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)
• 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)

By default, the App requests non-personalized ads only, and we do not enable personalized advertising tracking unless you affirmatively consent (see Section 6 on App Tracking Transparency). 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

2.7 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 third-party large language model providers (which may include OpenAI, Anthropic, and other AI providers) 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 third-party AI models where the provider's terms allow us to opt out, and we configure our API usage to disable training on submitted data where that option is available. The specific provider used may change over time as we optimize the Service.

6. App Tracking Transparency (iOS) and Advertising Choices

On iOS, before any tracking across apps or websites occurs, we will present Apple's App Tracking Transparency (ATT) prompt and will only enable personalized advertising or cross-app tracking if you grant permission. If you decline, you will still see ads, but they will be non-personalized.

You can control ad personalization at any time:

• 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 through the App's settings, 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).

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.

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. Sharing for cross-context behavioral advertising occurs only if you opt in via the ATT prompt; you may opt out at any time as described in Section 6. 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. 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) or necessary to resolve disputes and enforce agreements. 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).

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, Anthropic, RevenueCat, and PostHog). 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
• Anthropic: https://www.anthropic.com/legal/privacy
• RevenueCat: https://www.revenuecat.com/privacy
• PostHog: https://posthog.com/privacy

13. 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.

14. 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