DAILY WORD PRIVACY POLICY

Daily Word is an educational Android mobile application developed by Unplugged Technologies Ltd. ("Unplugged," "we," "us," or "our").

Daily Word is designed to demonstrate the breadth of information that a mobile application may be capable of obtaining from an Android device. The App collects information that is available to it through ordinary Android application functionality and permissions so that users and organizations conducting assessments can see and better understand the information that a mobile application may be capable of accessing.

This Privacy Policy explains what information Daily Word may collect, where that information is sent, who may have access to it, how long it is retained, and the choices and rights available to users.

1. How Daily Word Works

Daily Word accesses information made available to it through standard Android application functionality and interfaces, including information generally available to Android applications and information made available through permissions that you expressly grant on your device.

Daily Word is not designed to exploit vulnerabilities, bypass Android protections, circumvent operating-system permissions, or otherwise obtain unauthorized access to your device.

The information collected by Daily Word is transmitted to a centralized management server associated with the applicable assessment.

Depending on how the assessment is configured, that server may be hosted and managed by Unplugged, or hosted and managed by the company, research institution, organization or other entity conducting the assessment (an "Assessment Organization"). The applicable configuration should be disclosed to participants as part of the assessment.

2. Information Daily Word May Collect

The information collected by Daily Word is intentionally broad because the purpose of the App is to demonstrate the scope of information that may be available to an ordinary mobile application. The information is nevertheless limited to information available through standard Android application functionality or through access expressly permitted by the user through the mobile operating system.

Depending on your device, Android version, settings and permissions, Daily Word may collect information including:

·      hardware and software information about your device;

·      device and application identifiers accessible to the App;

·      operating-system and device configuration information;

·      wireless-network information;

·      Bluetooth information, including information concerning nearby devices where made available to the App;

·      IP-address information;

·      GPS-based or other location information;

·      physical-sensor information, such as movement, orientation, light or pressure information;

·      information concerning installed applications;

·      clipboard contents;

·      information made available through permissions you grant to Daily Word;

·      personally identifiable information contained within or derived from information exposed to the App; and

·      other information of a similar nature made available to the App through standard Android functionality, APIs, or permissions granted by the user.

Clipboard and Other Sensitive Information

Some information available to Daily Word may contain sensitive or highly personal information. In particular, clipboard contents depend entirely on what you or another application has placed on the clipboard and may potentially contain messages, email addresses, authentication codes, account information, financial information, health information or other sensitive content.

Location information and certain device identifiers may also constitute sensitive or protected information under applicable law.

Daily Word does not collect such information for advertising, profiling or marketing purposes. It collects it as part of the App's educational function of demonstrating what information may be available to a mobile application.

You should not intentionally place passwords, payment-card information, authentication credentials, health information or other sensitive information onto your clipboard for the purpose of testing Daily Word.

Account and Access Information

Daily Word may create or use an account identifier, such as a unique code, email address, phone number, or other identifier, together with associated device or authentication information necessary to provide access to the applicable assessment and associated device data.

3. Information Daily Word Does Not Intentionally Access

Daily Word declares no Android storage or media permissions, and Android therefore blocks the App from accessing photographs, videos and files through those permission paths. Daily Word does use the camera for the limited purpose of scanning the enrollment QR code. The App does not capture or save photographs or video as part of that process.

4. Where Your Information Is Sent

Information collected by Daily Word is transmitted to the centralized management server configured for the applicable assessment.

Unplugged-Hosted Assessments

For certain users, smaller organizations, researchers or other assessments, Unplugged may operate the centralized management server.

Where Unplugged hosts the server, collected information is stored using cloud infrastructure selected and managed by Unplugged. The underlying storage used for Unplugged-hosted deployments uses encryption at rest.

Data transmitted from the Daily Word mobile App to the configured management server is protected using HTTPS with TLS version 1.2 or later. Cleartext HTTP is disabled in the App build, and the App refuses connections to non-HTTPS server addresses.

Organization-Hosted Assessments

In many cases, the Assessment Organization will operate the centralized management server within its own infrastructure or environment.

In those circumstances, the Assessment Organization controls the server environment, its security configuration, its storage practices, and the persons authorized to administer it.

Unplugged does not control the Assessment Organization's infrastructure and cannot guarantee that an organization-hosted server uses encryption at rest unless the Assessment Organization separately implements it.

If you are participating in an organization-hosted assessment, questions concerning the Assessment Organization's own use, security or retention of information should be directed to that organization.

5. Who Can Access the Information

An individual user can access the records associated with that user's device through the credentials or access mechanism provided for the applicable assessment. A user may also voluntarily provide an access URL or credentials to another person. Users are responsible for protecting their credentials and should not share them unless they intend to provide access to their information.

The administrator of the centralized management server may have access to information collected from all devices managed by that server.

A management server may also be divided into separate tenants or teams. Where tenant functionality is used, a Tenant Administrator may have access to information associated with devices within that tenant but not information associated with other tenants.

For an Unplugged-hosted assessment, the collected information is not encrypted with a per-device or customer-generated key that prevents Unplugged from accessing its contents. Authorized Unplugged operational and support personnel may access the information when reasonably necessary to operate, maintain, troubleshoot or support the service. For an organization-hosted assessment, administrators designated by the Assessment Organization may have access to information collected through the assessment.

6. How We Use Information

Where Unplugged operates the Daily Word management service, information collected through Daily Word is used to:

1.     provide the Daily Word educational and assessment functionality;

2.     allow users to see information collected from their devices;

3.     allow authorized administrators to manage the applicable assessment;

4.     operate, secure, troubleshoot and maintain the service;

5.     respond to support requests;

6.     detect and prevent unauthorized access, abuse or security incidents; and

7.     comply with applicable legal requirements.

7. Assessments Conducted by Other Organizations

Daily Word may be used by companies, research institutions or other organizations to conduct an assessment.

Where an Assessment Organization determines why an assessment is being performed, which devices or users participate, who may access the results, and how the information will be used, that organization may be independently responsible for its processing of personal information under applicable privacy law.

Where Unplugged hosts the Daily Word service solely on behalf of such an organization, Unplugged may process the applicable assessment information on behalf of that organization and subject to its instructions.

The Assessment Organization is responsible for providing any additional notices, obtaining any permissions or consents, and establishing any lawful basis required for its own assessment and use of the resulting information.

Where the Assessment Organization operates the management server itself, the Daily Word mobile App communicates only with that customer-hosted management server. The App does not send assessment data to Unplugged and does not include third-party analytics or other third-party SDKs. Information may still be separately provided to Unplugged by the Assessment Organization for support, troubleshooting or another expressly disclosed purpose.

Two optional server-side services may perform IP-based or Wi-Fi-based geolocation lookups to demonstrate how a location can be inferred from this information. If enabled, the relevant IP address and/or Wi-Fi network information needed to perform the lookup may be transmitted by the management server to an external geolocation service, which returns an estimated location for display as part of the assessment. For on-premises deployments, both lookups are disabled by default and are enabled only with the Assessment Organization's agreement.

8. Legal Bases for Processing

Where applicable privacy or data protection laws require us to identify a legal basis for processing, the applicable basis depends upon the circumstances.

For assessments that an individual chooses to conduct directly through an Unplugged-hosted service, processing may be necessary to provide the service requested by that individual.

Where particular device access requires consent, Daily Word relies on the user's affirmative permission or consent as required by applicable law and platform requirements.

We may process limited operational and security information where necessary for our legitimate interests in operating and securing the service, provided those interests are not overridden by applicable individual rights.

Where Daily Word is used as part of an assessment conducted by another organization, that organization is responsible for determining the legal basis applicable to its processing. Where Unplugged acts solely as a processor for that organization, Unplugged processes the applicable information in accordance with the organization's documented instructions and applicable law.

9. Service Providers

Where Unplugged hosts the centralized management server, we use third-party infrastructure providers to operate the service, including Oracle cloud infrastructure. The Daily Word mobile App does not include third-party analytics, advertising, attribution or other third-party SDKs.

Such providers process information only as necessary to provide services to Unplugged and subject to applicable contractual and security requirements. If an optional IP-based or Wi-Fi-based geolocation lookup is enabled for an assessment, the management server may transmit the relevant IP address and/or Wi-Fi network information needed to perform the lookup to an external geolocation service solely to obtain the corresponding estimated location for display as part of the assessment.

We do not authorize our service providers to use Daily Word assessment data for advertising or independent marketing purposes.

10. Retention and Deletion

Unplugged-Hosted Assessments

For centralized management servers hosted by Unplugged, assessment data stored on the management server is deleted within 30 days after the applicable assessment period ends.

User-Initiated Deletion

Individual users may initiate deletion of the information associated with their device through the Daily Word mobile application. This functionality is intended to apply both to Unplugged-hosted management servers and to management servers operated by Assessment Organizations.

Users may also contact support@unplugged.com if they require assistance with a deletion request concerning an Unplugged-hosted assessment.

Organization-Hosted Assessments

Where the centralized management server is operated by an Assessment Organization, retention and deletion are controlled by that organization, subject to the Daily Word functionality available to individual users and the organization's contractual obligations.

Organizations conducting an assessment using a self-hosted Daily Word management server are required under Unplugged's applicable service terms to terminate the applicable assessment server or instance no later than 14 days after the assessment period ends, unless a different retention period has been expressly agreed or retention is required by applicable law.

11. Account Deletion

Where Daily Word creates an application account, users may request deletion of that account and associated data through the deletion functionality provided within Daily Word.

Where an Unplugged-hosted account is involved, users may also contact support@unplugged.com for assistance.

Deletion requests do not require a user to continue using or reinstall Daily Word solely in order to request deletion.

Where applicable law requires limited information to be retained for security, fraud-prevention, legal or regulatory purposes, we may retain only that information for the applicable period.

12. No Sale, Advertising or Unrelated Commercial Use

Unplugged does not sell Daily Word personal information.

Unplugged does not share Daily Word personal information for cross-context behavioral advertising or targeted advertising.

Daily Word does not contain advertising.

Unplugged does not use Daily Word assessment data for marketing, generating sales leads, data brokerage, behavioral profiling, training artificial-intelligence or machine-learning models, or developing unrelated commercial products.

This restriction also applies to aggregated and de-identified assessment data: Unplugged does not use Daily Word assessment data for product analytics, research, service improvement, or AI / machine-learning model training.

13. Your Privacy Rights

Depending on your jurisdiction and the entity responsible for the applicable processing, you may have rights including rights to request access, correction, deletion, restriction of processing, portability, objection to certain processing, and withdrawal of consent where consent is the applicable legal basis.

For information processed by Unplugged in connection with an Unplugged-hosted assessment, requests may be submitted to support@unplugged.com.

If an Assessment Organization controls the relevant information, we may direct you to that organization or assist it in responding to your request where required.

Nothing in this Policy limits rights available under applicable law.

14. International Users and Transfers

Daily Word may be made available worldwide. Where Unplugged hosts the service, our service providers and infrastructure may process information in countries other than the country in which you live.

Where applicable law requires safeguards for international transfers of personal information, Unplugged will use legally recognized transfer mechanisms or other safeguards permitted by applicable law.

Users in the European Economic Area, United Kingdom and other jurisdictions may have additional rights under applicable data-protection law, including rights of access, correction, deletion, restriction, portability, objection and withdrawal of consent, subject to applicable conditions and exceptions.

15. United States Privacy Rights

Residents of certain U.S. states may have additional rights under applicable state privacy laws, including rights to access, delete, correct or obtain a copy of certain personal information and, where applicable, to opt out of certain uses of personal information.

Daily Word does not sell personal information and does not share personal information for cross-context behavioral advertising or targeted advertising.

Where applicable law provides a right to appeal a decision concerning a privacy request, you may submit an appeal to support@unplugged.com and identify your request as a "Privacy Rights Appeal."

For California residents, to the extent California privacy law applies to Unplugged, the categories of personal information Daily Word may collect include identifiers; internet or other electronic network activity information; geolocation data; sensory or other electronic information; and sensitive personal information, depending on the information made available by the device, Android version, settings and permissions. The specific information within those categories is described in Section 2 above.

16. Children

Daily Word is intended for persons aged 18 and older. We do not knowingly offer Daily Word directly to children under 18.

If you believe information concerning a child has been collected through an Unplugged-hosted Daily Word assessment in circumstances not permitted by applicable law, contact support@unplugged.com.

17. Security

Where Unplugged hosts Daily Word, we use technical and organizational measures designed to protect the information processed through the service.

For Unplugged-hosted deployments, the underlying cloud-storage volume used to store assessment information uses encryption at rest.

The Daily Word mobile App requires HTTPS using TLS version 1.2 or later for transmission to the configured management server. Cleartext HTTP is disabled, and the App refuses non-HTTPS server addresses.

Daily Word does not use end-to-end or per-device encryption that makes assessment information technically inaccessible to the applicable server administrator. In an Unplugged-hosted deployment, authorized operational and support personnel may access assessment information as described above. Encryption of the underlying storage volume does not prevent authorized server-side access to the information.

For organization-hosted deployments, the Assessment Organization is responsible for the security of its own infrastructure and server configuration. The Daily Word App communicates only with the customer-configured server, subject to any optional server-side geolocation lookup that the Assessment Organization has agreed to enable. No technical or organizational measures can guarantee absolute security.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in Daily Word, our practices, applicable law or the ways in which the service is deployed.

If we materially expand the purposes for which information is processed, we will provide any additional notice or obtain any additional consent required by applicable law. The Effective Date below identifies the date of the current version.

19. Contact

Unplugged Technologies Ltd. | www.unplugged.com

Privacy/support: support@unplugged.com | Legal/security: legal@unplugged.com

 

Last update: September 10, 2026