This page is not final and has not been reviewed by a lawyer. The highlighted parts are still to be decided.
Glossom privacy policy
Effective date: To decide set at publication
Last updated: To decide set at publication
This policy explains what Glossom collects when you use the Glossom app on iPhone and iPad, why, who helps us run it, how long we keep it, and what you can do about it. We have tried to write it in plain words. If anything is unclear, write to us at support@glossom.app.
The short version
- Your learning lives on your phone first. We keep a copy on our server so your progress can follow you to another device and is safe if you lose your phone.
- Feedback on your speaking and writing comes from Google's Gemini AI. Before your first answer goes to it, we ask you.
- When you ask for feedback on your speaking, your recording is sent for feedback and then deleted. We never store it.
- Your writing, and the feedback on your speaking and writing, are kept with your progress, so your journal is there on every device.
- We count how Glossom is used, anonymously, to make it better. You can turn this off in You.
- We don't show ads, we don't sell your data, and we don't track you across other companies' apps or websites.
- Glossom is for adults: you must be 18 or older.
- You can delete your account at any time from You in the app.
Who we are
Glossom is made by an independent developer based in the United States. In this policy "Glossom", "we" and "us" mean that developer. Lawyer whether this policy must name the developer. We decide how your personal data is used and are responsible for it. You can reach us at support@glossom.app.
Glossom is offered on the App Store outside the European Union (EU), the European Economic Area (EEA) and the United Kingdom (UK). It is not offered in those regions yet; the last section of this policy is kept for when it is.
Lawyer whether any country where Glossom is offered requires a postal address or phone number in this policy or on the support page (Apple asks for them on the support page "as local law may require").
What stays on your phone
Some things never leave your device:
- Your answers in the opening story about you: whether you have taken the exam before, what you find hard and what you want to achieve.
- Drafts you have not sent yet, such as writing you are still typing or a grammar lesson part-way through.
- Your appearance, sound and haptics settings, and small things like which hints you have already seen.
- What you type into the word search.
Your speaking recordings are kept on your phone only while the session is open, so you can play them back, and are deleted when it ends. A recording you send for feedback leaves your phone for that moment only, as described below.
Lessons, practice and any levels you have downloaded work without a connection. Glossom only needs the internet for AI feedback, signing in, keeping your devices in sync, and downloading audio, pictures and updates.
What we collect, and why
Your account
The first time Glossom has a connection, it creates an account for you on our server, even before you sign in. We call it a guest account. It lets your progress be kept safely and lets you start the free trial. For it we keep:
- an account id that we create;
- a random id for each device you use, made by the app, with the device's platform (iPhone or iPad) and the app version;
- a record that your copy of Glossom is genuine, made with Apple's App Attest (a key and a counter). This stops scripts from creating endless accounts to use the AI feedback;
- sign-in tokens, so the app stays signed in. On our server we keep only a scrambled (hashed) form of the long-lived token.
If you sign in, which you can do with Apple, Google or a code sent to your email, we also keep:
- the id Apple or Google gives us for you, and the email address they share with us (with Apple, this can be a private relay address);
- or, for the email code, your email address.
We do not ask for your name. We use your email address only to let you sign in, and to answer you if you write to us. We do not send you marketing emails.
Why: to give you an account, keep you signed in, let you use Glossom on more than one device, and protect the service from abuse.
Your progress
Glossom saves your progress as a list of small records ("learned this word on this day", "finished this reading set"). They are made on your phone and a copy is sent to our server, so your progress follows you when you sign in on another device. This includes:
- what you studied and when: lessons, sessions, practice answers, skips and how long timed tasks took;
- the choices you make: your exam, your target scores, your daily time and study days, your starting levels, your level test results, the translation language you picked and the time of day you like to study;
- your Challenges stars and the cards saved to "Worth another look";
- your answers to questions, including what you typed;
- your writing and the feedback on it, and the feedback on your speaking (see below).
Why: to run Glossom for you: to work out your levels and your daily path, to keep your progress safe, and to bring it to your other devices.
Speaking feedback
When you finish a spoken answer and ask for feedback, the app sends the recording to our server (or, if our server is down, to our backup service on Cloudflare, which works the same way). Our server keeps it in memory only, sends it to Google's Gemini AI for feedback (see "What the AI sees"), and deletes it once the answer comes back. We never write it to disk, put it in our logs, or store it with your account.
The feedback that comes back includes a written transcript of what you said, quotes from it, corrections and an improved version of your answer. That feedback, with its quotes of your words, is saved with your progress and kept with your account, so your journal shows it on every device. Your recording never is.
Writing feedback
When you ask for feedback on your writing, the app sends your text to our server, which sends it to Google's Gemini AI in the same way. Your text and the feedback are saved with your progress and kept with your account.
Level tests
If you take the speaking or writing level test, your answers are sent for a rating in the same way: recordings are not kept, and the written answers, transcripts and ratings are saved with your progress.
What the AI sees
Glossom's feedback is written by Google's Gemini AI model. We send it the task (taken from Glossom's own lessons) and your answer: your recording or your text. We do not send your name, your email address or your account id.
Our main route goes through OpenRouter, an AI gateway, with zero data retention: OpenRouter keeps no copy of your request and sends it only to Google's Vertex AI service, which keeps no prompts or answers and does not train on them.
When our main server is down, the app uses our backup service, which sends the request to Google directly. To confirm the backup route's Google service. On Google's paid Gemini API, Google keeps requests for up to 55 days only to detect abuse, and does not use them to improve its products; this policy must then say so here. On Vertex AI with Google's abuse-monitoring exception nothing is kept, and this note goes.
To give the same answer if a request is repeated, our server keeps each AI answer for 24 hours and then deletes it.
We ask first. Before your first spoken or written answer goes to the AI (for the speaking and writing level tests, this can be while you set up Glossom), the app asks your permission on a screen that names Google, says what is sent and why. If you say no, you can still use everything else in Glossom, and you set your starting levels in speaking and writing yourself instead of taking those level tests. To confirm where in You the answer can be changed later, once the screen is built.
AI feedback can be wrong. It is there to help you practise; it is not an exam score. See our terms.
Why: to give you the feedback you asked for, and the ratings that suggest your starting level.
How much AI feedback you use
Speaking and writing feedback has a daily limit. To count it, we keep how many you have used on each day, using the time zone your phone sends us so your day starts at your midnight.
Why: to keep Glossom affordable and fair for everyone.
Your subscription
Subscriptions are bought through Apple. Apple takes the payment; we never see your card details. RevenueCat, a subscription service, tells us whether your account has a trial or a subscription, which plan, when it renews or ends, and which store it came from. We link that to your Glossom account so your subscription works on all your devices. RevenueCat also shows us totals, such as how many people start a trial or subscribe.
Why: to give you what you paid for, and to see how the subscription is doing.
Keeping Glossom safe and working
When the app talks to our server, we record technical details of each request: what was asked, the result, how long it took, your device's platform and app version, and your account id. We never log your sign-in tokens, your recordings or your writing. We also keep a short log of events such as signing in, finishing a feedback request or reaching the daily limit, with your account id. We do not share this log with anyone.
Like any service on the internet, our providers see your device's IP address when it connects. Our server holds it in memory for up to an hour to limit how many sign-in codes one connection can ask for. We do not use it to find where you are.
Why: to keep the service running, find and fix problems, and stop abuse.
Crash reports
If you agreed to share anonymous usage and crash reports (see below), when the app crashes or hits an error it sends a report to Sentry, our crash-reporting service: what went wrong in the code, the app version, and your device model and system version. Before a report leaves your phone, the app removes anything you wrote or said, and reports never include screenshots or your account. Our server and our backup AI service send their own error reports to Sentry the same way.
Why: to fix crashes.
Anonymous usage
To learn which parts of Glossom help people and which do not, the app sends anonymous usage events to PostHog, our product analytics service, on its EU cloud (Frankfurt, Germany). An event says what happened in the app, for example that a session was started or finished or that a screen was opened, with the app version and the kind of device. Events carry a random id for this installation of the app, never your account id, your name or your email address, and never what you write or say. PostHog does not keep your IP address, we do not use it to find where you are, and nothing is used for advertising or shared with advertisers.
This is off until you agree. Once, during the first setup, the app asks whether you want to share anonymous usage and crash reports, and nothing is sent unless you say yes. Until you answer, the app keeps a short list of the setup screens you have passed, on your phone only; it is sent only if you say yes, and deleted if you say no. You can change your answer at any time with Share anonymous usage in You; turned off, the app sends nothing more to PostHog or Sentry.
Why: to understand how Glossom is used and make it better.
Improving Glossom
After launch, we may use learners' answers to tune Glossom: for example, how hard a question or a level test is, or how long a timer in the word games should be. We do this anonymously and in aggregate, looking at many learners' answers together, never at you as a person. We never sell your answers and never use them for advertising.
Why: to make the level tests and the games fair and accurate for everyone.
When you contact us
If you write to us at support@glossom.app, we keep your message and our reply to help you. Our mailbox is hosted by Zoho (see "Who helps us run Glossom"). To decide how long support emails are kept.
Who helps us run Glossom
We use a few companies to run Glossom. They process your data only to provide their service to us.
| Provider | What they do for Glossom | What they handle |
|---|---|---|
| Railway | Hosts our server and its database, in its EU West region (Amsterdam, the Netherlands). | Everything our server keeps: your account, your synced progress, request logs. |
| Cloudflare | Runs our domain, protects and delivers traffic to our server, stores and delivers lessons' audio and pictures, stores our encrypted database backups, and runs our backup AI service. | Your IP address and requests as they pass through; our backups; for the backup AI service, the same as Google below. |
| OpenRouter | Our AI gateway: passes each feedback request to Google's Gemini model and returns its answer, keeping no copy (zero data retention). | The task and your answer (recording or text), without your name, email or account id. |
| Google (Vertex AI) | Runs the Gemini model that writes the feedback, on our main route, keeping no prompts or answers. If Gemini fails, our server may use another model: To decide name the fallback models' providers once chosen; any other provider is also named on the app's permission screen before it is used. | As OpenRouter. |
| Runs the Gemini model for our backup route, used only when our main route is down, which calls Google directly. Also provides Sign in with Google, if you use it. | For feedback: the task and your answer. For sign-in: your Google account id and email address. | |
| Apple | Sign in with Apple, App Attest (checks the app is genuine), and App Store payments. | For sign-in: your Apple id for Glossom and email (or relay address). Payments are Apple's own; see Apple's privacy policy. |
| RevenueCat | Keeps track of your subscription across devices. | Your Glossom account id, your purchase and subscription history, and your phone's language setting and currency. No location and no advertising identifier. |
| Sentry | Crash and error reports, on its EU cloud (Frankfurt, Germany), with IP addresses not stored. | Crash details, device model and system version, app version; never your words or recordings. |
| PostHog | Anonymous usage analytics, on its EU cloud (Frankfurt, Germany). You can turn it off in You. | Usage events with a random installation id, the app version and the kind of device; never your account id, your words or your IP address. |
| Resend | Sends the sign-in codes by email. | Your email address and the code. |
| Zoho | Hosts our support mailbox, support@glossom.app, in its data centres in the United States. | Your emails to us, our replies and your email address. |
| Expo | Delivers app updates when you open the app. | To confirm what Expo's update service receives, for example your IP address, the app version and an installation id. |
Each of these providers is bound by its terms with us to protect your data at least as well as this policy describes. To confirm each provider's data processing terms. Lawyer whether the providers should be named, as here, or described by category.
We do not sell your personal data, and we do not share it with advertisers or data brokers.
We may disclose data if the law requires it, or to protect the rights and safety of our users or of Glossom. Lawyer wording.
Where your data is stored
Our server and database are in the Netherlands (Amsterdam), and Sentry and PostHog keep crash reports and anonymous usage events in Germany (Frankfurt). Most of our other providers, among them OpenRouter, Google, RevenueCat, Resend and Zoho, are based in, or process data in, the United States, and some in other countries too. To confirm each provider's locations. Wherever your data is, we protect it as this policy describes.
How long we keep it
| Data | How long |
|---|---|
| Your speaking recordings | On our server: only while your feedback request is answered, then deleted. On your phone: until the session ends. |
| AI answers kept for repeated requests | 24 hours. |
| Your account and progress | Until you delete your account. |
| A guest account that is never signed in | Deleted, with its progress, after twelve months without use. |
| Sign-in codes | Ten minutes to use; removed within about an hour after they expire. |
| Sign-in tokens | A long-lived token lasts a year from its last use; used tokens are removed a day later. |
| Our encrypted database backups | 30 days. To confirm Railway's own backups, per our plan. |
| Request logs | Up to 7 days. |
| The event log (sign-ins, feedback completed) | Until you delete your account. To decide a shorter limit. |
| Crash reports | 30 days. |
| Anonymous usage events | To confirm up to one year, PostHog's retention on its free plan. They carry no account id, so they are not deleted with your account. |
| Subscription records | Until you delete your account; we then also delete your record at RevenueCat. Apple keeps its own records under its own policies. |
| Support emails | To decide |
Your choices and rights
Delete your account. You can delete your account at any time from You in the app. You are signed out everywhere at once, the copy on your phone is removed straight away, and everything we keep about you on our server (your account, sign-in methods, progress, feedback and counts) is deleted within 24 hours. If you signed in with Apple, we also tell Apple to end Glossom's access to your Apple ID. We delete your record at RevenueCat too. Copies in our encrypted backups disappear as the backups expire, within 30 days. To confirm the retention of Railway's own database backups on our plan. Deleting your account does not cancel a subscription bought through Apple: cancel it in your Apple Account settings. If you cannot use the app, write to support@glossom.app from the email address you sign in with, and we will delete your account for you.
Turn off AI feedback. To confirm the setting in You that withdraws your permission for the AI, once built. Your answers then stay on your phone and in your account, and nothing more is sent to Google. You can still study everything else.
Turn off anonymous usage. Switch off Share anonymous usage in You, and the app sends nothing more to PostHog or Sentry.
Sign out. Signing out removes your data from that device after a last sync, so nothing is lost. Your account stays on our server.
Deleting the app removes your progress from your phone but not your account on our server. To remove that too, delete your account first.
Your rights. Depending on where you live, you may have the right to:
- see the personal data we hold about you and get a copy of it;
- have it corrected;
- have it deleted;
- object to or limit how we use it;
- withdraw consent you have given;
- complain to your local data protection authority.
To use any of these rights, write to support@glossom.app from the email address on your account, or tell us your account id (shown in To confirm where in You, once built). We answer within 30 days. If you ask for a copy of your data, we send it to you by email within 30 days.
Lawyer a short section on US state privacy rights (for example California), honouring requests whether or not a state's law applies yet, as the research suggests. The EU, EEA and UK rights are in the last section.
Glossom is for adults
Glossom is for people aged 18 or older, and it is rated 18+ on the App Store. The app does not ask your age. This is because Google, whose Gemini model writes Glossom's feedback, does not allow it to be used in apps for people under 18. We do not knowingly collect personal data from anyone under 18. If we learn that a user is under 18, we delete their account. If you think someone under 18 is using Glossom, write to us at support@glossom.app.
Lawyer whether the 18+ rating and these terms are enough to show that Glossom is neither directed to nor likely to be used by people under 18, as Google's terms require.
How we protect your data
- Connections to our server are encrypted.
- On your phone, your sign-in tokens are kept in the system's secure storage (the Keychain). On our server, long-lived tokens and sign-in codes are stored only in hashed form.
- Your recordings are never written to disk on our server.
- Our database backups are encrypted.
- Keys and passwords for our services are kept out of our code.
No system is perfectly secure, but we work to keep yours safe, and we will tell you if a breach affects your data as the law requires.
Changes to this policy
If we change this policy, we will update the date at the top and, for important changes, tell you in the app before they take effect.
Lawyer notice period.
Contact
Glossom
Email: support@glossom.app
When Glossom opens in the EU, EEA and UK
To decide Glossom is not offered in the European Union, the European Economic Area or the United Kingdom at launch. This section is kept for when it is: it is completed then, with the EU and UK representatives, and it does not apply until then. Take it off the published page until it does.
Who we are there
To decide the controller's postal address and phone number, which the EU and UK need (GDPR Article 13 and the App Store's EU trader details); a P.O. box or mailbox address with proof of the link is enough.
To decide the EU representative's name and contact details (GDPR Article 27), and the UK representative's (UK GDPR Article 27).
Our legal reasons for using your data
Lawyer confirm or rewrite. A first draft for the EEA and the UK:
- To provide the service you asked for (your contract with us): your account, your progress, sync, AI feedback, your subscription and the daily limit.
- Our legitimate interests, balanced against yours: keeping the service secure, checking that requests come from the genuine app, limiting abuse, request logs and crash reports.
- Legal obligations, where a law requires us to keep or share something.
- Your consent, where we ask for it: sending your answers to Google's AI, and anonymous usage analytics, which in the EU, EEA and UK the app turns on only if you say yes. You can withdraw it at any time.
Transfers out of the EU and UK
Our server and database are in the EU (Amsterdam). When your data goes to providers outside the EU or the UK, we rely on Lawyer the transfer safeguards for each provider, for example the European Commission's standard contractual clauses, the EU–US Data Privacy Framework and the UK's addendum or extension.
Your rights there
Besides the rights above, you can take your data with you to another service, and you can complain to the data protection authority where you live or work. Lawyer the full list under the GDPR and the UK GDPR.
Before Glossom opens there
To decide before opening: the representatives and contact details above; the analytics opt-in prompt; Google's paid services on every AI route (the Gemini API terms allow only paid services for users in the EEA, Switzerland and the UK); the trader details on the App Store; and the terms' section on withdrawal rights.