Privacy Policy

Effective date: November 9, 2026. For the Prepoch app for iPhone.

This Privacy Policy explains how Prepoch ("Prepoch", "we", "us") handles information when you use the Prepoch app for iPhone (the "App"). It covers what we collect, why, who we share it with, how long we keep it and the choices you have.

If you have a question about this policy or your data, contact us at puhustudios@gmail.com.

1. Information we collect

Account information

You can use the App as a guest or sign in with Apple or Google.

• Guest: we create an anonymous account ID. No name or email is collected.
• Sign in with Apple: we receive a unique account ID and, if you choose to share them, your name and email address. If you choose "Hide My Email", we receive a private relay address instead of your real email.
• Sign in with Google: we receive a unique account ID, your name and your email address.
• Profile: the display name you enter in the App is stored with your account. The avatar you pick is stored on your device.

Content you create

• The text you write in the App (emails, academic discussion posts, coaching answers, sentences) and the answers you give in practice sessions and exams.
• Voice recordings you make in Speaking tasks.
• The results calculated from your work: scores, band estimates, mistakes, words and phrases you save, your streak and activity.

Speech recognition

In some review cards you repeat a sentence aloud so the App can show which words you missed. For this the App uses Apple's speech recognition. When your device supports it, recognition runs on your device and the audio does not leave it. On devices that do not support on-device recognition, Apple may process the audio under Apple's own privacy policy. We do not receive or keep this audio.

Purchases

If you buy a subscription plan or a credit pack, Apple processes the payment. We never see your payment card details. We receive confirmation of the purchase and your plan status through RevenueCat, which manages in-app purchases for us. RevenueCat links your purchases to your Prepoch account ID.

Credits and usage

To run the credit system and prevent abuse, our servers keep your credit balance, plan allowance, a history of credit changes, invite codes you share or redeem, and daily usage counters (for example how many AI requests your account made today and how large they were).

Security information

• App Check: we use Firebase App Check with Apple's App Attest to confirm that requests to our servers come from a genuine copy of the App.
• One-way hashes: when you sign in with Apple or Google, we store one-way hashes (scrambled, non-reversible codes) of your Apple or Google account ID and email address. They let us stop the same person from getting the free first practice or invite rewards more than once. A hash cannot be turned back into your ID or email.

Technical information

Our service providers receive technical information such as your IP address, device type and operating system version when your device connects to them. If you have chosen to share analytics with app developers in your device settings, Apple may share crash reports and diagnostics with us.

What we don't collect

We don't collect your precise location, contacts, photos, health data or advertising identifier. The App contains no third-party advertising and no analytics or tracking SDKs.

2. How we use information

• To provide the App: create and recognise your account, run practice sessions and exams, calculate scores, schedule your reviews, show your progress and show today's words in the widget.
• To give you feedback on your writing and speaking (see section 3).
• To manage credits, plans and purchases, and to prevent fraud and misuse.
• To keep the App secure and working, fix problems and answer your messages.
• To meet legal obligations.

Where the law requires a legal basis (for example in the EU or UK), we rely on performing our contract with you (providing the App), our legitimate interests (security, fixing problems, preventing abuse), your consent (microphone and speech recognition permissions) and legal obligations.

3. AI feedback

Writing feedback, Speaking scores, Coach sessions and some practice content are produced with a third-party AI service, Google's Gemini API.

• When you ask for feedback, the App sends the text you wrote or the audio you recorded, together with the instructions needed to evaluate it, to our servers, and from there to the AI service.
• The AI service returns the feedback, which we show you and save in your progress.
• We do not keep your voice recordings after they have been scored. The result (scores and notes) is kept.
• We do not use your writing or recordings to train our own AI models, and we do not sell them.
• The AI provider processes the content under its own terms for API use.
• Please don't include sensitive personal information (such as health, financial or identity numbers) in your practice answers.

AI feedback can be wrong. Scores and bands in the App are practice estimates, not official TOEFL scores.

4. Who we share information with

We share information only with the service providers that help us run the App, and only what each of them needs:

• Sign-in and account services
• Cloud hosting, database and security services
• AI feedback services (see section 3)
• Payment and subscription services, including Apple, which processes App Store payments
• Content delivery services for lesson audio

We may also disclose information if the law requires it, to protect the rights and safety of our users or others, or as part of a sale, merger or transfer of the App. In a transfer, the new owner would have to keep to this policy, and we would tell you.

We do not sell personal information and we do not share it for advertising.

5. Permissions

• Microphone: needed for Speaking tasks and for repeating sentences in review cards. The App asks for permission the first time and records only while you are answering.
• Speech recognition: used to write out what you said in review cards (see section 1).

You can turn these permissions off at any time in your device's Settings → Privacy & Security. The rest of the App keeps working.

6. Where your data is stored and how long we keep it

• On your device: your practice history, Notebook, progress, avatar and settings. Deleting the App removes this copy.
• iCloud: if you turn on iCloud backup in the App, a copy of your progress is saved in the private storage of your own iCloud account so you can restore it on another device. That copy is controlled by you and Apple. You can delete it in your iCloud settings.
• On our servers: your account, display name, credits, credit history, invite codes and usage counters. We keep them while your account exists.
• Voice recordings: not stored by us after scoring.

Deleting your account

You can delete your account at any time in the App's Settings. When you do, we delete your account and the data linked to it from our servers. The one-way hashes described in section 1 are kept, so that the free first practice and invite rewards cannot be claimed again; they cannot identify you. Purchase records held by Apple and RevenueCat may be kept as long as the law requires. Server logs are removed on a rolling schedule.

Deleting your account does not cancel an active subscription. Cancel it in your Apple ID settings.

7. Your rights

Depending on where you live, you may have the right to access, correct, delete or export your personal information, to object to or restrict certain processing, and to withdraw consent. You can delete your account in the App. For any other request, email puhustudios@gmail.com. We may need to confirm that the request comes from the account owner. You can also complain to your local data protection authority.

8. Children

The App is not intended for children under 13, and we do not knowingly collect personal information from them. If you are under the age of majority where you live, you need your parent's or guardian's permission to use the App. If you believe a child under 13 has given us personal information, contact us and we will delete it.

9. Security

Data is encrypted in transit between the App, our servers and our providers. Access to our servers is protected by sign-in and App Check. No system is completely secure, but we work to protect your information and to limit who can access it.

10. International transfers

Our providers operate servers in several countries, including the European Union and the United States. Your information may be processed outside your country. Where required, these transfers are protected by the safeguards our providers offer, such as standard contractual clauses.

11. Changes to this policy

We may update this policy when the App or the law changes. We will change the effective date above and, for significant changes, tell you in the App.

12. Contact

Questions or requests about privacy: puhustudios@gmail.com