Privacy Policy - Spelling and Vocab

1. Our Role

We act as a data controller for teacher accounts and subscription data.

We act as a data processor when processing student data on behalf of schools.

2. Information We Collect

Teachers

Name
Email address
Login credentials
Uploaded lesson content
Student performance data
Subscription information

Payments are processed by Stripe. We do not store full card numbers.

Students

First name or display name
Login credentials
Writing submissions
Pronunciation audio recordings (which are not stored after analysis)
Lesson results

We collect only data necessary for educational functionality.

SSO Data (Google/Microsoft)

Name
Email address
Basic profile information

Used solely for authentication and account management.

We do not sell or use SSO data for advertising.

Automatically Collected

IP address
Device information
Usage logs

Used for security and improvement.

3. How We Use Data

We use data to:

Provide the Service
Process subscriptions
Deliver AI feedback
Improve functionality
Maintain security
Comply with legal obligations

Audio recorded for pronunciation analysis is not stored.

We do not sell personal data.

We do not use student data for behavioural advertising.

4. AI Processing

Student writing and pronunciation may be processed by third-party AI providers solely to generate feedback.

We require providers to process data securely and in accordance with applicable data protection laws.

See below for the Spelling and Vocab Google Docs™️ Add-on limited use requirement statement.

5. Legal Bases (UK)

We process data based on:

Contract performance
Legitimate interests
Legal obligations
Consent (where required)

Schools determine lawful basis for student data.

6. U.S. Student Privacy

When used in U.S. schools:

Schools are responsible for obtaining parental consent under COPPA where required.
We act as a service provider under FERPA.
Student data is not sold or used for advertising.
Parents should contact their school first regarding student data.

7. Data Sharing

We may share data with:

Stripe
Cloud hosting providers
AI providers
Analytics providers
Professional advisers

We share only what is necessary to operate the Service.

8. Data Retention

We retain data only as long as necessary to provide the Service and meet legal obligations.

Student audio recordings are not stored after analysis.

If an account is deleted:

Data is removed from active systems within a reasonable period.
Some data may remain in secure backups temporarily.

9. Your Rights

UK Users

You have rights to access, correct, delete, restrict, object, and request portability.

Contact: team@spellingandvocab.com

You may lodge a complaint with the UK ICO.

U.S. Users

You may request access or deletion.
Teachers may request deletion directly.
Students and parents should contact their school first.

10. Security

We implement reasonable technical and organisational safeguards including encryption in transit and access controls.

11. International Transfers

Data may be processed outside the UK. We use appropriate safeguards where required.

12. The Google Docs™️ Add-on

By installing the Spelling and Vocab Google Docs™️ Add-on you agree that the add-on script can read the current Google doc™️. This is required to see which words have been highlighted for enrichment.

The contents of your Google doc™️ are not stored by the add-on.

Audio recorded on SpellingandVocab.com for pronunciation analysis is not stored after analysis.

Google Workspace API data:
The use of raw or derived user data received from Google Workspace APIs by Spelling and Vocab adheres to the Google User Data Policy, including the Limited Use requirements.

Google and Google Docs are trademarks of Google LLC.

13. Changes

We may update this Policy from time to time.

14. Contact

team@spellingandvocab.com

Komodo Learning Ltd
109–113 Royal Avenue
Belfast BT1 1FF, UK