Privacy Policy

Last updated: 20 July 2026.

This Privacy Policy (“Policy”) explains how Mind Work Solutions (“we”, “us”, “our”) collects, uses, and protects personal data of users (“you”) of the vocabulary learning application “My Words: Learn Vocabulary” (“App”) and its websites (https://mywords.app, https://my-words.ru, https://mindworksolutions.nl, https://app.my-words.ru and https://links.my-words.app), collectively referred to as the “Services”.

We are committed to protecting your data and complying with the General Data Protection Regulation (GDPR), Russian Federal Law on Personal Data, and other applicable privacy laws.

1. Who We Are

Mind Work Solutions is a company based in the Netherlands. For CloudPayments purchases, our authorized local partner ИП Бабкин Алексей Владимирович (ИНН 246307200869, ОГРН/ОГРНИП 325246800079370), registered under Russian law, acts as the merchant/seller and as an independent controller of related payment records. For support and privacy inquiries relating to Mind Work Solutions’ processing, contact us at support@mindworksolutions.nl.

2. Scope

This Policy applies to the Services offered worldwide via the App Store, Google Play, and our websites. It covers both data we process directly and data collected by third-party services used to provide the Services.

3. What Data We Collect

Platform-specific note: Registration is optional on iOS and Android. Core features work without an account.

On iOS, if you do not register or do not enable My Words account sync, we do not collect your learning content. Learning data remains on your device or in your private iCloud. A non-identifiable record may be stored to manage premium access. Signing into an account that already has a linked premium subscription allows access to premium features.

If you register and have a premium subscription, and (on iOS) choose to enable sync, the following categories of data are collected and stored securely:

Account data (registered users):

Email address (if provided)
Account identifier
Account creation date

Learning data (registered premium users who enable sync):

Vocabulary and translation content you create or save
Categories and category images
Custom texts and notes
Learning statistics and goals

On https://app.my-words.ru and https://links.my-words.app, users in Russia may register or sign in and make CloudPayments purchases. In that case we process account data needed for registration, sign-in, and premium access, together with subscription status and transaction or order references needed to administer the purchase.

General app usage, crash reporting, and device data may be collected by third-party services for analytics and advertising purposes (see section 7).

Payments: We do not store payment-card details. Payment details are processed by the App Store, Google Play, or CloudPayments according to the purchase channel. CloudPayments purchases are linked to a My Words account. We and/or our Russian payment partner may retain subscription status and transaction or order references for purchase administration and legal obligations. See section 6A.

Contact Form: If you contact us via the form on our websites, we collect your email address, message, and (optionally) your name. This information is used only to respond to your inquiry and is not stored long-term. It may be temporarily accessible via our website provider or email system until we reply.

Website cookies: On https://app.my-words.ru and https://links.my-words.app we use:

Strictly necessary cookies required for authentication, profile, and purchases. These cookies are needed for the websites to function and cannot be disabled through the cookie consent controls.
Optional Google Analytics cookies used to understand how the websites are used. These cookies are set only if you consent. You can reject them and change your preference through the website cookie controls.

4. How We Use Your Data

We use data to provide and improve the Services, respond to inquiries, process premium access where applicable, administer purchases where applicable, and comply with legal obligations.

Data Type	Purpose	Legal Basis	Retention
Account data	Sign-in, sync, premium access	Performance of contract	Until account is deleted
Learning data	Enable learning features and sync	Performance of contract	Until user deletes content or the account
Subscription status	Access control	Legitimate interest / contract	While subscription is active and as needed to resolve disputes
Transaction / order references (CloudPayments purchases)	Purchase administration and support	Legal obligation / contract	As required by applicable law and payment-partner policy
Strictly necessary website cookies	Authentication, profile, purchases	Performance of contract / legitimate interest	For the session or as needed for the security and function of the purchase websites
Google Analytics cookies	Website usage analytics	User consent	Until consent is withdrawn or as defined by the analytics provider
Analytics & Ads (apps)	Improve experience, show ads	User consent	As defined by third-party policies

5. Data Storage and Security

Account and synced learning data are stored on servers in the EU. Category images may be stored with our cloud storage provider, which may process data outside the EU under appropriate safeguards. We use encryption in transit and access controls appropriate to the Services. We do not publish detailed security architecture.

On iOS, the app uses Apple’s App Tracking Transparency (ATT) prompt and Google’s Consent SDK. On Android, Google’s UMP Consent SDK is used to obtain and manage advertising consent. On the purchase websites, cookie preferences for optional analytics cookies are managed through the website cookie controls.

6A. Purchases and Payments

Purchase channels:

App Store purchases — iOS in-app purchases;
Google Play purchases — Android in-app purchases outside Russia;
CloudPayments purchases — Android in-app purchases in Russia, and purchases by users in Russia on https://app.my-words.ru and https://links.my-words.app.

We do not store payment-card details. Payment details are processed by the App Store, Google Play, or CloudPayments according to the purchase channel. CloudPayments purchases are linked to a My Words account.

7. Third-Party Services

We rely on the following external services:

Google Ireland Ltd. — authentication, cloud storage, crash reporting, analytics, advertising, and website analytics where enabled
Yandex LLC — analytics and advertising
CloudPayments LLC (Russia) — payment processor for CloudPayments purchases

These services may transfer data internationally under Standard Contractual Clauses (SCCs) or equivalent safeguards.

8. Your Rights

You have the right to:

Access, correct, or delete your data
Restrict or object to its processing
Request data portability where applicable
Withdraw consent (where applicable)
File a complaint with a data protection authority

Registered users can delete their account via profile settings in the App or on the purchase websites. Account deletion removes account and synced learning data stored by us, subject to records retained for legal, accounting, or dispute-resolution purposes.

To exercise your rights, contact us at support@mindworksolutions.nl.

9. Children’s Privacy

The App can be used by children without registration. We do not knowingly collect personal data from users under 13 (or the legal age in your country) through registration, sync, or purchases. If you believe such data has been submitted, contact us.

10. Updates

We may update this Policy. Major changes will be posted in the App or on the website. Continued use of the Services implies acceptance.

11. Language Versions

This Policy is available in English, Spanish, and Russian. In case of conflict, the English version prevails.

Contact: support@mindworksolutions.nl