Last updated: 15 July 2026
This Privacy Policy explains what data BrioVocab collects, why we collect it, who we share it with, how long we keep it, and how you can access or delete it.
1. Who we are
BrioVocab is operated by Vasily Pintov, registered as self-employed in the Russian Federation (INN 422311303598).
- Postal address: 22 Marshala Zakharova St., bldg. 1, apt. 304, Saint Petersburg, 198328, Russia
- Email: vasily@briovocab.com
- Phone: +7 931 239-81-28
For users in the European Economic Area and the United Kingdom, we act as the data controller for the data described below. Email is the fastest way to reach us about any privacy matter.
2. What this policy covers
This policy applies to the BrioVocab website (briovocab.com), the web app (app.briovocab.com), the BrioVocab mobile apps for Android and iOS, the Telegram mini app, and the VK mini app. We refer to all of these together as the Service.
3. What data we collect
3.1 Data you provide
- Account data. Your name or nickname, and any other details you enter in your profile.
- Contact details. Your email address and phone number, if you choose to provide them.
- Voice recordings. When you use a speaking exercise or a voice message, the app records audio through your device microphone. See section 4.
- Images. Photos or images you choose to send to the AI assistant, for example to ask what an object is called in French.
- Messages. The text you write to the AI assistant, and the AI's replies.
- Support correspondence. Whatever you send us when you contact support.
3.2 Data collected automatically
- Installation and device identifier. A unique identifier assigned to your installation of the app. We use it to link your learning progress and subscription to your device when you are not signed in, and to keep the Service working correctly across sessions.
- Account identifiers. Identifiers from the sign-in systems you use (web app, Telegram, VK).
- Learning activity. Which words you have studied, your answers, your review schedule, your progress and your settings.
- Subscription and payment status. Your plan, access status, and payment and refund history. Card numbers are handled by the payment provider or by the app store; we never receive or store them.
- Technical data. IP address, app and OS version, language, and server logs of errors and technical events.
3.3 What we do not collect
- We do not use third-party analytics, advertising, attribution, or crash-reporting SDKs in the mobile apps.
- We do not collect your contacts, calendar, precise location, photo library (beyond images you deliberately send), SMS, or call logs.
- We do not ask for special categories of data such as health, biometric identification, religion or political opinions, and you should not send them to us.
- We do not sell your personal data, and we do not share it for advertising or cross-app tracking.
4. Microphone and voice recordings
BrioVocab requests the microphone permission (RECORD_AUDIO on Android, NSMicrophoneUsageDescription on iOS) for one purpose: to let you speak French and get feedback on what you said.
- The microphone is activated only when you deliberately start a recording, for example by pressing and holding a record button. The app does not listen in the background and does not record when you have not started a recording.
- Your recording is sent to our servers and to an external AI provider so that your speech can be transcribed and assessed. See section 6.
- Recordings are stored on our servers, linked to your account or installation identifier, and are kept until you delete them or delete your account. We keep them so that you can replay your own attempts and so the Service can track your pronunciation progress over time.
- You can withdraw the microphone permission at any time in your device settings. The rest of the Service continues to work without it; only the speaking exercises become unavailable.
5. Why we use your data, and our legal basis
Under the GDPR, we rely on the legal bases listed below. If you are not in the EEA or the UK, the purposes still describe what we do.
| What we do | Why | Legal basis (GDPR) |
|---|---|---|
| Create your account and give you access to BrioVocab | To provide the Service you asked for | Performance of a contract (Art. 6(1)(b)) |
| Store your learning progress and schedule your reviews | To make the Service work as described | Performance of a contract (Art. 6(1)(b)) |
| Process voice recordings, images and messages through AI | To deliver the AI features you actively invoke | Performance of a contract (Art. 6(1)(b)); consent for microphone access at the device level (Art. 6(1)(a)) |
| Use an installation or device identifier | To link your progress and subscription to your installation, and to keep the Service secure and functional | Legitimate interests (Art. 6(1)(f)) |
| Handle payments, trials, refunds and support requests | To run the paid Service and answer you | Performance of a contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) for accounting records |
| Keep logs, prevent abuse and fix errors | To keep the Service secure and reliable | Legitimate interests (Art. 6(1)(f)) |
| Send you service notifications about your account | To tell you things you need to know as a user | Performance of a contract (Art. 6(1)(b)) |
| Comply with applicable law | To meet our legal duties | Legal obligation (Art. 6(1)(c)) |
6. Sending your data to AI providers
BrioVocab's learning features are built on artificial intelligence. To make them work, we send the content you submit to third-party AI providers acting as our processors.
- What is sent: your voice recordings, the images you send to the assistant, the text of your messages, and the minimum context needed to produce a useful answer (for example, the word you are practising or your target level).
- What is not sent: your name, email address, phone number, or payment details. We do not send your contact details to AI providers.
- What they do with it: they process the request, return a result to us, and act only on our instructions under their contracts with us. We do not permit them to use your content for their own purposes.
- Where: these providers operate outside your country and outside the EEA, including in the United States. See section 8.
We may change AI providers as the Service evolves. Any provider we use is bound by a data processing agreement that limits them to processing your content for the purpose of answering your request.
7. Who else we share data with
We share personal data only with the following categories of recipients, and only as far as necessary:
- AI providers — as described in section 6.
- Hosting and infrastructure providers — to run our servers and store data.
- Payment providers and app stores (Apple, Google, and payment processors) — to process subscriptions, trials and refunds.
- Communication platforms (Telegram, VK) — where you use BrioVocab as a mini app inside their platform, and their own privacy policies also apply to your use of their platform.
- Authorities — where we are legally obliged to disclose data, or where disclosure is necessary to establish, exercise or defend legal claims.
We do not sell personal data and we do not share it with data brokers.
8. International transfers
We are based in the Russian Federation, and our providers operate in several countries, including the United States. If you are in the EEA or the UK, this means your personal data is transferred outside the EEA/UK to countries that have not received an adequacy decision from the European Commission and that may not provide the same level of protection as your home country.
Where we transfer your data to a processor, we put a data processing agreement in place and use appropriate safeguards, such as the European Commission's Standard Contractual Clauses, where those are available to us. Where they are not, transfers that are necessary to deliver the Service you asked for are made on the basis of Article 49(1)(b) of the GDPR (performance of a contract with you). You can ask us for details at vasily@briovocab.com.
9. How long we keep data
- Account data, learning progress, voice recordings, images and AI messages — until you delete them or delete your account (see section 10).
- Payment and accounting records — for as long as tax and accounting law requires us to keep them, even after you delete your account.
- Technical logs — normally for a short period, and then deleted or anonymised.
- Backups — deleted content is removed from backups on our normal backup rotation, and is not used for ordinary operations in the meantime.
10. Deleting your data and your account
You can delete your account directly in the app, in the app settings. Deleting your account deletes your profile, your learning progress, your voice recordings, your images and your AI messages.
You can also request deletion by emailing vasily@briovocab.com with the subject "Account deletion". We will action the request within 30 days.
Some data is kept after deletion where the law requires it — in particular records of payments and refunds, which we must retain for tax and accounting purposes. Retained data is isolated and used only for that purpose.
11. Your rights
Depending on where you live, you have the right to:
- Access the personal data we hold about you, and get a copy of it.
- Rectify data that is inaccurate or incomplete.
- Erase your data ("right to be forgotten").
- Restrict or object to processing based on our legitimate interests.
- Portability — receive your data in a machine-readable format and have it transferred to another controller.
- Withdraw consent at any time, without affecting processing that already took place. Withdrawing microphone permission in your device settings is one way to do this.
- Complain to a supervisory authority. In France, this is the CNIL (cnil.fr). You can also complain to the authority in your country of residence.
To exercise any of these rights, email vasily@briovocab.com. We respond within 30 days. We may ask you for information to confirm that the request comes from you.
12. Children
BrioVocab is not directed at children under 13, and we do not knowingly collect personal data from them. In the EEA, if you are under the age of digital consent in your country (between 13 and 16 depending on the country), you may use BrioVocab only with the consent of a parent or guardian. If you believe a child has provided us with personal data, contact us and we will delete it.
13. Security
We use reasonable technical and organisational measures to protect your data against unauthorised access, alteration, disclosure and loss. Data is encrypted in transit. Access to personal data is limited to those who need it to operate the Service. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
14. Changes to this policy
We may update this policy. When we do, we change the "Last updated" date at the top and publish the new version on this page. If a change materially affects how we use your data, we will tell you in the app or by email before it takes effect.
15. Contact
For any question about this policy, your data, or a deletion request:
- Email: vasily@briovocab.com
- Postal address: Vasily Pintov, 22 Marshala Zakharova St., bldg. 1, apt. 304, Saint Petersburg, 198328, Russia
Users in Russia are also covered by our Russian-language privacy policy, issued under Federal Law No. 152-FZ.