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Privacy Policy

What we collect when you use Wordy or wordytrainer.com, why, and what you can do about it.

Effective 13 October 2026, ARMA OUTDOOR d.o.o. Beograd

1. Who we are

Wordy is made and operated by ARMA OUTDOOR d.o.o. Beograd, a company registered in Serbia (company number / MB 21811343, tax ID / PIB 113148594), with its registered office at Vladimira Popovića 38, 1st floor, 11070 Novi Beograd, Serbia. In this policy "we", "us" and "Wordy" mean that company. We are the data controller for the personal data described here.

You can reach us about anything in this policy at hello@wordytrainer.com.

2. What this policy covers

This policy explains what personal data we collect, why, and what you can do about it, when you:

• visit wordytrainer.com,
• join the waitlist for the private beta,
• create an account and use the Wordy desktop app, including Wordy Helper and paid plans,
• write to us by email.

We process personal data under the Serbian Law on Personal Data Protection (Zakon o zaštiti podataka o ličnosti) and, for people in the European Economic Area and the United Kingdom, under the GDPR and UK GDPR. Where those laws give you rights, this policy applies them to you regardless of where you live.

3. What we collect and why

Waitlist

When you join the waitlist we store your email address, which form on the page you used, the date and time, and your IP address and browser identifier. We use the email address to send you an invitation to the beta and nothing else. The technical details exist only to stop automated sign-ups and duplicates.

Legal basis: your consent for the invitation email (you can withdraw it at any time by replying to any email from us or writing to us); our legitimate interest in keeping the waitlist free of abuse for the technical details.

Account

To use the app you create an account with an email address and a password. We store the email address, a one-way hash of the password (never the password itself), your chosen languages and settings, your plan, and the date you joined. If you came in with an invitation or promo code, we record which one.

Legal basis: performance of our contract with you, that is, providing the app.

Your words and progress

Everything you put into Wordy is yours: word lists you upload or type, the groups you make, favourites, and your answers on each card. We store your answers because spaced repetition needs them to decide when a word comes back. We do not read your lists, sell them, or use them for anything other than running your account.

Legal basis: performance of our contract with you.

Wordy Helper

When you ask Wordy Helper to build a list, the description you type and the language pair are sent to a third-party AI provider that generates the list. We send only that text, never your name, email address or anything else from your account. Do not put personal data about yourself or other people into Helper requests; it is a tool for building vocabulary lists, not for storing personal information.

Legal basis: performance of our contract with you.

Payments

Paid plans are billed by a payment processor. Your card or payment details go directly to that processor and never reach our servers; we receive confirmation that a payment was made, the plan and amount, the country used for VAT, and the last four digits of the card so you can recognise it. We keep invoices and payment records for as long as Serbian tax and accounting law requires.

Legal basis: performance of our contract with you; compliance with our legal obligations for invoices and tax records.

Technical and diagnostic data

Our web server keeps standard access logs (IP address, time, page requested, browser identifier) for 30 days so we can keep the site secure and understand if something is broken. The app may send us basic diagnostic information when something goes wrong: app version, operating system version and the error message. It does not send your word lists or screen contents.

Legal basis: our legitimate interest in running a secure, working service.

Email and support

If you write to us we keep the correspondence so we can answer you and follow up. Legal basis: our legitimate interest in handling your request, or performance of the contract where you are a customer.

4. Cookies and analytics

The website sets no cookies and uses no analytics or advertising trackers. If we add a visitor-statistics tool in future it will be a privacy-friendly one that does not use cookies or identify individual visitors, and we will update this page.

The app stores a sign-in token and your settings on your own computer so you do not have to sign in every time. Signing out removes the token.

The website loads its typefaces and all other assets from our own server; nothing on it calls out to Google or any other third party.

5. Who we share data with

We do not sell personal data and we do not share it with advertisers. We use a small number of service providers who process data on our behalf, under contracts that bind them to confidentiality and to our instructions:

• web hosting for the website and the app's backend,
• an email delivery service for invitations, receipts and account notices,
• a payment processor for paid plans,
• an AI provider that generates Wordy Helper lists.

Beyond that, we disclose personal data only if the law requires it, to a court or authority with proper jurisdiction, or to protect our rights or someone's safety. If Wordy is ever sold or merged into another company, your data would pass to the new owner under the same terms, and we would tell you first.

6. Where data is stored

We are based in Serbia and our primary systems are hosted there. Some of the providers listed above operate in the European Union or the United States. Where a provider is outside the EEA, the UK or Serbia, we rely on the European Commission's standard contractual clauses, the EU-US Data Privacy Framework where the provider is certified, or another lawful transfer mechanism, so your data keeps the same level of protection. You can ask us for details of the safeguards in place for a specific provider.

7. How long we keep data

Backups are rotated on a short cycle, so deleted data can remain in a backup for a limited time before it is overwritten.

8. Your rights

You have the right to:

• access the personal data we hold about you and get a copy,
• correct it if it is wrong,
• delete it (you can delete your account yourself in the app at any time),
• restrict or object to processing based on our legitimate interests,
• take your data with you in a machine-readable format; your word lists can be exported from the app,
• withdraw consent at any time where processing is based on consent, without affecting what was done before,
• complain to a supervisory authority.

To use any of these rights, email hello@wordytrainer.com from the address on your account. We answer within 30 days. We never charge for this.

The supervisory authority in Serbia is the Commissioner for Information of Public Importance and Personal Data Protection (Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti, poverenik.rs). If you live in the EEA or the UK you can also complain to the data protection authority in your own country.

9. Security

Data travels between the app, the website and our servers over encrypted connections. Passwords are stored only as salted hashes. Access to systems that hold personal data is limited to the people who need it to run the service. No system is perfectly secure; if a breach ever affects your data we will tell you and the relevant authority as the law requires.

10. Children

Wordy is not directed at children under 16. We do not knowingly collect personal data from anyone under 16 without a parent's or guardian's consent. If you believe a child has created an account, write to us and we will delete it.

11. Changes to this policy

We will update this page when our practices change, for example when the beta ends or we add a new provider. The effective date at the top always shows the current version. For material changes we will also tell you by email or in the app before they take effect.

12. Contact