Word Builder™ Privacy Policy

ReadingDoctor® Pty Ltd

Last updated: October 29th 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, advertising identifier, or any account information. The app uses two cloud features: a custom spoken voice, and AI pictures for some vocabulary words. Both receive only short text about the word being studied. AI pictures can be turned off in Settings. Recordings and pictures the app generates for a word are also shared with ReadingDoctor®’s asset library, described in section 3.3.

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 about the word being studied, generated recordings and pictures for that word, and proof that this installation is a genuine copy of Word Builder, as section 3 describes.

  • 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 on your device. Data leaves your device only in these cases: short text describing what is being studied, sent to the cloud features in section 3, and audio or pictures that Word Builder has generated for a word, which are shared with ReadingDoctor®’s asset library (section 3.3). To use that library, the app also sends proof that this installation is a genuine copy of Word Builder.

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 advertising identifier (IDFA)

  • 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

3.1 Custom spoken voice

Word Builder™ reads vocabulary words, definitions, and feedback aloud in a custom voice. The voice was recorded by the developer (Dr Bartek Rajkowski). No other person’s voice is used, and the app does not record or clone a voice while someone is using it.

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

What is not sent: any user identifier, account information, identifiers used for tracking, audio recordings, or any device data.

The speech service returns the audio. We do not authorise it to use the text for any other purpose.

When the iPad is offline, recordings included with the app still play. Other lines use Apple’s built-in voice, which runs on the device.

3.2 AI pictures

When “AI Images” is on in Settings (on by default), Word Builder™ can create an illustration for a vocabulary word. The app sends a short scene description (for example, “a red apple on a wooden table”) to an image service, which returns a picture.

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

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

The image service returns the picture. We do not authorise it to use the description for any other purpose.

Pictures are checked on the device before they are shown. A newly generated picture has a flag. Tapping the flag removes that picture from the device and sends the word and its sentence to ReadingDoctor® so we can review it. Pictures that have already been approved do not show the flag. Thumbs down removes the picture on this iPad only, and does not send a report.

To turn this off: open Settings and turn off “AI Images”. Words then show only the pictures included with the app.

3.3 ReadingDoctor® asset library

Word Builder™ checks ReadingDoctor®’s own asset library for recordings and pictures that are not already on the iPad. When Word Builder generates a new recording or picture that the library does not have, it uploads that file so ReadingDoctor® can check it and share it with other Word Builder users.

Uploads contain only the generated recording or picture, and the word, text, and settings used to make it. They never contain microphone audio, a child’s name or age, or any account details.

To stop misuse, each installation proves it is a genuine copy of Word Builder using Apple’s App Attest service. This creates a random key for that installation. On a Mac, where App Attest is not available, Word Builder instead sends Apple’s signed record showing it was obtained from the App Store, together with an identifier Apple provides for this app on that device. These are not advertising identifiers. They are used only to allow access to the library and to limit the number of requests.

When the iPad is offline, nothing is sent to the library. Deleting the app removes the copies stored on that device. Copies already shared with the library stay there so other Word Builder users can use them. They are not a record of a particular child.

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 the services in section 3:

  • 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 data that leaves the device is the text, recording, or picture for the word being studied, plus the install proof in section 3.3. It does not include the child’s name or a user account.

The spoken voice in section 3.1 is used whenever the iPad is online. AI pictures in section 3.2 are on by default and can be turned off in Settings. Turning AI pictures off does not change the spoken voice. When AI pictures are off, words show only the pictures included with the app.

5. Data we keep on the device

Your preferences (selected accent, theme, tile sets, audio settings, and whether AI pictures are on) stay on the device.

A local copy of a generated picture or recording is also kept on the device. A new one is uploaded to the asset library, as section 3.3 describes. Thumbs down removes that word’s picture on this iPad. Deleting the app removes the local copies.

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 the speech service, the short scene descriptions sent to the image service, the word and sentence sent to ReadingDoctor® when a generated picture is flagged, and the recordings and pictures uploaded to the asset library.

  • Data Not Linked to You: NSPrivacyCollectedDataTypeDeviceID, purpose NSPrivacyCollectedDataTypePurposeAppFunctionality. This is the App Attest key for this installation or, on a Mac, the identifier Apple provides with the App Store purchase record. It is used only to allow access to the asset library and to limit the number of requests.

  • 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 section 3 describes the services that receive any app-derived data.

  • GDPR / GDPR-K (European Union): Word Builder™ does not process personal data of any user. The vocabulary text sent to the speech and image services, the word and sentence sent when a generated picture is flagged, the files uploaded to the asset library, and the install proof in section 3.3 are not personal data as they are not attributable to an identified or identifiable child.

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