Privacy Policy
Nice Words (“we”, “us”, “our”) operates the Nice Words mobile application (the “App”). This Privacy Policy explains what personal data we collect, how we use it, and your rights regarding your data.
Effective date: August 9, 2026
Last updated: August 9, 2026
1. Owner and Data Controller
Aleksandra Lisek
03-982 Warsaw, Poland
Contact email: contact.nicewords@gmail.com
We are not required to appoint a Data Protection Officer (DPO) under GDPR Art. 37, as we do not meet the criteria that would trigger such appointment. Data protection inquiries should be sent to the contact email above.
2. Types of Data Collected
We collect the following categories of personal data:
Account data — email address, display name, profile picture (if provided via Google/Apple sign-in), user identifier.
User-generated content — affirmation groups, custom badges, custom tasks, daily task completions, application settings and preferences.
Device and usage data — device model, operating system version, application version, language, time zone, crash reports, performance metrics, in-app interactions (“Usage Data”).
Advertising identifiers — Apple IDFA (iOS) or Google Advertising ID (Android), collected only with user consent via the platform’s ATT/UMP consent flow.
Purchase data — subscription status, purchase history, product identifiers. No card or payment details are ever handled by the App; all payments are processed by Apple or Google.
Push notification tokens — device tokens used to deliver notifications, only if the user grants notification permission.
Whether provision of data is mandatory
- Email address — mandatory to create an account; without it you cannot use synced features. Without an account, you can still use limited offline functionality.
- Analytics and advertising data — optional; refusal has no impact on the App’s core functionality.
- Push notification tokens — optional; refusal means you will not receive reminders or notifications.
- Advertising identifier (IDFA/AAID) — optional; refusal means you will see non-personalized ads instead of personalized ones (free tier only).
3. How We Use Your Data
We process personal data for the following purposes:
- Providing the service — authenticating you, storing your affirmations and settings, syncing across devices
- Improving the app — pseudonymous usage analytics, crash diagnostics
- Delivering notifications — daily affirmation reminders, streak notifications
- Processing subscriptions — tracking active premium entitlements
- Serving advertisements — showing personalized or non-personalized ads (based on your consent choice) to free-tier users
- Complying with legal obligations
4. Legal Basis for Processing (GDPR)
For users in the EU / EEA, we process personal data under the following legal bases:
- Consent — analytics, advertising, personalized notifications, push notifications
- Performance of a contract — account management, subscription processing, providing the service
- Legitimate interest — see below
- Legal obligation — where required by applicable law
Users outside the EU/EEA
For users outside the EU/EEA, we process personal data based on your consent (given by creating an account and continuing to use the App) and the performance of the contract between us. Where applicable local laws provide additional bases or requirements (e.g., LGPD in Brazil, CCPA/CPRA in the United States), we apply those alongside — see the dedicated sections below.
Specific legitimate interests we pursue
Where we rely on legitimate interest as a legal basis, our specific interests are:
- Product improvement: analyzing pseudonymous usage patterns to identify bugs, improve features, and prioritize development. Balanced against your privacy by using pseudonymized data only.
- Fraud and abuse prevention: using Firebase App Check to prevent unauthorized API access and protect legitimate users from service disruption.
- Security monitoring: using crash reports to identify and fix security vulnerabilities.
You have the right to object to processing based on legitimate interest — see Section 7 below.
Automated decision-making
We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects on you.
5. Recipients of Personal Data (Third-Party Sub-Processors)
We share personal data with the following categories of recipients, acting as processors on our behalf under Data Processing Agreements pursuant to GDPR Art. 28:
- Cloud infrastructure providers (Firebase / Google Cloud) — hosting, database, functions
- Analytics providers (Firebase Analytics) — usage analytics
- Crash reporting providers (Sentry) — error monitoring
- Advertising networks (Google AdMob) — advertisement serving to free users
- Payment processors (RevenueCat, Apple, Google) — subscription management
- Authentication providers (Google, Apple) — user login
We do not share personal data with any recipients other than those listed above and their sub-processors.
Each service processes data according to its own privacy policy.
Firebase (Google LLC / Google Ireland Limited)
Firebase services are provided by Google LLC for users outside the EU/EEA and by Google Ireland Limited for users in the EU/EEA. Google is certified under the EU-US Data Privacy Framework. All Firebase services use the following privacy policy: https://firebase.google.com/support/privacy
Firebase Authentication — user login and account management (Registration and authentication).
- Personal Data processed: email address, user identifier, sign-in method
- Place of processing: Ireland (EU users) / United States (other users)
Firebase Cloud Firestore — cloud database for user data (Hosting and backend infrastructure).
- Personal Data processed: user profile, groups, affirmations, badges, tasks, completions, Usage Data
- Place of processing: Ireland (EU users) / United States (other users)
Firebase Cloud Functions — serverless backend for scheduled notifications and webhooks (Hosting and backend infrastructure).
- Personal Data processed: user identifier, Usage Data
- Place of processing: Ireland (EU users) / United States (other users)
Firebase Cloud Messaging — push notification delivery.
- Personal Data processed: device push token, notification content
- Place of processing: Ireland (EU users) / United States (other users)
Google Analytics for Firebase — pseudonymous usage analytics.
- Personal Data processed: device information, session data, screen views, custom events, Usage Data
- Place of processing: Ireland (EU users) / United States (other users)
Firebase App Check — anti-abuse verification of app authenticity.
- Personal Data processed: device attestation tokens (pseudonymous; no directly identifying personal data)
- Place of processing: Ireland (EU users) / United States (other users)
RevenueCat, Inc.
Subscription and in-app purchase management (Access to third-party service accounts / Payment management).
- Personal Data processed: user identifier, subscription status, purchase history, device identifiers
- Place of processing: United States
- Privacy policy: https://www.revenuecat.com/privacy/
Google AdMob (Google LLC / Google Ireland Limited)
Mobile in-app advertising (Advertising), shown to free-tier users only.
- Personal Data processed: advertising identifier (IDFA / AAID), device info, ad interaction data, IP address, coarse location, Usage Data
- Consent: users must consent via the UMP consent form on first launch; consent can be revoked in Settings
- Place of processing: Ireland (EU users) / United States (other users)
- Privacy policy: https://policies.google.com/technologies/ads
Sentry (Functional Software, Inc.)
Application error and crash reporting (Infrastructure monitoring).
- Personal Data processed: crash stack traces, device info, app version, user identifier (for grouping only)
- Place of processing: European Union (Sentry EU region —
de.sentry.io)
- Privacy policy: https://sentry.io/privacy/
Google Sign-In (Google LLC / Google Ireland Limited)
Optional authentication via Google account (Registration and authentication).
- Personal Data processed: email address, name, profile picture, Google account identifier
- Place of processing: Ireland (EU users) / United States (other users)
- Privacy policy: https://policies.google.com/privacy
Sign in with Apple
Optional authentication via Apple ID.
- Personal Data processed: email address (may be a private relay), name (only if user chooses to share)
- Place of processing: United States
- Privacy policy: https://www.apple.com/legal/privacy/
6. Data Retention
- Account data — retained for as long as your account is active. Deleted within 30 days of account deletion.
- User-generated content — retained while the account is active. Deleted immediately upon account deletion; we do not maintain user-recoverable backups.
- Analytics data — retained by Google for up to 14 months.
- Crash reports — retained by Sentry for up to 90 days.
- Purchase history — retained by RevenueCat and Apple/Google according to their policies; typically 7 years for tax and accounting compliance in Poland.
7. Your Rights
You have the right to:
- Access — request a copy of the personal data we hold about you
- Rectification — correct inaccurate data
- Erasure — delete your account and associated data
- Portability — receive your data in a machine-readable format
- Restriction — restrict certain processing activities
- Objection — object to processing based on legitimate interest or for direct marketing
- Withdraw consent — withdraw previously granted consent at any time
- Lodge a complaint — file a complaint with your data protection authority
To exercise these rights, contact us at contact.nicewords@gmail.com. We respond within 30 days. In exceptional cases involving complex or numerous requests, we may extend this period by up to two additional months, informing you of the reason for the delay within the initial 30-day window (as permitted by GDPR Art. 12(3)).
You can delete your account directly in the App: Settings → Account → Delete Account.
Right to lodge a complaint
If you believe our processing of your personal data violates GDPR, you have the right to lodge a complaint with a supervisory authority. For users in Poland:
Urząd Ochrony Danych Osobowych (UODO)
ul. Stawki 2, 00-193 Warsaw, Poland
Website: https://uodo.gov.pl
Phone: +48 22 531 03 00
EU/EEA users may also lodge a complaint with the supervisory authority of their habitual residence, place of work, or the place of the alleged infringement.
8. Users in the United States
This section applies to residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and Montana.
Notice at Collection (CCPA/CPRA)
We collect the following categories of Personal Information as defined by California law:
| Category |
Examples |
Purpose |
Retention |
| Identifiers |
email, user ID |
Account & service |
Account lifetime + 30 days |
| Internet/electronic activity |
app interactions, device info |
Analytics, functionality |
Up to 14 months (Google) |
| Commercial information |
subscription status, purchase history |
Subscription management |
7 years (tax) |
| Geolocation (coarse) |
approximate location from IP |
Advertising (free tier) |
Ad session only |
We do not collect Sensitive Personal Information as defined by CPRA.
Sale and Sharing
- We do not sell your Personal Information.
- We do share certain identifiers (advertising ID, device info) with Google AdMob for cross-context behavioral advertising when you consent via the UMP form. This “Sharing” is opt-in only. You may opt out at any time in the App: Settings → Privacy → Ad Preferences.
Global Privacy Control (GPC)
We honor Global Privacy Control (GPC) signals where technically feasible. If your device transmits a GPC signal, we treat it as an opt-out of Sharing.
Your rights
You have the right to:
- Know what Personal Information we collect
- Delete your Personal Information
- Correct inaccurate information
- Opt out of Sharing (see above)
- Non-discrimination for exercising these rights
- Designate an authorized agent (see below)
To exercise these rights: contact.nicewords@gmail.com
Authorized agents
You may designate an authorized agent to submit CCPA/CPRA requests on your behalf. To process such requests, we will require:
- Written and signed permission from you authorizing the agent
- Verification of your identity directly with us
- Verification of the agent’s authority (e.g., a signed power of attorney)
Send authorized-agent requests to contact.nicewords@gmail.com with the subject line “AGENT REQUEST”.
9. Users in Brazil (LGPD)
For users in Brazil, we process personal data (“Dados Pessoais”) pursuant to Lei Geral de Proteção de Dados (Federal Law No. 13,709/2018 — LGPD).
Legal bases (LGPD Art. 7 and Art. 11)
We process your data based on:
- Your consent
- Compliance with a legal obligation
- Execution of a contract
- Legitimate interests, subject to the balancing test
Your rights (LGPD Art. 18)
You have the right to:
- Confirmation of processing
- Access to your data
- Correction of inaccurate data
- Anonymization, blocking, or deletion of unnecessary data
- Portability
- Deletion of data processed based on consent
- Information about entities we share data with
- Information about the possibility to deny consent
- Withdrawal of consent
- Objection to processing that violates LGPD
Data Protection Officer (Encarregado)
We are not required to appoint a DPO under LGPD given our operation size. For data protection inquiries, contact contact.nicewords@gmail.com.
Complaint
You may lodge complaints with the Brazilian data protection authority: ANPD (Autoridade Nacional de Proteção de Dados) at https://www.gov.br/anpd
10. Children’s Privacy
Nice Words is not intended for children.
- Users in the EU/EEA: the App is not intended for users under 16. Per GDPR Art. 8 (as implemented in Poland), users aged 13–16 may only use the App with verifiable parental consent, which the App does not currently collect. If we become aware that we have collected personal data from a user under 16 in the EU without such consent, we will delete it.
- Users outside the EU/EEA: the App is not intended for users under 13 (COPPA standard). We do not knowingly collect personal data from children under 13.
Parents who believe their child has provided us with personal data may contact us at contact.nicewords@gmail.com and we will delete the data.
11. International Data Transfers
Your data may be transferred to and processed in countries outside the EU/EEA, including the United States.
For transfers to the United States, we rely on:
- EU-US Data Privacy Framework certification — Google LLC is certified: https://www.dataprivacyframework.gov/list
- Standard Contractual Clauses (SCCs) — as backup, and for transfers not covered by DPF
Our processors have committed to appropriate safeguards. However, we acknowledge that data protection laws in the United States may not be equivalent to those in the EU. If the DPF is invalidated or a processor loses its certification, we will rely on SCCs and, if necessary, transition to processors that provide equivalent protection.
You may request a copy of the applicable transfer mechanism by contacting us.
12. Security
We implement appropriate technical and organizational measures to protect your data:
- All network communication is encrypted in transit via HTTPS/TLS
- Local database encryption on-device (SQLCipher / AES-256)
- Firebase App Check to prevent abuse
- Firestore security rules restricting access to authorized users only
- Regular review of dependencies for security vulnerabilities
Data breach notification
In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will notify you without undue delay via the email address associated with your account, as required by GDPR Art. 34, and notify the competent supervisory authority within 72 hours as required by Art. 33.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be notified through the App and/or by email. The “Last updated” date at the top reflects the most recent revision.
For any privacy-related questions or to exercise your rights:
Aleksandra Lisek
Email: contact.nicewords@gmail.com