Privacy Policy
Polygloat — Last updated: August 2026
1. Who We Are
Polygloat is operated by Polygloat, a sole proprietorship
(eenmanszaak) based in Amsterdam, the Netherlands. We are
the data controller for the personal data described in
this policy.
For privacy questions or requests, contact us at:
legal@polygloat.com
2. What Data We Collect and Why
Account data
- Username — your unique identifier within the app,
publicly visible
- Display name — the name shown on your profile,
publicly visible
- Email address — used solely to send you a login
link. Not shown to other users.
- Profile avatar — an optional photo or image you
choose to upload
- Bio and social links — optional profile fields,
publicly visible
- Age confirmation — a timestamp recording that you
affirmed being 16 or older when you signed up — see
section 9.
Technical data
- Timezone — collected to schedule your spaced
repetition reviews at the correct local time. This
is a functional requirement of the app.
- Push notification token — if you grant permission
for push notifications, we store a device token
linked to your account so we can deliver reminders
and update notifications. You can disable push
notifications at any time in your device settings.
- Crash and performance diagnostics — if the app
crashes or runs slowly, a diagnostic report (device
model, OS version, app state, network timings) is
collected via Firebase so we can find and fix the
problem. Crash reports are tagged with your user ID
so we can investigate issues affecting your account.
Device permissions
When you upload content, the app may request access to:
- Camera — to record a video directly in the app
- Microphone — to capture audio during recording
- Photos — to select a video or image from your
library
These permissions are used only for the purpose you grant
them. We do not access these resources in the background.
Learning activity data
- Watch history — which videos you watched, when,
and for how long, including playback segments
- Vocabulary state — which words (lemmas) you have
encountered, and when they are scheduled for review
- Interactions — videos you liked, profiles you
visited, users you blocked, and reports you submitted
- Content you create — videos, transcripts, and
associated metadata if you upload to the platform
We collect learning activity data because it is the
core of the Polygloat service. Without it, personalised
video recommendations and spaced repetition scheduling
cannot function.
What we do not collect
We do not collect your real name, date of birth, phone
number, precise location, or payment information.
3. Legal Basis for Processing
We process your data on the following legal bases
under GDPR:
- Performance of a contract — account data,
timezone, and learning activity data are necessary
to provide the service you signed up for
- Legitimate interest — analysing usage patterns
and crash/performance diagnostics to improve the
app, enforcing these terms against abusive users,
and ensuring platform integrity
- Consent — push notifications and optional
device permissions (camera, microphone, photos)
4. Third-Party Services
We use the following third-party services (data
processors) to operate Polygloat. Each acts on our
instructions and under a data processing agreement.
- Supabase — hosts our database, authentication,
and storage services in the European Union (EU
region). Your account data and learning activity
data live here.
- Cloudflare R2 (US provider) — stores the video,
audio, and avatar files themselves.
- Google Firebase (US) — four narrowly scoped
services: Cloud Messaging delivers push
notifications (receives your device push token);
Analytics receives events about the upload flow,
with no personally identifying parameters;
Crashlytics receives crash reports tagged with
your user ID; Performance Monitoring receives
network and app timing measurements.
- Deepgram and Soniox (both US) — transcribe
the audio of uploaded videos (speech-to-text). An
uploaded video is personal data of the people in
it: it contains the uploader's face and voice, and
it is that voice which is sent for transcription.
Under Soniox's terms, Soniox retains uploaded media
until deletion is requested.
- ElevenLabs (US) — aligns uploaded audio with its
transcript (forced alignment) to produce word-level
subtitle timing.
- Google Translate (US) — translates sentence text
from content, including translations you request on
demand in the app.
- OpenAI and Anthropic (both US) — language
processing of content text: transcripts, dictionary
glosses, and example sentences. They never receive
private messages — Polygloat has none — and uploaded
content is public by design.
- Amazon Web Services (US) — generates reference
pronunciation audio (Polly text-to-speech) and
stores the generated files (S3). Only dictionary
text is involved — no personal data.
- SMTP2GO (New Zealand) — sends our transactional
email: login codes and launch-list emails. Receives
your email address.
- Google Cloud Run (US) — runs the
natural-language-processing services that analyse
content text.
We do not sell your data. We do not use your data
for advertising.
5. Data Retention
When you delete your account, we delete the following
within 30 days:
- Your username, display name, bio, and email address
- Your profile avatar and any social links on your
profile
- Your notification settings and push notification
tokens
- Your social connections (accounts you follow and
your followers), your activity feed, and your saved
collections
- Any video files you uploaded (unless you choose to
keep them anonymously — see the Content Upload
Policy)
Your learning activity data (watch history,
interactions, vocabulary state) and the transcriptions
and vocabulary analysis of videos you uploaded are
retained only in de-identified form: the identifiers
listed above are deleted, and what remains is held
under a random internal identifier that is not
connected to your name, email address, or any other
identity data. We commit to never attempting to
re-identify this data.
We retain this de-identified data under Articles
17(3)(d) and 89(1) GDPR (retention for statistical
purposes, with safeguards) and use it solely for
aggregate statistics and to improve the learning
system — for example, modelling how difficult words
are for learners in general. It is never used to make
decisions about you, and it is never shared in a form
that could identify anyone.
Some records are kept for legal reasons in restricted
form: proof that you accepted our terms, reports you
submitted, blocks you created, and moderation records.
These are kept only while a legal need exists — such
as demonstrating compliance or handling a dispute —
and we review at least every 24 months whether that
need still applies. Security logs (such as
authentication logs) are kept for up to 12 months.
6. Your Rights Under GDPR
As a user in the European Union you have the
following rights:
- Access — request a copy of the data we hold
about you
- Rectification — request correction of
inaccurate data
- Erasure — request deletion of your data
(right to be forgotten)
- Portability — receive your data in a
machine-readable format
- Objection — object to processing based on
legitimate interest
- Restriction — request that we limit how
we use your data
To exercise any of these rights, contact us at
legal@polygloat.com. We will respond within 30 days.
You also have the right to lodge a complaint with
the Dutch Data Protection Authority (Autoriteit
Persoonsgegevens) at autoriteitpersoonsgegevens.nl.
7. Data Security
We implement appropriate technical and organisational
measures to protect your personal data. Access to
personal data is restricted to systems that require
it to function.
8. International Transfers
Your data is primarily stored within the European
Union (Supabase, EU region). However, several of the
providers listed in section 4 are based in the United
States and process content or telemetry there. For
those transfers we rely on the safeguards required
by GDPR:
- Google, Amazon Web Services, Cloudflare, and
ElevenLabs are certified under the EU-U.S. Data
Privacy Framework.
- OpenAI, Anthropic, and Deepgram process data under
the EU Standard Contractual Clauses. Soniox
processes data under Standard Contractual Clauses
or another appropriate safeguard mechanism.
- SMTP2GO is based in New Zealand, which the European
Commission has formally recognised as providing
adequate data protection (an adequacy decision).
You can obtain a copy of the relevant safeguards by
contacting legal@polygloat.com.
9. Children
Polygloat is not directed at children under 16, and
you must be 16 or older to create an account (Terms of
Service, section 3). This requirement is stated next
to the signup button, and creating an account affirms
it; we record only a timestamp of that affirmation. We
do not ask for or store your date of birth. Where
Apple's App Store or Google Play provide an age signal
indicating a user is under 16, we refuse or block the
account. If we learn that an account belongs to
someone under 16, we will delete it. Parents or
guardians can contact us at legal@polygloat.com.
10. A Note on AI
Parts of the learning content in Polygloat —
transcripts, translations, dictionary glosses, and
example sentences — are machine-generated with AI
assistance and curated by humans. Polygloat has no AI
chat, and we make no automated decisions about you
that produce legal or similarly significant effects
(GDPR Article 22).
11. Cookies on Our Website
The Polygloat website uses a single functional cookie
that remembers your language preference. We do not
use analytics or tracking cookies.
12. Changes to This Policy
When we make material changes to this policy that
affect how we collect or use your data, we will ask
you to review and accept the updated version before
continuing to use the app.
13. Contact
legal@polygloat.com