Privacy Policy

This Privacy Policy explains how EvoHuman Ltd ("EvoHuman", "we", "us") collects, uses, and shares information in connection with First Words (the "Service"). First Words is a product operated by EvoHuman Ltd.

1. Who we are

Controller: EvoHuman Ltd, registered with the Information Commissioner's Office (ICO), registration number ZC254921. Contact: privacy@evohuman.co.uk / hello@evohuman.co.uk.

2. Information we collect

• Account & contact data — name, email, and similar details you provide.
• Usage data — app interactions, device type, OS version, crash logs, and diagnostics.
• Purchase data — if you buy features via Apple or other stores, we receive limited transaction status (not full payment card details).
• Content you submit — messages, inputs, or files you choose to provide within the Service.

3. How we use information

• Provide, maintain, and improve the Service
• Personalise experience and measure performance
• Communicate about updates, security, and support
• Comply with legal obligations and enforce our Terms

4. Legal bases (UK GDPR)

Where UK GDPR applies, we process personal data on the bases of contract performance, legitimate interests (operating and improving a secure product), consent (where required), and legal obligation.

5. Sharing

We may share data with infrastructure and analytics providers who process it on our instructions, with professional advisers, or when required by law. We do not sell personal data.

6. International transfers

If data is processed outside the UK/EEA, we use appropriate safeguards such as standard contractual clauses where required.

7. Retention

We retain information only as long as needed for the purposes above, then delete or anonymise it, unless a longer period is required by law.

8. Security

We apply reasonable technical and organisational measures. No method of transmission or storage is perfectly secure.

9. Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, or object to processing, and to data portability. You may also lodge a complaint with the UK ICO. Contact us to exercise rights.

10. Children

The Service is not directed to children under 13 (or the minimum age required in your country). We do not knowingly collect such data.

11. Apple App Store note

If you download First Words from the Apple App Store, Apple's terms and privacy practices also apply to the extent of their role as platform provider.

12. Changes

We may update this Policy and will revise the effective date above. Continued use after changes means you acknowledge the updated Policy.

13. Contact

Privacy questions: privacy@evohuman.co.uk.