(Last revised on April 9 2021 )




At RoxyPenguin, we care about your personal information, so we have prepared this privacy policy (our “Privacy Policy”) to explain how we collect, use and share it.


RoxyPenguin is a mobile and web learning service offered by Serhiy Krynytskyy (“Serhiy Krynytskyy”). Our services include a wide variety of content, courses and learning games and exercises, designed to facilitate learning of a wide range of subjects which are available as an iOS application available to download on mobile or tablet devices (“App”), and from our website (“Website”), or any other device , whether invented or to be invented, by which you can access our content, courses, games and exercises, collectively being our services to you (“Services”).


By using or accessing the Service, you agree to the terms of this Privacy Policy.


We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website or App and we will indicate the date these terms were last revised at the top of the Privacy Policy. Any revisions to this Privacy Policy will become effective the earlier of the first time you access or use the Service after any such changes.


This Privacy Policy explains what personal data (as defined below) we collect through the Services, how we use and share that data, and your choices concerning our data practices.


This Privacy Policy forms part of our Terms of Use, which are available at


By providing us with your personal data when using the Services, you consent to the processing of your personal data as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services.


1. Personal Data That We Collect


When you interact with our App or Website, in order to use our Services, we don't require information that, alone or in combination with other information, could be used to identify you (“Personal Data”), for example, name, email address, username, profile picture.


When you use the Services, you may generate learning data such as test answers, learning courses, words, learning progress, scores, which is stored locally on your Device or, additionally, on your iCloud (if you have it enabled in Premium version), we don't have access to this data. Only you have access to this local data base via our App installed on your Device.


We also collect information you choose to provide to us when you complete any “free text” boxes in our forms (for example, "feedback" form or "contact us" form). In addition, we may collect Personal Data disclosed by you on our forums, blogs and our other areas of the Services to which you can post information and materials.


We may also collect non-Personal Data, such as your time zone or language.


Automatically Collected Data: When you use the Services, the following information is created and automatically logged in our systems:


·       Log data: Information (“log data”) that the Apps automatically send when you use them.


·       Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.


·       Usage Information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities.



2. How We Use Data


We use the data we collect, described above:


·       To provide the Services, process transactions and respond to your requests. For users located within the EU , this use is necessary to perform the contract with you.


·       As necessary for certain legitimate business interests, which include the following:


o   To customize the learning experience and degree of difficulty to our users’ level and needs.


o   To better understand how visitors interact with our Website and App and ensure that our Website and App are presented in the most effective manner for you, and as part of our efforts to keep our Website and App, network and information systems secure.


o   To conduct analytics to inform our marketing strategy and enable us to enhance and personalize our communications and the experience we offer to our users.


o   To provide communications by email which we think will be of interest to you.


·       To conduct or assist research, and prepare scholarly papers. We may share the information we collect in anonymized and de-identified form with researchers who help us to improve the Service’s learning tools. We may also use such information to publish papers on language learning.


·       Marketing. We will send you updates and information about our new products and services, upcoming events or other promotions or news by email or push notification. Where required by law, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you or by updating your user settings. In addition, if at any time you do not wish to receive future marketing communications, please contact us at We will continue to contact you via email regarding the provision of our Services and to respond to your requests.


If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing.


We may anonymize, de-identify and/or aggregate the information that we collect and use such anonymized, de-identified and/or aggregated data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners.


For information on your rights under the applicable European Union (“EU”) law, please see the “Rights under EU Law” section below.


3. Sharing And Disclosure

We may share your Personal Data and other information with certain third parties in the following circumstances:


·       Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions your Personal Data may be shared with third-party providers of hosting, email communication and customer support services, analytics, marketing, advertising (including Amazon Web Services and Google in the United States, both certified to the Privacy Shield). For more details on the third parties that may place cookies through the Website, please see the “Cookies” section below. Following our instructions, these parties may access, process or store Personal Data in the course of performing their duties for us.


·       Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of a service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction.


·       Legal Requirements: If required to do so by law, applicable regulation or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of RoxyPenguin, (iii) act in urgent circumstances to protect the personal safety of users of the Apps, or the public, or (iv) protect RoxyPenguin against legal liability.


·       Advertisements: Our mobile app may incorporate advertisements from third-party networks or platforms. These ads are essential for supporting the free availability of our app and ensuring its continued development and improvement. The third-party ad networks may collect certain information such as device identifiers, IP addresses, and geolocation data to provide more relevant ads to users. However, we do not directly control the data collected by these networks and platforms. We recommend reviewing the privacy policies of these third parties to understand their data collection and usage practices. Please note that opting out of personalized advertising within the app may result in seeing generic or less relevant ads. We strive to work with reputable ad networks that prioritize user privacy and comply with industry standards. However, we cannot guarantee the practices of these third parties. Therefore, we encourage users to exercise caution and take appropriate measures to protect their personal information while interacting with ads in our mobile app.


4. Data Retention


We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.


5. Update Your Information


If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us at We will address your request as required by applicable law.


As we don't keep any of your Personal Data on our servers, except those, which you shared with us through communication channels, you can manually delete Data Base from your device by deleting the App from your iOS system. This will completely delete Data Base. Also, if you were using iCloud Data Base backup functionality - you can delete all backups in your iCloud account.



6. Rights Under EU Law


Scope. This section provides information on your rights under EU law (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway).


Data Controller. Serhiy Krynytskyy is the data controller for your Personal Data.


Your Rights. Subject to EU law, you have the following rights in relation to your Personal Data:


·       Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.


·       Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.


·       Right to erasure: You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.


·       Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.


·       Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.


·       Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:

o   If we are relying on a legitimate interest (described under the “How We Use Data” section above) to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing; or

o   If we are processing your Personal Data for direct marketing.


·       Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.


·       Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.


·       Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.


You may contact us to exercise your rights at


Legitimate Interest. “Legitimate interests” means our interests in conducting our business, managing and delivering the best Services to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.


Changes. We will notify you of changes to the data processing activities described in this Privacy Policy by posting a prominent notice on the Website or the Apps or as otherwise required by law.


7. Publicly Posted Information


This Privacy Policy shall not apply to any information you post to the public areas of the Services. This includes, but is not limited to comments on the RoxyPenguin blog or public forums. Comments posted to public areas may be viewed, accessed, and used by third parties subject to those parties’ privacy practices and policies.


8. Children

At all times Serhiy Krynytskyy does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Serhiy Krynytskyy through the Services please contact us at and we will endeavor to delete that information from our databases.



9. Links to Other Websites


The Website and App may contain links to other websites not operated or controlled by us (“Third Party Sites”), including social media websites and services. The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of such Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact those sites directly for information on their privacy practices and policies.


10. Security


We take reasonable administrative and technical steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure. Therefore, while we strive to protect your data, we cannot guarantee its absolute security.


11. Changes To Our Privacy Policy


We may change this Privacy Policy at any time and when we do we will post an updated version on this page. By continuing to use the Website and App or providing us with information after we have posted an updated Privacy Policy you consent to the revised Privacy Policy and practices described in it.


12. Contact Us


If you have any questions about our Privacy Policy or our data practices, please contact us at