Privacy Policy

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliatemeans an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to my500, the software program provided by the Company.

• Company(referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to my500.

• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Country refers to: British Columbia, Canada

• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

• Personal Data(or "Personal Information") is any information that relates to an identified or identifiable individual.

  We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.

• Service refers to the Application or the Website or both.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Website refers to my500, accessible from my500.app.

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address

• The display name You choose, which appears as Your character in the stories We write for You

Learner Profile You Give Us

The Service personalises stories, so most of what We hold is what You tell Us in onboarding and in Your weekly journal. This may include:

• Your city or region, school or campus, and field of study, chosen from a list where possible

• Your pronouns, target language, and level

• Your interests and the tone You want Your stories to have

• The people You choose to add to Your story cast, such as a first name, how they relate to You, and their pronouns

• What You write in Your weekly journal about what is happening in Your life and what You want to practise

• Your time zone, used for streaks and review scheduling

Please only include details You are comfortable sharing. You do not need to give Us Your address, Your exact location, or details about other people that they would not want shared.

Learning and Content Data

• The stories generated for Your account, including episodes, scenes, and audio

• Your choices inside episodes, saved words, review answers, streaks, minutes practised, and achievements

• Reports and feedback You send Us, including the episode context attached to a content report

Purchase and Subscription Data

If You subscribe to Pro, We store Your subscription status linked to Your account, such as whether Pro is active, which plan it is, and when the current period ends. Purchases in the mobile app are processed by Apple. We do not receive or store Your card number, and We do not have access to Your payment method.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

This section describes Our website. On the website We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies We use include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

Where required by law, we use non-essential cookies (such as analytics, advertising, and remarketing cookies) only with Your consent. You can withdraw or change Your consent at any time using Our cookie preferences tool (if available) or through Your browser/device settings. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

  Type: Session Cookies

  Administered by: Us

  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of Our Privacy Policy.

Our Mobile App Does Not Use Cookies or Analytics SDKs

Our iOS app does not use cookies or web beacons, and it does not include any third-party analytics, advertising, or crash-reporting software development kit. We do not track You across other companies' apps or websites, We do not use the Advertising Identifier, and We do not share data with data brokers. Product analytics and error monitoring described below run on Our website only.

Activity in the app still reaches Us when the app calls Our servers to load or save Your learning progress, because that is how the Service works. Nothing on Your device collects it separately.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You:To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
• With other users: The Service has no social feed, no profiles visible to other learners, and no way to share Your stories with another learner. We do not publish Your Personal Data or the stories generated for You to other users.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

The Service Providers We Use

We keep this list short on purpose. Each company below processes data on Our behalf, under contract, and is required to protect it to the standard described in this Privacy Policy. We do not sell Your Personal Data.

• Supabase hosts Our database and handles account sign-in. It processes Your email address, account identifier, learner profile, learning data, and generated stories.

• OpenAI generates Your stories. See How We Use Artificial Intelligence below for exactly what is sent.

• Apple provides Sign in with Apple and processes in-app purchases. If You use Sign in with Apple, Apple lets You hide Your email address behind a private relay address, and We only receive what Apple passes to Us. Apple handles the payment itself.

• RevenueCat records whether Your subscription is active so Pro works across Your devices. It receives Your account identifier and Your App Store subscription status, not Your payment details.

• PostHog (product analytics) and Sentry (error monitoring) run on Our website only, not in Our iOS app.

How We Use Artificial Intelligence

The stories at the centre of the Service are written by an artificial intelligence language model provided by OpenAI. To write a story that is actually about You, We send OpenAI the details You gave Us, which typically include Your display name, Your city or campus, Your school and field of study, Your pronouns, Your interests, the story cast You added, what You wrote in Your weekly journal, and context from Your earlier episodes so the story stays continuous.

• We do not send Your email address, Your password, or Your payment information to OpenAI.

• We do not use Your Personal Data or Your generated stories to train Our own public models, and We instruct Our provider not to use data sent through its interface to train its models.

• Generated stories are stored against Your account and are private to You. They are deleted when You delete Your account.

• A language model can be wrong. If a story contains something inaccurate or upsetting, report it from inside the episode player and it reaches a queue We review.

Generating a story is something You choose to do, and using that feature is what sends this information to Our provider. If You would rather not have Your details processed this way, do not generate stories, and You can delete Your account at any time as described below.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

• Account Information

  • User Accounts: retained for the duration of your account relationship plus up to 24 months after account closure to handle any post-termination issues or resolve disputes.

• Customer Support Data

  • Support tickets and correspondence: up to 24 months from the date of ticket closure to resolve follow-up inquiries, track service quality, and defend against potential legal claims
  • Chat transcripts: up to 24 months for quality assurance and staff training purposes.

• Usage Data

  • Website analytics data (cookies, IP addresses, device identifiers): up to 24 months from the date of collection, which allows us to analyze trends while respecting privacy principles.
  • Application usage statistics: up to 24 months to understand feature adoption and service improvements.
  • Server logs (IP addresses, access times): up to 24 months for security monitoring and troubleshooting purposes.

Usage Data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.

We may retain Personal Data beyond the periods stated above for different reasons:

• Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
• Legal claims: Data is necessary to establish, exercise, or defend legal claims.
• Your explicit request: You ask Us to retain specific information.
• Technical limitations: Data exists in backup systems that are scheduled for routine deletion.

You may request information about how long We will retain Your Personal Data by contacting Us.

When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures:

• Deletion: Personal Data is removed from Our systems and no longer actively processed.
• Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance.
• Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to, and maintained on, computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

You can delete Your account yourself, from inside the Service. Go to Profile, then Account, then Delete account. This permanently deletes Your account together with Your learner profile, Your generated stories, Your saved words, and Your learning history. You do not need to email Us, open a support ticket, or wait for Our approval.

You may also update or amend Your information at any time by signing in to Your Account and visiting the account settings section, or contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so. In particular, records of a subscription purchase are held by Apple under its own terms, and We may keep the minimum transaction records We are required to keep for tax and accounting purposes. Deleting Your my500 account does not cancel an App Store subscription: cancel that in Your device settings under Your Apple Account and Subscriptions.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

The Service is intended for adults. Our Terms of Service require You to be at least 18 years old to use or register for the Service, and Our Service does not address children. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18, We take steps to delete that account and remove the information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By visiting this page on our website: https://my500.app/privacy