Privacy Policy

This Privacy Policy describes how Indy Interactive Inc. ("Indy Interactive," "we," "us," or "our") collects, uses, and shares information when you use the PAL (Practice Active Listening) mobile application and related services (collectively, the "App" or "Service").

By using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use the App.

1. Who We Are

Data Controller: Indy Interactive Inc.
Contact: support@activepalapp.com
Mailing Address: 2093 Philadelphia Pike #9979, Claymont, DE 19703

If you are in the European Economic Area (EEA), United Kingdom, or Switzerland, you may also contact us regarding your data protection rights at the email above.

2. Information We Collect

2.1 Voice and Audio Data

The core function of the App requires you to listen to an audio passage and then speak back what you recall. To provide this function:

• When you record a response, your device captures audio through your microphone.
• Speech-to-text transcription is performed on your device. Your spoken audio is converted to text locally on your device.
• You are shown the resulting transcript and may review and edit it before submitting.
• Only the resulting text transcript, not the underlying audio recording, is transmitted to our servers for scoring and feedback.
• We do not store your raw voice audio on our servers, and we do not use your voice to create a voiceprint, identify you biometrically, or for any purpose other than generating the transcript on your device.

2.2 Practice and Performance Data

To provide stats, streaks, and feedback, we collect and store:

• Transcribed text of your recalled responses
• Accuracy scores and per-session analysis (concepts captured/missed)
• Difficulty levels attempted, completion data, and timestamps
• Streak counts, personal bests, and historical performance

2.3 Account Information

When you create an account, we collect:

• Email address (if you register with email and password)
• Your name, which you supply at signup or which we receive from Sign in with Apple or Sign in with Google. Apple provides your name only on your first sign-in and never again, so we store it at that point if you choose to share it.
• Apple ID identifier (if you use Sign in with Apple). If you choose Apple's "Hide My Email" feature, we receive a private relay email address rather than your real email.
• Google account identifier and email (if you use Sign in with Google)
• An encrypted/hashed password (if you register with a password; we never store passwords in plain text)
• A username, if you choose to set one

We use a third-party authentication library (better-auth) to manage sign-in and account security.

2.4 Subscription and Purchase Data

We use RevenueCat and the Apple App Store / Google Play billing systems to manage subscriptions. We and RevenueCat may collect:

• Subscription status, plan, trial status, and renewal/expiration dates
• Anonymized purchase and transaction identifiers
• Platform-provided receipt data

We do not collect or store your full credit card number or payment account details. Payments are processed by Apple and Google, not by us.

2.5 Advertising Data

The free tier of the App displays rewarded video ads (which you choose to watch in exchange for extra practice challenges). We use Google AdMob to serve these ads. AdMob and its partners may collect:

• Advertising identifiers (Apple's IDFA, Google's Advertising ID / AAID)
• Device information (model, operating system, language, general location inferred from IP)
• Ad interaction data (impressions, clicks, completions)

Whether an ad is personalized is your choice. We request personalized ads only where you have granted Google's consent form and, on iOS, Apple's App Tracking Transparency prompt. If you decline either one, or your answer cannot be established, every request the App makes is non-personalized. You can change your answer at any time (see Section 6). Paid subscribers do not see ads, and the advertising SDK is not initialized for subscribers.

2.6 Device and Usage Data

We automatically collect certain technical information:

• Device type, operating system version, and app version
• IP address (used to infer general/approximate location, not precise GPS location)
• Crash reports, diagnostic logs, and performance data
• General usage analytics (features used, session frequency), collected via PostHog

When you sign in, our authentication system records the IP address and browser/device user agent of that login alongside the session, which helps us detect suspicious account access. These are stored with the login session and are deleted shortly after the session expires.

2.7 Push Notifications

If you allow notifications, we collect and store, linked to your account:

• A push notification token issued by your device, used to address messages to it
• The platform the token belongs to (iOS or Android)
• Your device's time zone, so reminders arrive at a sensible local hour rather than in the middle of your night. This is a coarse regional signal, not precise location.

We send four kinds of notification, and each can be turned off independently in the App under Profile → Preferences → Notification types:

• Daily practice reminder, at a time inside the morning/afternoon/evening window you pick
• Streak expiration alert, in the evening when a streak is about to lapse
• Hearts refill notice, a late-morning reminder that your free daily practice sessions have reset
• Milestone celebration, when you reach a streak milestone

You can also turn off all notifications for PAL in your device settings. Doing so stops delivery immediately; deleting your account deletes the stored tokens.

2.8 Information We Do Not Collect

We do not knowingly collect precise GPS location, contacts, photos, or health data.

3. How We Use Your Information

We use your information to:

• Provide the core listening-practice function, including transcription, scoring, and feedback
• Maintain your account, streaks, statistics, and practice history
• Process and manage subscriptions
• Serve and cap rewarded advertisements in the free tier
• Improve the App, develop new features, and analyze aggregate usage
• Detect, prevent, and address fraud, abuse, and technical issues
• Communicate with you about your account, updates, and support requests
• Comply with legal obligations

We process your transcribed text using third-party AI services (see Section 4) solely to generate accuracy scores and feedback.

4. How We Share Your Information

We do not sell your personal information. We share information only as described below:

We may also disclose information: (a) to comply with law, legal process, or government requests; (b) to enforce our Terms of Service; (c) to protect the rights, property, or safety of Indy Interactive, our users, or others; and (d) in connection with a merger, acquisition, or sale of assets, in which case we will notify you of any change in ownership or use of your personal information.

5. AI Processing

Your transcribed text responses are processed by OpenAI, a third-party large language model provider, to evaluate accuracy and generate feedback. This processing analyzes the meaning of your text against the source passage. We send only the text necessary for scoring. We never send your voice audio, which never leaves your device.

We do not use your responses to train AI models. Under OpenAI's API terms, data submitted through the API is not used to train OpenAI's models; OpenAI may retain it for a limited period (currently up to 30 days) to monitor for abuse, after which it is deleted. If we ever add or change AI providers, we will update this policy before doing so.

5.1 Your Consent, and How to Withdraw It

Because this sends your text to a third party, the App asks for your explicit consent before it scores anything. You will see a consent screen describing exactly what is sent, and no response of yours is transmitted for scoring until you accept it. Declining is a valid choice; it simply means sessions cannot be scored.

You can review or withdraw that consent at any time in the App under Profile → About → "AI Scoring & Your Data". Withdrawing takes effect immediately and stops all further AI processing of your responses. Scores already generated remain in your practice history until you delete them or delete your account.

6. App Tracking Transparency (iOS) and Advertising Choices

On iOS, no tracking across apps or websites happens unless you have granted permission through Apple's App Tracking Transparency (ATT) prompt. The App does not show that prompt at launch. It appears the first time you choose to watch a rewarded ad, so you are asked in the one context where the answer actually matters, and only free-tier users are ever asked at all.

Your answer decides whether the ads are personalized. We ask for ATT permission because Google's advertising software accesses your device's advertising identifier when it has been granted. If you grant Google's consent form and, on iOS, the ATT prompt, we request personalized ads. If you decline either one, or your answer cannot be established, we request non-personalized ads. Either way you see the same number of ads and earn the same rewards, and your recordings, transcripts, and scores are never used for advertising. Paid subscribers see no ads, and the advertising SDK is never initialized for them.

You can review or withdraw your advertising consent at any time:

• In the App: Profile → About → "Ad Privacy Settings" reopens Google's consent form. This row appears for free-tier users in regions where Google provides such a form; withdrawing takes effect on the next ad you watch.
• iOS: Settings → Privacy & Security → Tracking, and Settings → Privacy → Apple Advertising
• Android: Settings → Google → Ads (reset or delete your Advertising ID, or opt out of ad personalization)

For more on AdMob's data practices, see Google's Privacy Policy at https://policies.google.com/privacy.

7. Your Privacy Rights

7.1 All Users

You may access, update, or delete your account and associated data at any time in the App under Profile → Account → "Delete Account", or by contacting us at support@activepalapp.com. When you delete your account, we delete or de-identify your personal data, except where retention is required by law or for legitimate business purposes (e.g., transaction records).

One exception is worth knowing before you use it: if you published a custom passage, that passage and its audio are kept after your account is deleted, because other people's practice history may reference it. Your authorship is removed, so it is no longer linked to you. Passages you kept private are deleted with the rest of your account, unless someone else practised the passage while it was published; in that case it is kept, with your authorship removed, for the same reason.

Deleting your account does not cancel a paid subscription. Cancel that in your App Store or Google Play account settings.

7.2 EEA / UK / Switzerland (GDPR)

If you are in these regions, you have the right to: access your data; rectify inaccurate data; erase your data; restrict or object to processing; data portability; and withdraw consent. You also have the right to lodge a complaint with your local supervisory authority.

Erasure and withdrawal of AI-processing consent are both available directly in the App (Sections 5.1 and 7.1). For access, correction, or a portable copy of your data, email us at support@activepalapp.com from the address on your account; we handle these requests manually and will respond within the time the law allows. There is no self-service export in the App.

Legal bases for processing: We process your data to perform our contract with you (providing the Service), based on your consent (e.g., personalized ads, microphone access), to comply with legal obligations, and for our legitimate interests (e.g., securing and improving the Service).

7.3 California (CCPA/CPRA)

California residents have the right to know what personal information we collect, to request deletion, to correct inaccurate information, and to opt out of "sale" or "sharing" of personal information. We do not sell your personal information. Where you have granted advertising permission, serving personalized ads through Google AdMob may amount to "sharing" for cross-context behavioral advertising under the CPRA. That happens only if you opt in, and you can withdraw at any time under Profile → About → "Ad Privacy Settings" or through your device's tracking and advertising settings, all described in Section 6. If you have not granted permission, or you withdraw it, the advertising you see is non-personalized. We do not discriminate against you for exercising these rights.

7.4 Other Jurisdictions

Residents of other regions with privacy laws (e.g., Canada's PIPEDA, Australia's Privacy Act) may have similar rights. Contact us to exercise them.

8. Data Retention

We retain your account and practice data for as long as your account is active. Your transcripts, scores, and feedback are kept for the life of your account so your history and statistics stay intact; they do not expire on their own. After account deletion, we remove or de-identify personal data within 30 days, except where longer retention is legally required (e.g., financial/transaction records), necessary to resolve disputes and enforce agreements, or covered by the published-passage exception in Section 7.1. Crash and aggregate analytics data may be retained in de-identified form.

We do not retain raw voice audio on our servers (see Section 2.1).

Reports you file (see our Terms, Section 8) are stored as a record of which account reported which passage or practice session, the reason chosen, and any detail you typed. We keep them so that repeated reports about the same content can be recognised and acted on, and so there is a record behind any removal. A report is deleted along with the account that filed it.

Our analytics provider (PostHog) is a specific case of that de-identified retention. The analytics record of your use is keyed to a random account identifier and never contains your email address or name, so once your account is deleted that identifier no longer refers to any account we hold, and the record cannot be linked back to you. Deleting your account does not itself erase those historical usage events, and the deletion is recorded as an anonymous event so that it does not recreate an analytics profile for the account being removed.

9. Data Security

We use technical and organizational measures to protect your information, including encryption in transit (TLS), encryption at rest, hashed passwords, and access controls. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

10. International Data Transfers

We and our service providers may process and store your information in the United States and other countries that may have different data protection laws than your country. Where required, we rely on appropriate safeguards (such as Standard Contractual Clauses) for international transfers of personal data out of the EEA, UK, or Switzerland.

11. Children's Privacy

The App is intended for users 13 years of age and older (or the minimum digital-consent age in your jurisdiction, whichever is higher). We do not knowingly collect personal information from children under 13. If we learn we have collected such information, we will delete it. If you believe a child has provided us personal information, contact us at support@activepalapp.com.

12. Third-Party Links and Services

The App relies on third-party services (including Apple, Google, OpenAI, RevenueCat, PostHog, and Expo). Their handling of your data is governed by their own privacy policies:

• Apple: https://www.apple.com/legal/privacy/
• Google: https://policies.google.com/privacy
• OpenAI: https://openai.com/policies/privacy-policy
• RevenueCat: https://www.revenuecat.com/privacy
• PostHog: https://posthog.com/privacy
• Expo: https://expo.dev/privacy

13. Our Website

This policy covers the App. Our website at activepalapp.com is a plain informational site: it sets no cookies, runs no analytics or advertising scripts, and has no sign-in, forms, or comment fields. We do not build a profile of visitors to it. Our hosting provider (Cloudflare) processes standard request data such as IP address and user agent to serve pages and protect against abuse. Because we set no cookies and do no tracking on the site, there is no cookie banner and nothing to opt out of.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version in the App and update the "Last Updated" date. For material changes, we will provide more prominent notice (e.g., in-app notification). Your continued use of the App after changes take effect constitutes acceptance.

15. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Indy Interactive Inc.
support@activepalapp.com
2093 Philadelphia Pike #9979
Claymont, DE 19703