Privacy Policy
If you have questions about accessing or collecting your personal data please contact us.
Manabi strives to maintain the care and respect your personal data deserves. We're taking steps to improve transparency and reduce unnecessary data collection to a minimum. This document serves as both regulatory compliance as well as a guide for customers to understand how to find confidence in Manabi's operations.
It is Manabi's policy to respect your privacy regarding any information we may collect while operating our websites. This privacy policy ("policy") covers what personal data Manabi ("we") collect, what we use it for, how we store it, how it's protected, as well as your rights associated with your personal data and how we process it. When we say "you" we mean as a user of one of Manabi's websites or apps or as an online service or product customer of ours.
Revision history: Updated July 29 2022.
Who is Manabi?
Manabi is currently a sole proprietorship owned and operated by John A Ehlke in Toronto, Canada. Manabi is a passion project from a lifelong learner motivated to build world-class learning tools. The aim is for these tools to set world-class-defining standards in terms of their value, quality, and learning outcomes for users. Email: [email protected]
Manabi's website and apps include manabi.io, reader.manabi.io, and the Manabi and Manabi Reader apps on the Apple App Store. Throughout this Privacy Policy we’ll refer to our websites, mobile applications, and other products and services collectively as “Services.”
As a news feed and RSS reader client (among other web-oriented functionality), Manabi contains many links and embedded content targeting or displayed from third-party external websites, social media profiles, or other outside companies and content providers. These "other websites" are not Manabi's properties, and this policy doesn't cover how those other websites store and process data. When viewing other website content using Manabi tools, please refer to those websites' own policies and privacy notices.
Information we collect
Certain visitors to Manabi's websites choose to interact with Manabi in ways that require Manabi to gather personally-identifying information. The amount and type of information that Manabi gathers depends on the nature of the interaction. For example, we ask visitors who sign up for an account at Manabi.io to provide a username and email address. In each case, Manabi collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor's interaction with Manabi. Manabi does not disclose personally-identifying information other than as described in this policy. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website and app-related activities.
We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information you provide to us
It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:
- Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up in the Manabi or Manabi Reader apps to provide a username, email and password. We may have sign-in options with third-party OAuth2-type providers who offer options to hiding or not providing certain information such as email.
- Public profile and content information: If you have an account with us, we collect the information that you provide for your public profile. For example, Manabi accounts will display your username in your public profile and on content (such as flashcard decks) that you share with other users. This includes other non-personal information such as flashcard deck descriptions that you may choose to provide. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
- Payment and contact information: There are various ways in which you may provide us payment information and associated contact information. For purchases made through the Apple App Store (currently the majority of our Services), Apple collects but does not provide us with your personal or payment information; Apple does provide us with aggregate geographical and non-personal information on transaction histories, but uses anonymous or pseudonymous identifiers for customer identities.
- Communications with us (hi!) You may also provide us with information when you respond to surveys, communicate with us about a support question, post a question in public forums or social media, or sign up for a newsletter. When you communicate with us via form, email, comment, or otherwise, we may store a copy of our communications.
- Public testimonial As a small and independent operation, Manabi relies largely on word-of-mouth for marketing. If you post reviews or other types of testimonial content on public forums or in direct contact with us, Manabi may reference or reuse your comments as testimonial in marketing or other Service materials. Manabi will seek your consent as appropriate based on the source and potentially identifying information. You may request for us to take down if for instance you no longer believe it to be representative of your views or if you'd simply prefer your words to be taken down for whatever reason. We want testimonials to be honest and consensual.
- Credentials: Depending on the Services you use, you may provide us with credentials for other services you wish to integrate your Manabi account with, such as to import/sync flashcards from other services.
Information we collect automatically
We also collect some information automatically:
- Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services — for example, when you create or make changes to flashcard content in Manabi.
- Transactional information: When you make a purchase through our Services, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
- Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
- Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that users perform with flashcard decks while using Manabi — in other words, who did what and when (e.g., [Manabi username] deleted “[title of deck]” at [time/date]). We also collect information about what happens when you use our Services (e.g., page views, interactions with shared flashcard decks and other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
- Stored information: We may access information stored on your device via our apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access your clipboard, our Service can access text that you choose to paste content that was stored (temporarily or persisted) on your device in order to process and display it as material to learn from.
- Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Manabi uses cookies to help Manabi identify and track visitors, their usage of Manabi website, and their website access preferences. Manabi visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Manabi's websites, with the drawback that certain features of Manabi's websites may not function properly without the aid of cookies.
Information we collect from other sources
We may also get information about you from other sources. For example:
- Third Party Login: If you create or log in to your Manabi account through another service (like Facebook) we’ll receive associated login information (e.g. a connection token, your username and/or user ID, your email address)
- Social Sharing Services: If you connect your account to a social media service (like Facebook or Twitter), we’ll receive information from that service (e.g., your username) via the authorization procedures for that service.
- To provide our Services. For example, to set up and maintain your account, provide customer service, and verify user information.
- To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them learn more efficiently or make our Services easier to use.
- To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a paid plan after receiving a marketing message), and understanding and forecasting user retention.
- To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Automattic and others, which may result in us, for example, declining or terminating Services.
- To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
- To improve user learning outcomes For example, Manabi Reader tracks the words that are read within articles as they are read in order to show which words are new to the user or to show flashcards that the user has created which appear in the article. This helps users enrich their learning experiences and retain what they've learned more efficiently.
- To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services, recommending content through Manabi Reader feed suggestions, and providing relevant flashcards or other personalized learning resources.
- To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Manabi; contacting you with offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important transactional updates relating to your account.)
- Limit the information that you provide: If you have an account with us, you can choose not to provide any optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services — for example, the ability to store and review flashcards — may not be accessible.
- Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like pasting clipboard content into Manabi Reader in order to read articles in a foreign language.
- Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other important transactional communications, like those about your account and legal notices.
- Set your browser to reject cookies: At this time, Manabi does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Manabi's websites, with the drawback that certain features of Manabi's websites may not function properly without the aid of cookies.
- Close your account: While we’d be sad to see you go, you can close your account if you no longer want to use our Services. (Here is the account deletion form for Manabi accounts.) Please keep in mind that we may continue to retain your information after closing your account, as described in "How long we keep information" — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
- Identifiers (like your name, contact information, and device and online identifiers);
- Commercial information (your billing information and purchase history, for example);
- Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
- Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an author of a shared flashcard deck in Manabi);
- Geolocation data (such as your location based on your IP address);
- Audio, electronic, visual or similar information (such as vocabulary from learning resources you upload);
- Inferences we make (such as likelihood of retention or attrition).
- Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
- Request deletion of personal information we collect or maintain;
- Opt out of any sale of personal information; and
- Not receive discriminatory treatment for exercising your rights under the CCPA.
The information we receive depends on which services you use or authorize and what options are available.
Aggregated Statistics
Manabi may collect statistics about the behavior of visitors to its websites. Manabi may display this information publicly or provide it to others. However, Manabi does not disclose personally-identifying information other than as described in this policy.
Protection of certain personally-identifying information
Manabi discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Manabi's behalf or to provide services available at Manabi's websites, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Manabi's websites, you consent to the transfer of such information to them. Manabi will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Manabi discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Manabi believes in good faith that disclosure is reasonably necessary to protect the property or rights of Manabi, third parties or the public at large. If you are a registered user of an Manabi website and have supplied your email address, Manabi may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what's going on with Manabi and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Manabi takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
How and why we use information
Purposes for using information
We use information about you for the purposes listed below:
Legal bases for collecting and using information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or
(5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on, as described in our policies.
How long we keep information
We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on "How and why we use information" — and we’re not legally required to keep it.
For example, we keep web server logs that record information about a visitor to one of Manabi's websites, like the visitor’s IP address, browser type, and operating system, with a storage limit that deletes previous historical data after, at the time of writing, approximately 20MB of logs are retained. We retain the logs for a period of time in order to, among other things, analyze traffic to Manabi's websites and apps and investigate issues if something goes wrong on one of our Services.
As another example, when you delete a flashcard or flashcard deck in Manabi, the content is "soft-deleted" such that it is no longer accessible by users of our Services, but is retrievable with authorized Service administration for maintenance or to recover from catastrophic Service failures. Currently there is no fixed length of time upon which soft-deleted content is purged.
Security
While no online service is 100% secure, we work hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks and routinely upgrade Services infrastructure to keep pace with security fixes and improvements.
Choices
You have several choices available when it comes to information about you:
Your rights
If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.
European General Data Protection Regulation (GDPR)
If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
You also have the right to make a complaint to a government supervisory authority.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it.
The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:
You can find more information about what we collect and sources of that information in the "Information we collect" section of this policy.
We collect personal information for the business and commercial purposes described in the "How and why we use information" section. And we share this information with the categories of third parties described in the "Sharing information" section.
If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:
Contacting us about these rights
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, please reach out to us by email [email protected] or other means offered in our apps and websites.
When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.
Controllers and responsible companies
Manabi's Services are worldwide. Depending on the Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is the Manabi company that entered into the contract with you under the Terms of Service for the product or service you use.
How to reach us
If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the "Your rights" section in this policy, please contact us by email [email protected] or through one of our other support contact methods.
Other things you should know
Transferring information
Because Manabi's Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors. This is required for the purposes listed in the "How and why we use information" section in this policy.
When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include entering into European Commission approved standard contractual arrangements with entities based in countries outside the EEA.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
Third-Party Software and Services
If you’d like to use other third-party software or services which Manabi tools such as our browser extensions and news/RSS readers allow you to access and interface with as learning resources, please keep in mind that interacting with them may mean providing information about yourself to those third parties. For example, some third-party services may request that you sign up for an account on their platform. Please note that if you use the third-party service or grant access, your data will be handled in accordance with the third party’s privacy policy and practices. We don’t own or control these third parties, and they have their own rules about information collection, use, and sharing, which you should review before using the software or services.
Visitors to our users' shared content
We also process information about visitors to our users’ content, such as shared flashcard decks, on behalf of our users and in accordance with our user agreements.
Users control the content posted on their shared learning resources, so any disputes regarding content on a user’s profile or shared materials should be made directly to the content owner as able, by leaving a comment on their resources, or by contacting Manabi for possible assistance if such means are unavailable.
Account and personal data deletion
An automated account and personal data deletion option is maintained for users at this page: https://manabi.io/accounts/delete-all-account-data/ - please note that this page requires that users are logged-in to the account they wish to delete. For deletion requests this tool does not cover, please contact us at [email protected]
Privacy Policy changes
Although most changes are likely to be minor, Manabi may change its Privacy Policy from time to time. Manabi encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the revision log, and, in some cases, we may provide additional notice (like adding a statement to our homepage or sending you a notification through email or in your app). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.
That’s it! Thanks for reading.
This work above is licensed under a Creative Commons Attribution-ShareAlike 3.0 Unported License. Adapted in part from Automattic.