Terms of Use

Last updated: 31 May 2023.

1. General

1.1 These Terms of Use govern, together with the Privacy Policy, your use of the «My words: Grow your vocabulary» mobile application (the ”Application”), “mywords.app”, “mindworksolutions.nl” web-sites (the ”Web-Site”) and related services provided by Mind Work Solutions (”Us”, ”We”). By using the Application, you accept and agree to these Terms and Conditions (“Terms”). Therefore, it is important that you carefully read through these Terms. If you do not consent to these Terms, you should not use the Application.

2. Rights and Obligations

2.1 Hereunder we undertake to:

  • comply with the Privacy Policy as well as the relevant requirements for personal data protection;

  • duly consider incoming applications, complaints and comments of Users.

2.2 We have rights to:

  • unilaterally amend and (or) supplement the Terms, if necessary, including updates in accordance with the applicable law;

  • modify, suspend or terminate operation of or access to the Services, any part and/or features of the Services for any reason;

  • interrupt the operation of the Services or any part thereof, if it is required to perform any maintenance, bug fixes and (or) make any other modifications;

  • place and display advertisements, including advertisements of third parties. These advertisements may contain links to third party resources;

  • delete accounts with unconfirmed email addresses 1 week after creation.

2.3 The User agrees to:

  • submit accurate information requested for the use of the Services, when such information is requested;

  • comply with the Terms of Service and other rules of use of the Services (Privacy Policy) as well as any other applicable law;

  • refrain from re-engineering (reverse engineering), decompilation and disassembly of the Services or parts thereof, refrain from actions aimed at determining the source code of the Services, refrain from actions aimed at circumvention of the software and hardware means of protection of the Services;

  • refrain from using the Services for any purpose prohibited by applicable law or these Terms as well as incite any illegal activity or other activity that violates our rights and legitimate interests as well as the rights and legitimate interests of third parties.

2.4 The User has rights to:

  • use the features of the Services within the limits and in the manner permitted hereby and by the applicable law;

  • contact the Provider for suggestions and/or complaints.

3. Intellectual Property Rights

3.1 All rights in and to the Services, including any trademarks, service marks, trade names and copyrighted content (collectively “Intellectual Property”) presented within the Application are the property of Provider and/or third parties. You agree not to use Intellectual Property for any other purposes except for your use of the Service unless required otherwise by applicable mandatory law.

4. Disclaimer


4.2 Some links on our Services may lead to resources located on third-party websites. These links are provided for convenience of users or as advertisement and do not imply that the Provider is responsible for the availability of these resources or for their content.

4.3 The Services allow users to enter and send information. Users will be fully responsible for contents of such information and undertake to obtain any permits from third parties necessary for the provision of the information.

4.4 The provider is not responsible for the content of advertisements when the content of advertisements is determined by third parties.

5. Changes to these terms

5.1. We may update our Terms of use from time to time. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. If the changes are significant, we may provide more prominent notice or get your consent as required by law.

6. Extended Plan

6.1 The Provider imposes special restrictions on the features of the Services and places advertisements when access to the Services is provided free of charge.

6.2 You may remove restrictions and disable advertisements for an additional fee (Extended Plan). The provider can provide the Extended Plan for the entire time of use of the Services in exchange for a single payment, or provide temporary access in exchange for regular payments (Subscription). The Extended Plan can also be provided for a limited period of time without charge (Trial Version).

6.3. The available options for accessing the Extended Plan, the payment terms and conditions, the price, the nature of special restrictions are specified in the Application itself.

6.4. The Provider may change the price for the Subscription for a future time. In the event of a change in the Subscription price, the User shall be notified as stipulated in the rules of the platform through which they have accessed the App (Google Play, App Store or App Gallery). The User may consent to the changes or deny consent (fail to provide consent). In the latter case, the Subscription is automatically cancelled in the manner stipulated by the respective platform.

6.5. In app purchases are linked to store accounts (Google Play, AppStore). If you bought a Google Play purchase it will only be available on Android devices with Google Play access. If you purchase from the App Store your purchase will only be available on iOS and macOS.

7. Data Protection

7.1 . The Services may collect and process your personal data. Any collection and processing of your personal data is governed by our Privacy Policy.

Privacy Policy

Last updated: 18 March 2024.

This Privacy Policy (hereinafter, the Policy) governs the processing of personal data of the users of the «My words: Grow your vocabulary» vocabulary learning platform and the pages of the websites with the domain names mywords.app”, mindworksolutions.nl”, (hereinafter referred to as the Services).

We attach great importance to the protection of your personal data, so take a few minutes to find out more about our Privacy Policy and be sure to contact us if you have any questions.

1. Terms and Definitions

1.1 For the purposes hereof, the following terms and definitions are used:

Web-site - web-sites with the domain names “mywords.app”, “mindworksolutions.nl”.

You (User) – any individual that is using the Services and has reached the age of full legal capacity in accordance with the legislation of the country of their citizenship.

Application – application for learning foreign words «My words: Grow your vocabulary».

We (Controller) – Mind Work Solutions.

Services – application for learning foreign words «My words: Grow your vocabulary», as well as the pages of the web-sites with the domain names “mywords.app”, “mindworksolutions.nl.

2. Scope

2.1. This Policy applies to any interaction between the Controller and users regarding personal data when using the Services.

2.2. This Policy neither governs nor determines the rights and obligations of third parties. It also does not apply to third-party applications or software available to users for integration with the Services. Thus, if you integrate any third-party applications with our Services, we will not be able to control how such applications process your personal data.

2.3. Please do not use the Services if you do not agree with the provisions and the scope hereof.

3. Personal data that we collect

3.1. Personal data is any information that could enable direct or indirect identification of a person (e.g., their name, online identifier, etc.).

3.2. Personal data may be collected both directly and indirectly:

  1. Personal data is collected directly when you provide it voluntarily (e.g. when you buy a tariff plan in the Application);

  2. Indirect collection of personal data may occur automatically when you use the Services, as it happens, for example, with cookies.

3.3. We collect the required minimum of your personal data for the purposes specified in this Policy:

  1. User data: IP address, user actions in the Services, and (in case of registration in the Services) email address;

  2. Device data: country code, language code, time zone, version of the Services, OS version, device identifier;

  3. App data: identifier of the Services, events in the Services, in-app purchases and subscriptions, diagnostic information;

  4. Payment information: list of User transactions in Services.

3.4. We do not store bank card numbers, payment details or other sensitive payment information of Users:

  1. By making payments in app stores (Google Play, App Store, App Gallery), you accept their terms of use and privacy policies.

4. Transfer and Disclosure

4.1. The following third parties may have access to the personal data you are providing us:

(1) Google Ireland Ltd (Ireland)

Address: Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Google Privacy Policy

Google may have access to the personal data that you provide to us because we use the following services:

  • Firebase Crashlytics, Firebase A/B Testing, Google Analytics for Firebase – to collect analytics to improve the user experience;

  • Google AdMob – to show advertisements, including advertisements of third parties, in the app in accordance with the Terms of Use;

  • Play Market – to store user data and host our Services.


Yandex Privacy Policy

Yandex may have access to the personal data that you provide to us because we use the following services:

  • Yandex Advertising Network – to show advertisement in the Application, including advertisements of third parties, in the application in accordance with the Terms of Use;

  • AppMetrica - to collect analytics to improve the user experience. Detailed terms of use and processing of AppMetrica data are described in the following documents:
    Terms of use.

4.2. Please note that disclosure of your personal data may be required in accordance with the law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of the Controller and third parties or for other substantial public interest purposes.

5. Data Processing, Storage and Protection

5.1. “Processing” is understood as any or a combination of the following: storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your personal data.

5.2. We will process your personal data only for the following purposes and on the following legal grounds:

Terms of Use and Privacy Policy

5.3. Subject to data anonymisation, your personal data may be used by us for any other purposes.

5.4. We do not not use automated decision-making tools (including profiling) in personal data processing. Automated decision-making tools primarily include those systems that process your personal data without human intervention to make decisions that may have potential legal consequences for you.

5.5. Your personal data will be stored on the servers of our counterparties that we are using for operating our Services.

5.6. Our employees shall also take all necessary organisational, legal and technical measures available to us for protection of your personal data. Users of the Services shall also be responsible to the maximum possible extent for the provision of accurate account details, keeping passwords and any other information required for authorisation confidential and its protection from unauthorised access by third parties.

5.7. If your personal data is transferred to any third party, the storage time will be determined in accordance with the privacy policy of such a third party. We will do our best to inform them about the deletion of your personal data if necessary.

5.8. Any personal data collected and processed hereunder shall be properly protected unless:

  1. you consent to their disclosure;

  2. such personal data are anonymised;

  3. such personal data are subject to disclosure under the applicable law.

5.9. We will do our best to keep your personal data protected. However, despite any possible measures taken on our part, we cannot guarantee full protection of the Services against information security risks.

6. User Rights

6.1. The rights of users related to the collection and processing of personal data shall be determined in accordance with the applicable law.

6.2. Your rights with respect to the collection and processing of personal data may be determined in accordance with applicable data protection law.

For example, you may access, change and/or make additions to, delete, restrict processing and migration of, object to or withdraw your consent to the processing of your personal data as well as opt-in/opt-out and lodge a complaint to the supervisory authority.

6.3. To exercise any of your rights above and any other rights guaranteed to you by applicable law and if you have any related questions, write to: support@mindworksolutions.nl. For issues related to your personal data please contact: support@mindworksolutions.nl

6.4. We reserve the right to verify your identity before exercising any rights at your request. In case we are not able to exercise any of your rights or provide any information, we will also explain the reasons to you.

7. Final Provisions

7.1. This Policy may be amended and (or) modified at any time of the Services operation. In this case, a notice with information about the changes accompanied by the new version of the Policy and date of its adoption will be published in the Services. The User of the Services must read and acknowledge the new version hereof.

7.2. The Policy is an agreement between us and the User about the use of the Services. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby canceled.

7.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.

7.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.

7.5. This policy has been drawn up in Russian and English. In the event of any textual discrepancy, the Russian version prevails.

Contact Information

E-mail for communication on technical support and personal data: support@mindworksolutions.nl