Privacy Policy

Effective date: March 28, 2025

Table of Contents

Round Tower Software Limited ("us", "we", or "our") operates Dyslexia.ai including our website, mobile applications, and related services (hereinafter collectively referred to as the "Service").

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

1. Definitions

• Service

  Service refers to Dyslexia.ai, including our website, mobile applications, and related services operated by Round Tower Software Studios Limited

• Personal Data

  Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

• Usage Data

  Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Cookies

  Cookies are small files stored on your device (computer or mobile device).

• Data Controller

  Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

  For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

• Data Processors (or Service Providers)

  Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

  We may use the services of various Service Providers in order to process your data more effectively.

• Data Subject (or User)

  Data Subject is any living individual who is using our Service and is the subject of Personal Data.

• Special Categories of Personal Data

  Certain types of personal data are considered "special" or "sensitive" under applicable privacy laws. This includes data related to health, biometric data, and information about children.

2. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email Address
• First Name and Last Name
• Date of Birth
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

When you access the Service, we may collect certain information automatically, including, but not limited to, the type of device you use, your device unique ID, IP address, operating system, browser type, unique device identifiers and other diagnostic data ("Usage Data").

Device Permissions

Our Service may request certain permissions on your device to function properly. These may include:

• Camera: Used for scanning text or documents for processing with our dyslexia tools
• Storage: Used to save and retrieve documents and settings
• Microphone: Used for voice input and text-to-speech functionality
• Notifications: Used to alert you about events, updates, or reminders
• Location: Used to provide location-specific services when explicitly requested

You can manage these permissions through your device settings. Denying certain permissions may limit the functionality of our Service.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.
• Analytics Cookies. We use these cookies to collect information about how you use our Service, monitor performance, and improve our Service.

3. Use of Data

Round Tower Software uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
• To personalize your experience and deliver content and product features relevant to your preferences and needs
• To process payments and manage subscriptions

In accordance with the principle of data minimization, we only collect and process the data necessary for these purposes.

4. Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA) or United Kingdom, Round Tower Software's legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Round Tower Software may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• For payment processing purposes
• To comply with the law

We will always be clear about which legal basis applies to each processing purpose.

5. California Consumer Privacy Rights (CCPA/CPRA)

If you are a California resident, you have certain rights regarding your personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These include:

• Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, our business or commercial purpose for collecting personal information, and the categories of third parties with whom we share personal information.
• Right to Delete: You have the right to request deletion of personal information that we have collected from you, subject to certain exceptions.
• Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information to third parties.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive personal information.

To exercise your rights under the CCPA/CPRA, please contact us at hello@dyslexia.ai. We will respond to your request within 45 days.

We do not sell your personal information as defined by the CCPA/CPRA.

6. Retention of Data

Round Tower Software will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Specifically, we retain different types of data for the following time periods:

• Account information: For as long as your account is active, plus 30 days after account closure
• Payment information: For 7 years for tax and accounting purposes
• Support communications: For 2 years after your last interaction with our support team
• Marketing preferences: Until you withdraw consent or unsubscribe

Round Tower Software will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

7. Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Ireland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Ireland and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Round Tower Software will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

For transfers to countries without an adequacy decision by the European Commission, we implement appropriate safeguards such as Standard Contractual Clauses approved by the European Commission.

8. Disclosure of Data

Business Transaction

If Round Tower Software is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Round Tower Software may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Round Tower Software may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Round Tower Software
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

9. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our security measures include:

• Encryption of data in transit using TLS/SSL protocols
• Encryption of sensitive data at rest
• Regular security assessments and penetration testing
• Access controls and authentication requirements for staff
• Regular security training for employees
• Incident response procedures

Data Breach Procedures

In the event of a personal data breach, we will notify affected users and relevant authorities without undue delay, and where feasible, within 72 hours of becoming aware of the breach, as required by applicable law.

10. Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

11. Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA) or United Kingdom, you have certain data protection rights. Round Tower Software aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at hello@dyslexia.ai.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. We will respond to your request within 30 days.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Data.

• The right of restriction. You have the right to request that we restrict the processing of your personal information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where Round Tower Software relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

12. Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We have data processing agreements in place with our service providers to ensure they comply with applicable data protection laws.

13. Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

• Firebase

  Firebase is analytics service provided by Google Inc.

  You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: here

  We also encourage you to review the Google's policy for safeguarding your data: here.

  For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: here

• Sentry

  We use Sentry to monitor and fix crashes and performance issues within our Service. Sentry may collect and use your data as described below:

  Types of Data Collected by Sentry

  • Error Data

    Sentry collects data related to application errors and crashes, including error messages, stack traces, and the conditions under which the error occurred.

  • Device Data

    Sentry collects information about your device, such as device model, operating system, and unique device identifiers.

  • User Data

    Sentry may collect information that helps identify you as a user, such as user IDs and email addresses, to provide better support and debugging.

  Use of Data by Sentry

  Sentry uses the collected data for the following purposes:

  • To monitor and diagnose application errors and crashes
  • To improve the stability and performance of our application
  • To provide customer support related to application issues

  Data Sharing and Transfer

  Sentry may share your data with third-party service providers to facilitate their services. Your data may be transferred to and processed in countries other than your own. Sentry ensures that appropriate safeguards are in place to protect your data during such transfers.

  Retention of Data

  Sentry retains your data only for as long as necessary to fulfill the purposes outlined in this addendum and to comply with legal obligations.

  For more information on Sentry's privacy practices, please visit their Privacy Policy.

14. Behavioral Remarketing

Round Tower Software uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

• Google Ads (AdWords)

  Google Ads (AdWords) remarketing service is provided by Google Inc.

  You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: here

  Google also recommends installing the Google Analytics Opt-out Browser Add-on - here - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: here

• Twitter

  Twitter remarketing service is provided by Twitter Inc.

  You can opt-out from Twitter's interest-based ads by following their instructions: here

  You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: here

• Facebook

  Facebook remarketing service is provided by Meta Platforms, Inc.

  You can learn more about interest-based advertising from Facebook by visiting this page: here

  To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: here

  Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

  For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: here

15. Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Apple Store In-App Payments

  Their Privacy Policy can be viewed here

  Manage your subscription here

  Request a refund here

• Google Play In-App Payments

  Their Privacy Policy can be viewed here

• Stripe

  Their Privacy Policy can be viewed here

• RevenueCat

  Their Privacy Policy can be viewed here

16. RevenueCat

We use RevenueCat to manage subscriptions and purchases within our Service. RevenueCat may collect and use your data as described below:

Types of Data Collected by RevenueCat

• Purchase Data

  RevenueCat collects data related to your purchases, including transaction receipts, product identifiers, and subscription status.

• Device Data

  RevenueCat collects information about your device, such as device model, operating system, and unique device identifiers.

Use of Data by RevenueCat

RevenueCat uses the collected data for the following purposes:

• To verify and manage your subscriptions and in-app purchases
• To provide customer support related to purchases
• To analyze purchase trends and improve our services

Data Sharing and Transfer

RevenueCat may share your data with third-party service providers to facilitate their services. Your data may be transferred to and processed in countries other than your own. RevenueCat ensures that appropriate safeguards are in place to protect your data during such transfers.

Retention of Data

RevenueCat retains your data only for as long as necessary to fulfill the purposes outlined in this addendum and to comply with legal obligations.

For more information on RevenueCat's privacy practices, please visit their Privacy Policy.

17. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

18. Children's Privacy

COPPA (Children Online Privacy Protection Act) & GDPR

When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) & GDPR puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of apps and online services must do to protect children's privacy and safety online.

Our Practices for Children's Data

For users under the age of 13:

• We require verifiable parental consent before collecting personal information
• We collect only the information necessary to provide the service
• We do not use children's data for marketing or advertising purposes
• We implement stronger security measures for children's data
• We do not share children's personal information with third parties except as necessary to provide the service

We adhere to the following COPPA & GDPR tenants:

Parents can review, delete, manage or refuse with whom their child's information is shared through contacting us directly, or via the Edit Profile section of our Service.

In order to remove your child's information please contact us at: hello@dyslexia.ai, or delete your data via the Edit Profile section of our Service.

19. Automated Decision-Making

Our Service may include features that use algorithms to provide personalized reading assistance based on your reading patterns and preferences. These may include:

• Text formatting recommendations based on your reading history
• Content recommendations based on your previous usage
• Personalized exercise suggestions to improve reading skills
• Reading level assessments and progress tracking
• Customized learning pathways

These automated processes are designed to improve your experience, but they do not have legal or similarly significant effects on you. You can control most personalization settings within the Service.

Under the GDPR, you have the right not to be subject to a decision based solely on automated processing if it produces legal or similarly significant effects. While our automated processes do not fall into this category, you can contact us at any time if you have concerns about how your data is being used for personalization.

20. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

21. Cookie Consent and Data Processing

Consent to the use of cookies

For our website to function properly we use cookies. To obtain your valid consent for the use and storage of cookies in the browser you use to access our website and to properly document this we use a consent management platform: CookieFirst. This technology is provided by Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH, Amsterdam, The Netherlands. Website: https://cookiefirst.com referred to as CookieFirst.

When you access our website, a connection is established with CookieFirst's server to give us the possibility to obtain valid consent from you to the use of certain cookies. CookieFirst then stores a cookie in your browser in order to be able to activate only those cookies to which you have consented and to properly document this. The data processed is stored until the predefined storage period expires or you request to delete the data. Certain mandatory legal storage periods may apply notwithstanding the aforementioned.

CookieFirst is used to obtain the legally required consent for the use of cookies. The legal basis for this is article 6(1)(c) of the General Data Protection Regulation (GDPR).

Data processing agreement

We have concluded a data processing agreement with CookieFirst. This is a contract required by data protection law, which ensures that data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

Server log files

Our website and CookieFirst automatically collect and store information in so-called server log files, which your browser automatically transmits to us. The following data is collected:

• Your consent status or the withdrawal of consent
• Your anonymised IP address
• Information about your Browser
• Information about your Device
• The date and time you have visited our website
• The webpage url where you saved or updated your consent preferences
• The approximate location of the user that saved their consent preference
• A universally unique identifier (UUID) of the website visitor that clicked the cookie banner

22. Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: hello@dyslexia.ai
• By mail: [Your Physical Address]

23. Data Protection Officer

For questions or concerns specific to data protection, you can contact our Data Protection Officer:

• By email: dpo@dyslexia.ai