Privacy

Who we are

Wading is operated by Frozen Crow Inc. (“Frozen Crow”, “we”), 3744 E. Chapman Ave. Ste. #F12358, Orange, CA 92859, United States. For UK and EU data protection law we are the controller of the personal data described here. Contact us any time at privacy@lc.wading.ai.

The short version

We store your account, your conversations with Wade, the words you've met, and a short list of things Wade remembers about you so he can pick up where you left off. We send your conversation text — and, for spoken practice, short recordings of your voice — to Google's Gemini API, which generates Wade's replies. We don't sell your data, we don't share it with advertisers, and we don't use it to train AI models. We use PostHog analytics, including session recordings, to see how the site and the apps are used — what that covers is below. You can download a copy of everything, and delete everything, permanently, from the app.

What we collect, and why

Your account

Your email address, your first name, and a securely hashed password. If you sign in with Google we receive and store your Google account id, the email on it, your name and your profile picture URL — we ask Google only for your basic profile and email. Legal basis: performance of our contract with you.

Your learning

The full text of your conversations with Wade, including what you wrote, what he replied, and the gentle corrections he made — which quote what you originally wrote or how you pronounced something. Also every word you've met, the sentence you met it in, how well you know it, your immersion level, your chosen topics and how long you've practised. Also what Wade writes about your conversations — a name and a two-line summary for each one, and a short letter each month — and what you add yourself: messages you save, notes on words, words you've asked him to stop using, your reason for learning, and your settings. This is the product: without it Wade restarts from nothing every time. Legal basis: contract.

What Wade remembers about you

When a conversation ends, we send its last stretch to Google's Gemini API and ask it to note up to three durable facts about you — things you volunteered, like “has a sister in Lisbon” or “interviewing for a nursing job next month.” We keep at most 120 of these, and Wade sees them at the start of each conversation so he can ask about your life instead of starting cold.

Some of what people mention in a language lesson is sensitive — health, faith, politics, sexuality, money, grief, or facts about other people. Those are flagged when they're recorded. A flagged fact is still used in conversation (that's the point of a tutor who remembers you), but it is structurally excluded from choosing which sponsor you see — see the Advertising policy. Legal basis: contract; and for anything falling into a special category under GDPR Art 9, your explicit consent, given by choosing to tell Wade. You can see every one of them in the app under History → What Wade remembers, and remove any of them with Forget. Deleting your account erases all of it at once. You can also ask us to remove one for you.

Spoken practice

When you talk to Wade out loud, your microphone streams directly to Google — that live audio does not pass through our servers. Separately, your device records up to about twenty seconds of your most recent speech and sends that clip to us, and we forward it to Google to score how you sounded. We do not store the recording: it lives in memory for the length of that request and is never written to a database or disk. The transcript of what you said is stored with the rest of the conversation.

When you hold to dictate a message, your device records that clip — up to about thirty seconds — and sends it to us, and we forward it to Google to be written out as text. We don't store the recording or the text: the text goes back into your message box, and is only kept if you send it, as part of the conversation. If you give Wade a hint for how to say your name, that is stored with your settings and used in spoken practice.

Where you live

We ask for your country of residence — where you actually live, not where you happen to be — and, in the US, which state. Travelling doesn't change it. That answer decides which privacy law governs your account and which sponsors are allowed to reach you, so it isn't optional. It arrives pre-filled from your device's time zone, which is only ever a guess and will be wrong if you're away from home; you can correct it in Account at any time, and we'd rather you did than leave a guess standing. Until you answer we treat you as covered by the stricter European rules.

In the United States we also ask for your post code, and it's required there; outside the US it's optional. To be precise about what each one does: your country and statedecide which privacy law applies to you and which sponsors may lawfully reach you. Your post codeis used to match sponsors near you, and nothing else. Neither is ever sent to a sponsor. Legal basis: contract, and our legal obligation to honour the privacy law that applies where you live.

Election and campaign messages

Free accounts in the US may see sponsored messages from candidates and campaigns. By default these are untargeted: a campaign reaches you because of the state you live in, and we hold no information about your politics at all. You can decline the category outright in Account, and then you see none of them. Legal basis: our legitimate interest in funding the free plan, balanced against a choice to opt out that costs you nothing else.

Separately, you can switch on a questionnaire that lets campaigns be matched to your views. It is off unless you turn it on. It asks six questions about where you stand on issues like tax, regulation and immigration, plus which topics matter to you. We store those answers, the moment you switched it on, and the rough position we work out from them.

We deliberately don't display that position back to you in the app — shown a result, people tend to adjust their answers until it reads the way they would prefer, and we would be measuring self-presentation instead of opinion. It is still your data and you are still entitled to it: email privacy@lc.wading.ai and we will tell you what we hold, which is your six answers and the range they average to. You can change the answers or delete the lot at any time from Account.

Legal basis: your explicit consent, which is the only lawful basis there is for political opinions — a special category under GDPR Art 9 and sensitive personal data under US state laws. Switching it off withdraws that consent and deletes the answers and the position; we don't keep them behind a disabled switch. You can change your answers at any time.

Three things we do not do with any of this. We never send it to a campaign or anyone else — advertisers get counts, not people. We never show it to Wade, so it cannot influence a conversation or a lesson. And we never derive it from your conversations: it comes from that questionnaire and nowhere else, and nothing you say in a lesson adds to, changes or substitutes for it.

Device and technical data

If you turn on notifications we store a push token for that device — or, in a browser, its push subscription — with the hour you want the daily word, the days and quiet hours you choose, whether to hide the word's meaning, and whether you've switched reminders off altogether. If you tell us you're going away, we store the date you'll be back. We keep a list of your recent daily words and of any messages Wade has sent you, so you can look back at them. We store your time zone so the daily word and your daily limits land on your day, not ours. When you confirm at sign-up that you're 16 or older, we record when you did. Our hosting provider processes standard server logs, including IP addresses, to run and secure the service. Legal basis: contract, and our legitimate interest in keeping the service working and secure.

Billing

Payments are handled entirely by Stripe on Stripe's own pages. No card number ever reaches us. We send Stripe your email address and an internal account id; Stripe tells us your subscription status, plan, renewal date and its own customer id. Legal basis: contract and our legal obligation to keep financial records.

Who else sees your data

We do not sell your personal data, and we do not share it for cross-context behavioural advertising. These are the companies that process it on our behalf:

• Our AI provider — currently Google, via the Gemini API — generates every one of Wade's replies. It receives your first name, target language, your vocabulary list, the conversation itself, what Wade remembers about you, your local time, your reason for learning and how you'd like to be addressed if you've told us, and for spoken practice and dictation your audio, its transcripts and any hint you've given for saying your name. We use a paid API tier, under which the provider does not use your prompts or responses to train its models. If we change provider we will update this page before the change takes effect.
• Stripe — payments, as described above.
• Expo, and Apple or Google — deliver push notifications to the phone app. The daily-word notification contains the word itself (and its meaning, unless you choose to hide it), so it appears on your lock screen. If you have switched on messages from Wade, those travel the same way, never during the quiet hours you set.
• Your browser's push service (for example Google, Mozilla or Apple) — delivers browser notifications, only if you switch them on in a browser that supports them.
• PostHog — product analytics and session recordings on this website, in the web app and in the phone app. See Analytics below.
• Google Cloud and our database host — run the servers and store the data.
• LeadConnector (the GoHighLevel platform) — powers the in-app support chat and receives email you send to any of our addresses. It gets whatever you write to us, including anything you attach.

Analytics

We use PostHog to see how people use this website and the apps, so we can find what is confusing or broken. It keeps a random identifier in a first-party cookie and your browser's storage (on the phone, in the app's storage). Once you sign in, the apps link that identifier to your account id — never your name or email.

• On this website: which pages you visit (the path only, never the query string), taps on “Request access” and the monthly/yearly price switch, and session recordings of the page with anything you type masked.
• In the web app: page visits, a handful of named events — starting a conversation, ending a session, starting or solving a game, and similar — with counts but never what you wrote, and session recordings in which all text and everything you type are masked, so they show layout rather than words.
• In the phone app: the same events, and session recordings in which the conversation screen, the voice panel and anything you type are masked. Other screens — your words, Progress, History, Account — can appear in a recording as they look on screen.
• On our servers: what each AI request cost us, with no content.

We don't use any of this for advertising, there are no advertising pixels, and nothing follows you to other websites. On this website and in the web app we honour your browser's Do Not Track setting. Legal basis: our legitimate interest in keeping the service working and improving it.

Each of these is bound by contract to use your data only to provide their service to us. We are a US company and our servers are in the United States, so data from the UK and EU is transferred to the US under the UK/EU Standard Contractual Clauses. Ask us and we'll send you a copy.

How long we keep it

• Your account, conversations, vocabulary and memories: until you delete them, or you delete your account.
• Resetting a language erases that language's words and sessions immediately.
• Financial records: retained as long as tax and accounting law requires, typically seven years, mostly held by Stripe.
• Anonymised cost and advertising records: kept indefinitely — see the next section.

Deleting your account

Account → Careful → Delete my account, in the app on any platform. You type your email address to confirm, and it happens immediately and permanently: your account, conversations, vocabulary and everything Wade remembers are erased, and any active subscription is cancelled so you are never billed again. Nobody can restore it afterwards, including us.

Two things survive deletion, and both are stripped of any link to you first:

• What the AI cost us — token counts and money, no content. This is our accounting.
• Advertising delivery counts — so reports we already gave sponsors don't retroactively change.

In both cases your account id is replaced with a random token that is stored nowhere else, so those rows cannot be traced back to you.

We also keep our internal log of administrator actions — who did what to which account. That log exists to hold us accountable, and letting account deletion erase it would make deletion a way to destroy evidence of misuse.

Your rights

You can download a copy of everything Wading holds about you, as one file, from Account → Download my data. Wherever you live, you can also ask us to give you a copy of your data, correct it, delete it, or object to how we use it — and we won't treat you worse for asking. Email privacy@lc.wading.ai and we'll respond within 30 days.

If you are in the UK or EU (GDPR): you have the rights of access, rectification, erasure, restriction, objection and portability, and the right to withdraw consent at any time without affecting what we did before you withdrew it. You can complain to your national supervisory authority, or to the UK ICO.

If you are in a US state with a privacy law (California, Virginia, Colorado, Connecticut, Texas, Oregon, Maryland and others): you have rights to know, access, correct, delete and to opt out of the sale or sharing of your personal information and of targeted advertising. We do none of those things — we do not sell or share personal information, and our sponsor messages are chosen by our own servers without sending anything about you to any advertiser or ad network. If we ever deny a request you may appeal it by replying to our decision; we'll give you a written answer.

Children

Wading is for adults. You must be at least 16 to use it, and signing up asks you to confirm that you are. We do not knowingly collect data from children. If you believe a child has an account, email us and we'll delete it.

Security, and being honest about it

Passwords are stored hashed, never in plain text. Traffic is encrypted in transit. Access to production data is limited to administrators, and every administrative action on an account is logged. No system is perfectly secure, and we won't pretend otherwise — if a breach affects you, we will tell you and the relevant regulator within the timeframes the law requires.

Changes

If we change how we use your data in a way that matters, we'll update the date at the top of this page and tell you in the app before the change takes effect.