VocaX and Privacy

VocaX is designed to protect your information and let you choose what to share

What is Personal Data at VocaX?

At VocaX, we firmly believe in and respect fundamental privacy rights and believe these basic rights should not differ depending on where you live. Therefore, we treat any data relating to an identified or identifiable person or data that VocaX has linked or can link to a person as personal data, regardless of where the person resides. This means data that can directly identify you (like your Apple account identifier) is personal data, and data that cannot directly identify you but can reasonably infer your identity (like your learning records and practice data) is also personal data.

Personal Data Collected by VocaX

We firmly believe that VocaX can provide you with an exceptional learning experience while effectively protecting your privacy. The data we collect is strictly limited to the bare minimum.

Accounts and Sync Credentials

When you use "Sign in with Apple", we only receive the anonymized user identifier (User ID) provided by Apple, which is used to identify your account within VocaX and verify data ownership. Your private CloudKit database is managed by the system iCloud account and is independent of this identifier. We cannot obtain your real name, email address, or physical address through this identifier.

Profile (Optional)

We will request your nickname to greet you on the "Account Settings" page of the App. This is completely optional. If you choose to hide or not provide a nickname, the App will refer to you as "You" by default. This information is stored only locally on your device and in your private iCloud database; we do not read it.

Zero Tracking Commitment and Apple Diagnostics

We do not integrate any third-party behavioral tracking SDKs (such as Firebase, Umeng, or Facebook SDK). Your behavioral data, including clickstreams, browsing habits, and usage duration, belongs entirely to you. Regarding app crash data and performance metrics, we rely solely on anonymous diagnostic services provided by Apple. We only receive anonymous crash reports through Apple to help fix bugs if you have opted to "Share with App Developers" in your iOS system settings.

Learning Data and Zero Access

Your vocabulary learning records, practice statistics, and multi-dimensional interaction data are 100% stored in your private iCloud database. Based on Apple's privacy design, as developers, we are physically unable to decrypt or view any content stored in the CloudKit private database. You retain full sovereignty over your learning data.

How VocaX Uses Personal Data

In accordance with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Personal Information Protection Law (PIPL), and the applicable laws in your region, we process your personal data based on the following legal grounds:

Powering our services

VocaX collects necessary personal data to support our services. The collected data may be used for product or service improvements, internal purposes such as internal analysis, or troubleshooting. For example, when you practice words, we record your learning progress to provide you with personalized review plans and study suggestions.

On-Device Intelligence

Our core intelligence algorithms utilize cutting-edge cognitive science models and run locally on your device to provide a personalized learning experience. Your complete learning data is stored in a private iCloud database (encrypted and managed by Apple), accessible only by you. When you choose to use cloud-based AI features, we only transmit de-identified text snippets essential to fulfill the request for anonymous processing, without associating them with your identity.

Speech Evaluation Service

When you use Speaking Practice, VocaX analyzes audio captured by the microphone on your device to provide pronunciation feedback. Word practice recordings are stored as part of your practice records in your private iCloud database through CloudKit. Sentence practice recordings are used only to calibrate pronunciation on the current screen and are deleted when you try the sentence again or leave the Speaking Practice screen. We do not receive the recordings, and they are not used to train models. You can delete saved word practice records along with your account data.

Improve Learning Experience

We use your learning data to improve app features and user experience, such as optimizing review session recommendations and adjusting review intervals. This data is processed only on your device, or saved in your private iCloud database through Apple's CloudKit service; we cannot read it. We do not collect or analyze your personal learning content for any of the developer's commercial purposes.

Security & Compliance

We leverage on-device security mechanisms to protect the VocaX execution environment and prevent malicious intrusion or fraudulent activity. Because we adhere to the principle of data minimization and store all core data within your private iCloud container or locally on your device, your personal information is protected by Apple's rigorous system-level encryption. This ensures that your data remains inaccessible even to us as developers.

Generative AI and Third-Party Processing

VocaX's core definitions, example sentences, and translation features are powered by third-party Large Language Models (LLMs). To provide these services, we must send specific text segments to the cloud for processing. This section details the data transmission methods, security measures, and associated risks.

Only the Necessary Text Snippet Is Sent

When you look up a word or translate a sentence, VocaX sends only that specific text snippet and does not send your user ID, device fingerprint, or location information.

Training Data Isolation

VocaX does not use your Input or Output to train, test, or fine-tune general AI models. AI providers that receive text to complete your request process data under their applicable terms of service, privacy policies, and agreements with VocaX; retention periods may vary by provider and service region. Unless the applicable terms have been verified, VocaX does not promise immediate third-party deletion after inference.

Limitation of Liability

While we make every effort to vet compliant suppliers, you should avoid entering highly sensitive personal information (such as credit card numbers, passwords, or health records) into the AI chat box. VocaX shall not be held jointly liable for any third-party data breaches resulting from your proactive input of sensitive information.

Local de-identification

Before sending a request, VocaX strips all identity-related metadata (such as User ID, IP address, and device fingerprint) locally on your device. AI providers only see anonymous text snippets and cannot trace them back to you. Our architecture ensures a complete separation of identity and content: developers cannot peek at your original learning material, and cloud models cannot identify you or your personal information from these snippets alone.

Content Filtering and Child Protection

While we employ rigorous prompt engineering to restrict the generation of inappropriate content, there remains a very low probability that generative AI may produce errors, bias, or text unsuitable for minors. Such content does not represent the stance of VocaX. We recommend that users under the age of 18 use these AI features under the guidance of a guardian.

External Links and Risks

While we strive to vet our partners, these third-party service providers maintain independent privacy policies. VocaX assumes no liability for third-party API downtime, data breaches, or policy changes. Once your data is transmitted to a third-party provider, it will be governed by that provider's privacy policy.

CloudKit Data Syncing

We use Apple's CloudKit service as our exclusive data backend. This is more than just data sharing—it is data hosting: your core learning data for long-term storage never actually leaves Apple's secure ecosystem. It resides solely within your iCloud private database, with Apple managing both encryption and physical security. As developers, VocaX can only access data through restricted system interfaces and cannot directly view your original content.

Your Privacy Rights at VocaX

At VocaX, we respect your ability to know, access, correct, transfer, restrict processing, and delete your personal data. We provide these rights to all our users worldwide, and if you choose to exercise these privacy rights, you have the right not to be discriminated against by VocaX and to receive the same level of service quality from VocaX as when you do not exercise privacy rights. If you are asked to consent to VocaX processing your personal data, you have the right to withdraw your consent at any time.

You can exercise your privacy rights through:

Since we use CloudKit private database architecture, your learning data is actually stored in your iCloud account, and you can also access or delete your iCloud data through Apple's Data and Privacy portal.

How VocaX Protects Personal Data

VocaX believes that powerful privacy protection rests on a foundation of great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve these safeguards to help keep your personal data secure.

The security measures we implement include:

Children and Personal Data

VocaX is designed for users aged 13 and older. We deeply understand the importance of protecting the personal data of minors, and therefore utilize the account system provided by Apple to ensure regulatory compliance.

Relies on Apple Family Sharing

We rely entirely on Apple's "Sign in with Apple" and "Family Sharing" mechanisms to handle underage accounts. If a child under the age of 13 needs to use this App, parents can create a child Apple account for them through the Apple Family Sharing feature. The creation of child accounts, parental consent, and privacy controls are all managed by the Apple system; we do not collect additional personal information from children at the App level.

Managed Account for Educational Institution

Educational institutions that join "Apple School Manager" can create Managed Apple Accounts for students. The privacy settings and parental consent process for these accounts are managed jointly by the educational institution and Apple, and we follow the same data protection principles.

We do not proactively identify or distinguish between child and adult accounts. All user data is protected according to the same standards described in this Privacy Policy. If parents need to manage their child's account data or exercise privacy rights, they can do so by logging into the child's account via the in-app Settings page, or manage it through the parental control features of "Apple Family Sharing."

International Data Transfers

VocaX’s products and services connect you to the world. To make this possible, your personal data may be transferred to or accessed by entities around the world to perform processing activities described in this Privacy Policy related to your use of our products and services. VocaX complies with applicable laws on the transfer of personal data between countries and regions to help ensure your data is protected, wherever it may be, and prioritizes the principles of de-identification and data minimization whenever feasible.

According to Apple's privacy policy, your data may be transferred by Apple to Apple data centers around the world. The cross-border transfer and storage of this data is fully managed and protected by Apple, and is part of the system-level services provided by Apple.

Data Retention

VocaX retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, strive to retain the personal data for the shortest period permissible under law.

Since your learning data is stored in your iCloud private database, you have complete control over data retention. You can delete your account and all data at any time through the Settings page in the app. Once deleted, the data will be permanently removed from your iCloud private database and cannot be recovered.

Local Storage Technology

Similar to how websites use cookies, VocaX uses on-device local storage technologies (such as User Defaults, SwiftData, and file system caching) to enable core functionality.

Absolutely Essential Storage

To track your vocabulary mastery and save your preferences (such as theme, sound effects), we must write this data locally on your device (including core algorithm model parameters). Clearing this data will prevent the app from functioning properly or cause progress loss.

Performance Cache

To save your data and improve loading speed, we temporarily cache downloaded audio files or images in your device sandbox. The system may automatically clear these caches when storage is insufficient, or you can completely remove them by reinstalling the app.

Changes to Privacy Policy

We may update this Privacy Policy from time to time. The updated policy will be posted within the app, along with the date of the update. If we make material changes to this Privacy Policy, we will notify you through an in-app notification or other appropriate means. Your continued use of this application constitutes your acceptance of the updated policy. We recommend that you check this page regularly to stay informed about our latest policy.

Contact Us

If you have any questions about exercising your privacy rights, please contact us at [email protected]. Additionally, you have the right to lodge a complaint with the relevant regulatory authority.

We will respond to your request as soon as possible, usually within 7 days.

Updated: September 16, 2026