Word Builder™ Privacy Policy

ReadingDoctor® Pty Ltd

Last updated: July 10th 2026

Word Builder™ is a phonics teaching app. We do not track you. We do not sell your data. We do not show ads. We do not collect your name, email, location, contacts, microphone audio, camera images, device identifiers, or any account information. The app uses two cloud features by default: custom-voice text-to-speech (ElevenLabs) and AI vocabulary images (Runware), which receive only the vocabulary word being studied. Both can be turned off in Settings. A third, on-demand feature (tapping the “flag this word” icon on a card) sends the flagged word to a developer-only endpoint so we can improve the word list.

1. About this notice

This notice governs the Word Builder™ iOS app. It is a product-specific privacy notice and stands alone from the general ReadingDoctor® privacy policy that covers our website, the ReadingDoctor® Online teaching platform, and our other business interactions.

  • Word Builder™ (this notice): the iOS app. Zero user accounts, zero analytics, zero tracking; the only data that leaves the device is short text describing what is being studied, and only when the optional cloud features in section 3 are enabled.

  • General ReadingDoctor® privacy policy (readingdoctor.com.au/privacypolicy): covers the website, the ReadingDoctor® Online platform (which uses accounts and roster data), and general company data-handling practices (marketing communications, complaints handling, GDPR / Australian Privacy Principles rights, OAIC escalation, etc.).

Where the two overlap (corporate identity, complaint handling, statutory rights of access and correction), this notice defers to the general policy and links to the relevant section. Where they diverge (what actually leaves the device, and who receives it), this notice is the authoritative document for the Word Builder™ app.

2. What data leaves your device

Word Builder™ runs entirely on your device. The only data that ever leaves your device is short text describing what is being studied (typically a single vocabulary word, sometimes with its dictionary definition or a short correction prompt), and only when one of the three optional cloud features described in section 3 is used.

We never collect or transmit:

  • your name, email address, phone number, or postal address

  • your account information or any login credentials

  • microphone audio, camera images, or video

  • your contacts, calendar, photos, or files

  • your device identifier (IDFA / IDFV / advertising ID)

  • your IP address (beyond what is needed to route the API request)

  • your location

  • usage analytics or behavioural data

We do not use third-party analytics, advertising, or tracking SDKs.

3. Cloud features and sub-processors

3.1 Custom-voice text-to-speech (ElevenLabs)

When the “Use Cloned Voice” setting is enabled (on by default for internet-connected devices), Word Builder™ synthesises spoken vocabulary words, definitions, and feedback using a custom voice hosted at ElevenLabs (elevenlabs.io). The voice is a custom voice cloned from the developer’s (Dr Bartek Rajkowski’s) own voice recordings. No third-party voice talent is involved, and the app does not clone voices at runtime or upload any user audio.

What is sent to ElevenLabs: the short text to be read aloud (a vocabulary word, its definition, or a short correction prompt).

What is not sent to ElevenLabs: any user identifier, account information, IP-address-derived identifiers used for tracking, audio recordings, or any device data.

ElevenLabs’ own privacy policy is available at elevenlabs.io/privacy-policy. They process the text on our behalf to return synthesised audio; we do not authorise them to use it for any other purpose.

To disable: open Settings (gear icon, top-right of the main menu) and turn off “Use Cloned Voice”. When disabled, the app uses Apple’s built-in system text-to-speech voice, which runs entirely on-device.

3.2 AI vocabulary images (Runware)

When the “Runware AI Images” setting is enabled (on by default for internet-connected devices), Word Builder™ generates educational illustrations for vocabulary words using Runware (runware.ai). The app sends a short scene description (for example, “a red apple on a wooden table”) to Runware’s image generation API, which returns an image.

What is sent to Runware: a short scene description in plain English, derived on-device from the vocabulary word being studied.

What is not sent to Runware: any user identifier, account information, IP-address-derived identifiers used for tracking, the child’s name or age, photos, or any device data.

Runware’s own privacy policy is available at runware.ai/privacy. They generate the image on our behalf and return it; we do not authorise them to use the prompts for any other purpose.

Generated images are passed through on-device quality and safety checks before they are shown to the student. Every image also has a flag icon that you can tap to report the image; flagged images are discarded immediately and never shown again on that device.

To disable: open Settings (gear icon, top-right of the main menu) and turn off “Runware AI Images”. When disabled, vocabulary words show only the hand-curated pictures bundled with the app.

3.3 Word / image flagging (developer endpoint on Google Apps Script)

When you tap the flag icon on a vocabulary card to report a word or an image that looks wrong, the app sends the flagged item plus a short optional note to a developer-only endpoint hosted on Google Apps Script (script.google.com). This is not a Google user-analytics or advertising service. It is a private Apps Script owned and operated by ReadingDoctor® Pty Ltd that appends the flag to an internal review sheet used to improve the word list and image library.

What is sent to the flagging endpoint: the flagged word or image identifier, an optional short note you may type in the flag dialog, and an app version string (for triage).

What is not sent: any user identifier, account information, IP-address-derived identifiers used for tracking, the child’s name or age, or any other device or personal data.

Google Apps Script’s underlying data-handling is governed by Google’s standard privacy policy at policies.google.com/privacy.

To disable: this endpoint is contacted only when you explicitly tap the flag icon on a card. Simply do not tap the flag icon to opt out.

4. Children’s data

Word Builder™ is designed for use in speech-language pathology clinics, other intervention settings, classrooms, and at home with children. We have designed the app so that no information about the child reaches us or our sub-processors:

  • The app does not ask for the child’s name, age, school, or any identifying information.

  • The app does not contain a user-account system; there is nothing to sign in to.

  • The only data that leaves the device is the vocabulary word or image identifier being studied or flagged (when the features in section 3 are used), not who is studying it.

The cloud features described in sections 3.1 and 3.2 are enabled by default and can be turned off at any time in the on-device “Settings” sheet, which is password-protected for educator/parent use so the child cannot re-enable them once disabled. The child sees the same vocabulary cards either way; only the voice (ElevenLabs vs system TTS) and pictures (Runware vs bundled artwork only) differ.

5. Data we keep on the device

The following data is stored only on the device, never on our servers or our sub-processors’ servers:

  • your preferences (selected accent, theme, tile sets, audio settings, AI feature toggles)

  • the most recently generated AI images (cached so the same word does not need to be regenerated; cleared when you clear the AI image cache in Settings or uninstall the app)

6. App Store privacy details

Word Builder™ declares to Apple, via its App Store privacy “nutrition label” and its in-bundle PrivacyInfo.xcprivacy manifest, that:

  • Data Linked to You: none.

  • Data Not Linked to You: NSPrivacyCollectedDataTypeOtherUserContent, purpose NSPrivacyCollectedDataTypePurposeAppFunctionality. This covers the vocabulary text sent to ElevenLabs, the short scene descriptions sent to Runware, and the flagged items and optional notes sent to the developer endpoint on Google Apps Script.

  • Data Used to Track You: none.

We have no tracking SDKs, no ad SDKs, and no third-party analytics. The NSPrivacyTrackingDomains array in the manifest is therefore empty. The only Required Reason API declared is UserDefaults (NSPrivacyAccessedAPICategoryUserDefaults, reason code CA92.1), used for on-device preferences.

7. Children’s privacy laws

Word Builder™ does not knowingly collect any personally identifiable information from any user, including children under 13. The app is listed in the Education category and is intended to be used under the supervision of a parent, teacher, or reading specialist.

  • Australian Privacy Principles: Word Builder™ is developed in Australia by ReadingDoctor® Pty Ltd (ABN 98 120 961 971). We comply with the Australian Privacy Act 1988 and the Australian Privacy Principles.

  • COPPA (United States): Word Builder™ does not collect personal information from children under 13. The cloud features described in section 3 do not involve a user account and do not collect any information about the child.

  • FERPA (United States): Word Builder™ does not collect, store, or transmit any education records as defined by 20 U.S.C. 1232g. There are no student records to receive; the app cannot act as a “school official” under FERPA because there is no record system to be given access to.

  • SOPPA / state student-data laws (United States): The app does not collect covered information under Illinois SOPPA, California AB-1584, New York Education Law 2-d, or similar state student-data privacy laws. ReadingDoctor® Pty Ltd is prepared to sign a compliant Data Privacy Agreement (DPA) with any US school district using Word Builder™. Please contact us at the address in section 9.

  • Student Privacy Pledge (United States): The data practices used by Word Builder are consistent with the Student Privacy Pledge 2020: we do not sell student personal information, we do not use student data for targeted advertising, we do not build personal profiles of students, and we disclose the sub-processors that receive any app-derived data (see section 3).

  • GDPR / GDPR-K (European Union): Word Builder™ does not process personal data of any user. The vocabulary text sent to ElevenLabs and Runware, and the flagged items sent to the developer endpoint, are not personal data as they are not attributable to any identified or identifiable individual.

For statutory rights of access, correction, deletion, or complaint (under the APPs, GDPR / GDPR-K, or comparable US student-data laws), see the general ReadingDoctor® privacy policy at readingdoctor.com.au/privacypolicy sections 10 to 13 for the current escalation procedure and OAIC contact details. Requests specific to the Word Builder™ app can be sent to the contact address in section 9 below; because we do not collect personal information through the app there is typically no personal data to access or delete on our servers.

8. Changes to this policy

We will update this policy when the data flowing out of the app changes. Material changes will be announced via the App Store release notes for the version that introduces them.

9. Contact

ReadingDoctor® Pty Ltd
ABN 98 120 961 971
69 Goodwood Rd, Wayville SA 5034, Australia
Phone: 1300 66 99 40
Product support: support@readingdoctor.com.au
General privacy enquiries: enquiry@readingdoctor.com.au
Website: readingdoctor.com.au