VerbaLearn AI – Privacy Policy

Effective Date: October 6, 2025
Company: RMonaghan Venture Studios (“we,” “us,” “our”)
Address: 4500 Center Ave, Apt 1021 A, Pittsburgh, PA 15213, USA
Support: rdmrules101@gmail.com

Entity status: RMonaghan Venture Studios is currently a sole proprietorship. We’re in the process of registering as an LLC in Pennsylvania. Upon completion, we’ll update this policy to reflect the new entity name and governance. Any material changes will be communicated in-app and on our website.

1) What VerbaLearn Is

VerbaLearn is a study workspace: handwritten notes and drawing, PDF markup, flashcards with spaced repetition, transcription and text-to-speech, computer vision/problem solving, document-to-flashcards, and an AI study buddy. Sign-in is available via Apple, Google, or email; premium features are available through auto-renewing subscriptions.

2) Plain-English Summary

  • No “tracking” for advertising. No data sold. No third-party ads.

  • Your study content (notes, drawings, PDFs, images, audio, transcriptions, flashcards) belongs to you. We process it only to provide features you choose.

  • You can export, delete content, and delete your account at any time.

  • We use reputable processors (Apple, Firebase, RevenueCat, Cloudflare, OpenAI/AI vendor, ElevenLabs, Sentry, Mixpanel) with data minimization and strict access controls.

3) Data We Collect

A. You Provide

  • Account: email (or Apple/Google identifier), display name (optional), profile image (optional).

  • Study content: notes, drawings, PDFs, imported images, audio recordings, transcripts, flashcards/decks, and optional tags/metadata.

  • Support messages you send to us.

B. Collected Automatically

  • Device & usage: app/OS version, device model, locale/region (non-precise), feature screens/taps, performance.

  • Diagnostics: crash logs/error traces.

  • Purchase state: subscription entitlement status (via Apple & RevenueCat).

C. From Connected Services (Processors)

  • Sign-In: Apple/Google provide an ID and (optionally) email/name to authenticate you.

  • Subscriptions: RevenueCat returns entitlements (e.g., premium_access).

  • App integrity: Firebase App Check validates app requests.

  • AI features (on demand only):

    • TTS via ElevenLabs (we send the text you request to convert).

    • Transcription (we send audio you choose to transcribe).

    • Vision/flashcard generation/chat via our AI provider (we send only the prompt and the specific content you selected).

4) How We Use Data

  • Deliver core features, sync/backup (if enabled), and persist your content.

  • Authenticate and secure the app (App Check/DeviceCheck/App Attest).

  • Process purchases & manage entitlements (RevenueCat + Apple).

  • Improve reliability and UX through product analytics and crash diagnostics.

  • Provide support and respond to your requests.

5) No Tracking & No Third-Party Ads

  • We do not track you across other companies’ apps or websites.

  • No third-party advertising SDKs.

  • Analytics are for product improvement only (not ad profiling) and are pseudonymous.

6) Processors/Sub-Processors (Function-Scoped)

  • Apple (Sign in with Apple, App Store purchases, DeviceCheck/App Attest, iCloud if you enable it)

  • Google Firebase (App Check; may be used for auth/session and storage with production rules)

  • RevenueCat (subscriptions & entitlements)

  • Cloudflare Workers (our API gateway; validates App Check)

  • AI Providers (feature-specific, on demand only):

    • OpenAI / equivalent for chat, vision, flashcard generation

    • ElevenLabs for TTS

  • Sentry (crash/error diagnostics, pseudonymous)

  • Mixpanel (product analytics, pseudonymous; no ads)

We’ll maintain an up-to-date Sub-processors list on our website and update this policy if the list materially changes.

7) Storage & Retention

  • Local: Your content is saved on your device with SwiftData.

  • Cloud (if enabled): Content or derived data may be stored in our backend (Firebase/Cloudflare) under secure rules.

  • Retention:

    • Account & purchases while your account is active (and as required by law for receipts).

    • User content until you delete it or delete your account.

    • Diagnostics/usage only as long as necessary for stability and improvement.

8) Your Controls

  • Export notes, PDFs, audio, flashcards.

  • Delete content within the app.

  • Delete account in Settings → Account → Delete Account, or email us. We will remove or de-identify personal data in our systems and processors (subject to legal retention).

  • Analytics opt-down: You may reduce analytics in Settings (as available).

9) Children & Students

VerbaLearn is not directed to children under 13. If under the age required by your region, use only with parent/guardian consent or under a school agreement. Educators/parents provisioning accounts are responsible for consent and supervision.

10) Security

  • Transport encryption (HTTPS/TLS).

  • Application attestation (App Check/DeviceCheck/App Attest).

  • Least-privilege access to processors and key management practices.

  • Ongoing permission/key reviews and incident response procedures.

11) International Transfers

Data may be processed in the United States or other jurisdictions. Where required, we implement appropriate safeguards (e.g., Standard Contractual Clauses).

12) Your Rights

Depending on your location (e.g., GDPR/CCPA), you may have rights to access, correct, delete, or port your data, or restrict certain processing. Contact us to exercise these rights.

13) Changes to This Policy

We’ll update this policy as the app evolves and as we transition to an LLC. Material changes will be communicated in-app or by email.

14) Contact

RMonaghan Venture Studios
4500 Center Ave, Apt 1021 A, Pittsburgh, PA 15213, USA
rdmrules101@gmail.com