Legal
Privacy Policy
Effective 2026-05-06
This Privacy Policy explains how Andrii Donich(“we,” “our,” “us”) collects, uses, and shares personal data when you use Shadowin(the “Service”). It is written to comply with the EU/UK GDPR and the California Consumer Privacy Act (CCPA/CPRA). Where these regimes grant additional rights, those rights are described in Section 7.
The data controller is Andrii Donich, registered at Malovskogo 10, Odesa, Ukraine. You can contact us about privacy at deplazaa@gmail.com.
1. Data we collect
Account. Email address, hashed password (or OAuth identifier), display name, and account creation date. Source: you, at sign-up.
Profile. Display name, premium status, premium gem color, language preference. Source: you, in settings.
Practice data. Voice recordings, transcript alignment, accuracy scores, mistake history, lesson progress, streak counts, XP, and total practice time. Source: generated as you use the Service.
Payment metadata.For card sales: order ID, subscription status, last 4 digits of card, billing country — source: Gumroad. For crypto sales: invoice ID, blockchain transaction hash, paid currency and amount — source: NOWPayments. We never see your full card number, your wallet's private keys, or any seed phrase.
Technical. IP address, browser/device user agent, request timestamps, error logs. Source: automatically, when you use the Service.
We do not collect: full payment-card numbers; biometric identifiers beyond the voice features needed for scoring; precise geolocation; or data from minors under sixteen (16).
2. How we use data
We use personal data to:
(1) provide the Service: authenticate you, run pronunciation scoring, track progress, and gate premium features; (2) process payments — for card sales, via Gumroad which acts as Merchant of Record and as an independent data controller for billing data; for crypto sales, via NOWPayments which acts as a payment processor for an invoice issued by us; (3) generate AI-personalized practice content (premium feature) by sending your most-missed words to OpenAI for sentence generation, without identifying account data attached; (4) communicate with you via transactional email (receipts, security alerts, refund correspondence) — we do not send marketing email without separate opt-in consent; (5) detect and prevent abuse: rate-limit enforcement, fraud detection, account-security investigations; (6) comply with legal obligations and enforce our Terms.
Legal bases (GDPR). Contract — providing the Service you signed up for. Legitimate interests — security, abuse prevention, service improvement, balanced against your rights. Consent — any feature explicitly marked as opt-in (none currently). Legal obligation — tax records, responding to lawful requests.
3. AI processing — voice and text
Voice recordings you submit during practice are transmitted to OpenAI's APIs for transcription (Whisper) and to OpenAI's text-generation APIs (GPT-4o-mini) for premium content generation. Per OpenAI's API terms in effect at the time of writing, API inputs are not used to train OpenAI models and are retained for abuse-monitoring purposes for a limited period before deletion.
We do not transmit your account email, name, or user ID with these requests — only the audio or text needed to produce the result. Aggregated, non-identifying derivatives (e.g., your top mistake words) are stored in our database to power the focus-session feature.
4. Sharing and subprocessors
We share data only with the following categories of recipients, each acting on our instructions or as an independent controller for their own portion of the flow:
Supabase — hosting, authentication, database (EU or US, per project region). Vercel — application delivery and edge functions (global edge). OpenAI — AI transcription and content generation (US). Gumroad, Inc. — card-payment processing, tax handling, billing receipts; acts as an independent data controller for card-payment data (US). NOWPayments — crypto-payment invoice hosting and on-chain transaction monitoring; acts as a processor for crypto invoices we issue.
We do not sell your personal data, and we do not “share” it for cross-context behavioural advertising as defined by the California Privacy Rights Act.
International transfers are protected by Standard Contractual Clauses (SCCs) where required by GDPR or UK GDPR.
5. Retention
Account profile — while your account is active; deleted within thirty (30) days of an account-deletion request.
Practice data (recordings, scores) — while your account is active; deleted on request. Raw voice recordings are not retained server-side beyond the time required to return a score.
Payment metadata — retained seven (7) years for tax-compliance purposes. Card-payment records are controlled by Gumroad, Inc. as Merchant of Record under their own retention policy. Crypto-invoice records are retained by us for the same tax-compliance period.
Application/error logs — ninety (90) days.
6. Security
We use industry-standard measures: TLS in transit, encrypted storage at rest, row-level security in our database, scoped service-role keys, hashed passwords (handled by Supabase Auth). No system is perfectly secure; we will notify affected users and authorities of any qualifying data breach without undue delay as required by law.
7. Your rights
Depending on your jurisdiction, you have the right to: access the personal data we hold about you; rectify inaccurate data; erase your data (“right to be forgotten”); restrict or object to certain processing; port your data in a structured, machine-readable format; withdraw consent for any processing based on consent; and lodge a complaint with your local supervisory authority.
California residents (CCPA/CPRA) additionally have the right to know, delete, correct, and limit the use of sensitive personal information, and the right to non-discrimination for exercising these rights.
To exercise any of these, email deplazaa@gmail.com from the address associated with your account. We will respond within thirty (30) days, or forty-five (45) for complex requests.
8. Cookies and local storage
We use only strictly-necessary cookies and local storage for authentication session state. We do not use third-party analytics, advertising cookies, or behavioural tracking.
9. Children
The Service is not directed at children under sixteen (16) and we do not knowingly collect data from them. If you believe a child has provided us with personal data, contact deplazaa@gmail.com for prompt deletion.
10. Changes to this policy
Material changes will be communicated by email or via an in-app notice at least fifteen (15) days before they take effect.
11. Contact
Andrii Donich
Malovskogo 10, Odesa, Ukraine
Data protection contact: deplazaa@gmail.com