Privacy Policy

1Who we are

Act Up is made and published by Nuralingua Studios Ltd, 71-75 Shelton Street, London WC2H 9JQ, United Kingdom. We are the data controller for the data described on this page. If you have a question about any of it, email peter@nuralingua.com and a human will reply.

2What we collect

Usage analytics

When you use the app it sends anonymous product-analytics events to PostHog, hosted in the European Union. These tell us how the game is used, for example: the app was opened or sent to the background, a tutorial was completed, a deck was selected, a round started or finished (with the round length, deck, score and orientation), a round was replayed, a video was saved or shared, the paywall was shown or dismissed, a permission was granted or denied, and a setting was changed. Each event carries:

• a random device identifier generated by the analytics library on first launch (it is not your advertising ID and is not linked to any account);
• the app version, platform (iOS or Android), device model and OS version, and the app language you chose;
• whether the device has an active Act Up Pro subscription (true/false, no purchase details);
• an approximate location at country or city level, derived by PostHog from your IP address at the moment the event arrives. PostHog does not store the IP address itself in the event.

We use this to see which decks and features people enjoy, find bugs, and decide what to build next. It is never used to build a profile of you, to serve advertising, or to track you across other apps or websites.

Purchases and subscriptions

Act Up Pro is sold as an in-app subscription through Apple's App Store or Google Play. Apple or Google takes the payment and holds your payment details; we never see your card number or billing address. To unlock Pro and keep it unlocked across launches, the app uses Adapty, a subscription-management service. Adapty receives the store's purchase receipt, verifies it with Apple or Google, and stores the result (product bought, purchase and expiry dates, trial status, store transaction identifiers, country of the store) against an anonymous Adapty profile identifier for your device. Adapty also records the device model, OS version, app version and IP-derived country when the app talks to it.

Support email

If you email us, we keep the message and your email address for as long as it takes to resolve the issue, and for a reasonable period afterwards in case it comes back. That's the only time we ever learn who you are.

3What we do NOT collect

• No account. There is nothing to sign up for. We do not collect your name, email address, phone number, date of birth or photo.
• No contacts, calendars or messages.
• No precise location. The app never asks for location permission.
• No advertising identifier (IDFA / Android Advertising ID), and no App Tracking Transparency prompt, because there is no tracking.
• No tracking across other apps or websites, no advertising SDKs, no data brokers, and we do not sell or "share" data in the sense used by the California Consumer Privacy Act.
• No recordings, photos or audio. See the next section.
• No custom deck contents. Word lists you write stay on your device; analytics only records that a custom deck was played, never the words.

4Permissions and what stays on your device

Act Up only asks for a permission at the moment a feature needs it, and the game is fully playable if you decline every one of them.

Recordings are captured and processed entirely on your device. They are never uploaded to us or to any third party, never analysed, and never used to train anything. A recording only leaves the device if you save it to your photo library or send it through the system share sheet, at which point the app you share it with has its own privacy policy.

Also stored locally and never sent to us: your settings (language, round length, sound, haptics, orientation), your custom decks, your round history, and a count of the free rounds you've played today. Deleting the app removes all of it. Recordings you saved to your photo library stay there until you delete them.

5Third parties we work with

These companies process data on our behalf or as independent controllers. We do not share data with anyone else.

• Apple (App Store, in-app purchases on iOS). Apple processes your payment and holds your Apple Account. Apple Privacy Policy.
• Google (Google Play, in-app purchases on Android). Google Privacy Policy.
• Adapty Tech Inc. (subscription verification and status). Adapty Privacy Policy.
• PostHog Inc. (product analytics, EU Cloud, servers in Frankfurt, Germany). PostHog Privacy Policy.

Adapty forwards subscription events (trial started, renewed, cancelled) to our PostHog project under the same anonymous identifier so we can see whether Pro is working. No payment details are included.

Apple and Google separately collect data about downloads and crashes through the App Store and Google Play under their own policies; we only ever see anonymised aggregate numbers there.

6Legal basis and international transfers

Under the UK GDPR and EU GDPR we rely on our legitimate interest in understanding and improving the game (analytics) and on performance of a contract (delivering the subscription you bought). We keep analytics deliberately anonymous and minimal so the intrusion on you is as small as we can make it; you can object at any time (see section 9).

Analytics data is stored in the EU. Adapty is based in the United States and may process data there; the transfer is covered by Adapty's standard contractual clauses with us. Apple and Google process purchase data under their own terms.

7Retention

• Analytics events are kept in PostHog for up to 12 months and then deleted. Aggregate statistics (such as "how many rounds were played in March") may be kept longer but contain no identifiers.
• Subscription records in Adapty are kept while your subscription is active and for as long afterwards as we need to handle restores, refunds, disputes and tax or accounting obligations.
• Support emails are deleted within 12 months of the issue being closed.
• Everything on your device is removed when you delete the app.

8Children

Act Up is rated 4+ / Everyone and is designed to be played by families and groups of all ages. It has no accounts, no chat, no social features, no advertising and no way for a child to enter personal information. The only data the app sends is the anonymous usage and subscription data described above, which is not linked to any person and is not used for behavioural advertising or profiling.

We do not knowingly collect personal information from children under 13 (or the age of digital consent where you live), and we have designed the app so that we do not need to. Purchases require the device owner's App Store or Google Play authorisation; parents can use Screen Time or Google Play parental controls to block or approve purchases. If you believe we have received personal information from a child, email us and we will delete it.

9Your rights

The UK GDPR, EU GDPR and California Consumer Privacy Act (and similar laws elsewhere) give you rights to access, correct, delete and port your personal data, to object to or restrict its processing, and not to be discriminated against for exercising them. We honour all of these.

Because we never hold your name or contact details, we cannot look you up. The only handle we have is the random identifier on your device, so to exercise a right you can either:

• do it yourself: deleting the app deletes the analytics identifier, so nothing further is linked to you, and existing events age out within 12 months; or
• ask us at peter@nuralingua.com. If you can tell us the approximate date you first installed the app and your device model, we will make reasonable efforts to locate and delete the matching events. For subscription records, include the App Store or Google Play order number and we will ask Adapty to delete the profile. We respond within one month.

We do not sell personal information and have not done so in the preceding 12 months, so there is nothing to opt out of under the CCPA.

If you are in the UK or EU and think we've handled your data improperly, you can complain to your local supervisory authority. In the UK that's the Information Commissioner's Office at ico.org.uk.

10Terms of Use and subscriptions

Act Up Pro is an optional auto-renewing subscription. The full terms, including the free tier, trial, renewal, cancellation and refund rules, are on our Terms of Use page. On iOS, Apple's Licensed Application End User License Agreement also applies.

11Changes & contact

If we change how data is handled, we'll update this page and the date at the top before the change goes live, and note it in the release notes. Earlier versions of this policy (before 23 September 2026) described an app with no analytics and no purchases; both were added in version 1.1.1.

Questions? We'd genuinely rather hear from you than not.