to restrict the generation of inappropriate content, there remains a very low probability that generative AI may produce errors, bias, or text unsuitable for minors. Such content does not represent the stance of VocaX. We recommend that users under the age of 18 use these AI features under the guidance of a guardian.

External Links and Risks

These third-party providers have their own independent privacy policies; once your data has been given to such a provider, that provider’s own processing is also governed by its privacy policy. Where a third-party outage, a security incident or a policy change causes abnormal situations, each party’s responsibility is determined according to the specific facts and within the scope that applicable law allows.

CloudKit Data Syncing

After you sign in, your core learning data is stored in your iCloud private database using Apple’s CloudKit service; when you are not signed in, this data is stored on your current device. The core learning data kept for long-term storage exists in your iCloud private database and on your own device; its encryption and storage security measures are provided by Apple under its own terms, and we make no commitment on Apple’s behalf and cannot confirm them for Apple. To be plain about who reads it: on your device this app reads and writes, through the authorized interfaces Apple provides, the records necessary to provide the features; we cannot read those private records directly.

How VocaX Protects Personal Data

VocaX believes that strong privacy protection has to rest on excellent security. We use administrative, technical and physical safeguards to protect your personal data, while taking into account the nature of the personal data, the processing it undergoes and the threats it faces. We keep improving these safeguards according to the nature of the personal data, the way it is processed and the risks involved.

The security measures we implement include:

Children and Personal Data

VocaX is intended for users who meet the minimum age required by the law of their location and by the platform rules, generally thirteen years of age or above. We do not ask users to submit a date of birth or identity documents. A guardian may use the device and account management features Apple provides; where the law requires guardian consent, notification or other protective measures for the personal information of a minor, we act in accordance with applicable law.

Relies on Apple Family Sharing

Apple’s Family Sharing mechanism may allow a guardian to create a child Apple Account, but the existence of that account does not by itself change the minimum age of use set out in these Terms of Service. VocaX does not collect dates of birth or age proof inside the app and does not, on that basis, presume that someone below the minimum age has become eligible to use it.

Managed Account for Educational Institution

Educational institutions that join “Apple School Manager” can create Managed Apple Accounts for students. The privacy settings and parental consent process for these accounts are managed jointly by the educational institution and Apple, and we follow the same data protection principles.

We do not proactively identify or distinguish between child and adult accounts. All user data is protected according to the same standards described in this Privacy Policy. If parents need to manage their child’s account data or exercise privacy rights, they can do so by signing into the child’s account via the in-app Settings page, or manage it through the parental control features of “Apple Family Sharing.”

Transfer of Personal Data Between Countries

When you use services that cross regions, part of the text needed to complete your request, together with the pseudonymous identifiers and security records used for abuse prevention, may be transmitted to the selected service provider and processed in its processing region; Apple’s sign-in, transactions and iCloud synchronization run on Apple’s infrastructure and under Apple’s policies. Under applicable law we distinguish processing as a trusted processor from provision to an independent recipient, and we perform the corresponding obligations to notify the categories of recipients, to safeguard cross-border transfers and to arrange for the exercise of rights; the actual categories of recipients and the processing regions are as stated in the corresponding disclosures in this section and above, and the channel for exercising your rights is given under “Contact Us”. Within the range that is feasible, we give priority to the principles of de-identification and data minimization.

When you use the iCloud features, Apple may process the related data in different countries or regions, according to your account region and the service arrangements that apply to it. For cross-border processing in which we and the service providers we entrust actually take part, we state the purposes of processing, the categories of recipients, the transfer safeguards and how personal rights may be exercised in accordance with applicable law; where the law requires separate consent or another statutory condition, we handle it accordingly.

Data Retention

VocaX keeps personal data only as long as is needed to complete the purpose for which it was collected, and judges this category by category: the learning records and preferences on the device are kept until you delete them or delete your account, subject to the state of the device; the records in your iCloud private database after you sign in are managed by your own account operations together with the synchronization and backup lifecycle of Apple; we keep only these few categories of entries — usage counters, forensic entries for anomalies, device credentials and subscription transaction bindings — and the cleanup conditions of each category and the grounds for continuing to keep it are each determined according to the functional purpose that category corresponds to; we do not treat the nominal window of a cleanup cycle as a commitment to the point in time at which physical deletion is complete; periods that the law requires to be retained, or that are needed for handling disputes, apply as the law provides.

You can delete the records you manage on this device inside the App, and start deletion of the data within the applicable scope through account cancellation. For records that have entered your iCloud private database, how deletion propagates and whether older copies remain in device or system backups may be affected by Apple’s synchronization and retention mechanisms; for the online security records and support communications we actually hold, retention and deletion periods are determined by the “Data Retention” section and applicable law.

Other than the data necessary to provide online lookup, the AI features, usage-allowance management, security and abuse prevention and technical support, and disclosed in this Policy, we do not retain your complete learning content in ordinary online storage. Online systems may keep pseudonymous usage, security and transaction-related records; their categories, purposes, retention rules and deletion exceptions are as stated in the corresponding sections of this Policy.

Local Storage Technology

Similar to how websites use cookies, VocaX uses on-device local storage technologies (such as preferences, learning progress, and cache files) to enable core functionality.

Essential Local Storage

To track your vocabulary mastery and save your preferences (such as theme, sound effects), we must write this data locally on your device (including core algorithm model parameters). Clearing this data will prevent the app from functioning properly or cause progress loss.

There is one further channel that does not belong to this app: iCloud Backup may keep a copy of this app’s device data under your account. That backup is managed by Apple and controlled by you; you can view it, pause it or delete it at any time in the system settings, and we do not read your content through it.

Performance Cache

To save your mobile data and speed up loading, we temporarily cache downloaded audio files and images in the app sandbox on your device. The system may clean up this cache automatically when storage space runs low, and reinstalling the app also clears it.

Our Companywide Commitment to Your Privacy

We communicate privacy and information-security requirements to the personnel involved in product and user-support work, and we apply access controls and internal management measures appropriate to their job responsibilities.

Changes to Privacy Policy

We may update this Privacy Policy from time to time. The updated policy will be published inside the app with its update date marked. Only within the scope that applicable law allows will your continued use of the app after an update takes effect count as acceptance of that update; where applicable law requires consent to be obtained separately or gives you a right of withdrawal, we act in accordance with that law. We suggest that you review this page regularly to see the latest policy.

Contact Us

If you have any questions about exercising your privacy rights, please contact us at support@vocax.app. Additionally, you have the right to lodge a complaint with the relevant regulatory authority.

We will reply as soon as possible after receiving your request.

Updated: October 14, 2026