Ultraland Privacy Policy

We collect information in a few different ways: information you provide to us, information created when you use Ultraland, and information we receive from third parties that help us operate the Service.

A. Information You Provide

We may collect information that you choose to provide, including:

• your name, username, email address, phone number (if you sign in by phone), password or login credentials, profile information, avatar, and language preferences;
• account settings and subscription preferences;
• payment-related information, such as subscription plan, billing status, transaction history, and payment confirmation;
• messages, support requests, feedback, survey responses, or other communications you send to us;
• any other information you choose to provide when using Ultraland.

Payment information is processed by our third-party payment provider, Stripe. We do not directly store your full payment card number.

B. Learning, Gameplay, and User Content

When you use Ultraland, we may collect and process content and activity related to your learning experience, including:

• answers, translations, prompts, written responses, practice text, and other language inputs;
• battle records, game history, scores, rankings, streaks, mistakes, and learning progress;
• AI scoring results, grammar feedback, fluency analysis, accuracy analysis, and performance summaries;
• exported or saved learning records;
• interactions with other users, where social or multiplayer features are available;
• content you submit, upload, generate, save, export, or share through the Service.

We refer to this information as “User Content” and “Learning Data.”

C. Information Collected Automatically

When you access or use Ultraland, we may automatically collect certain technical and usage information, including:

• IP address;
• device type, browser type, operating system, app version, and device identifiers;
• log data, such as pages visited, features used, access times, referring pages, and session activity;
• gameplay and feature usage patterns;
• crash reports, error logs, and performance data;
• approximate location based on IP address;
• cookie, local storage, pixel, SDK, or similar technology data.

We use this information to keep Ultraland running, improve performance, protect accounts, understand how users interact with the Service, and develop better learning features.

D. Information From Third Parties

We may receive information from third parties that help us provide, secure, or improve Ultraland, such as login providers (including Google), payment processors, analytics providers, AI service providers, hosting and database providers, customer support tools, fraud-prevention and security providers, and marketing partners (if applicable).

We use information to provide, operate, protect, and improve Ultraland. This includes using information to:

• create, manage, and secure user accounts;
• provide language learning games, battles, practice modes, AI scoring, and feedback;
• save learning records, progress, rankings, and Pro subscription status;
• generate grammar feedback, fluency analysis, accuracy scoring, mistake summaries, and learning insights;
• allow users to review, save, or export learning records;
• personalize the learning experience, including language level, practice history, and recommended features;
• process payments, subscriptions, cancellations, renewals, and billing-related support;
• respond to customer support requests, feedback, and inquiries;
• analyze how the Service is used and improve features, design, safety, and performance;
• develop new products, features, and learning tools;
• detect, prevent, and respond to fraud, cheating, abuse, security incidents, technical issues, or violations of our Terms of Use;
• protect the rights, safety, privacy, and property of Ultraland, our users, and others;
• comply with legal obligations, enforce our agreements, and resolve disputes.

We may also use aggregated or de-identified information for analytics, research, product development, business planning, and service improvement. Where information has been de-identified so that it can no longer reasonably identify you, we may use it to the fullest extent permitted by law.

Ultraland uses AI systems to provide language scoring, grammar feedback, translation support, fluency analysis, learning suggestions, and performance summaries.

To provide these features, your inputs and learning activity may be processed by Ultraland and by trusted third-party AI service providers.

Our AI providers process your inputs in order to return results to you. Your inputs and the resulting outputs may also be used by Ultraland and our AI providers to operate, maintain, secure, personalize, and improve our respective products and services, including to develop, improve, and train AI models. Where practical, we use aggregated or de-identified data for these purposes.

AI-generated feedback may not always be accurate, complete, or suitable for every learning purpose. Privacy requests involving AI-generated information will be evaluated based on applicable law and the technical ability of our systems.

We do not share your personal information casually. However, we may share information in the following situations.

A. Service Providers

We may share information with vendors and service providers that help us operate Ultraland. These currently include, for example, Stripe (payment processing), our third-party AI service providers (for AI scoring, feedback, and text-to-speech), PostHog (product analytics), Resend and Aliyun (email and SMS delivery), and our cloud hosting and database providers. These providers may access, process, or store information only as needed to perform services for us, subject to their agreements with us.

B. Legal, Safety, and Protection Reasons

We may disclose information if we believe it is reasonably necessary to:

• comply with applicable law, regulation, legal process, or government request;
• enforce our Terms of Use or other policies;
• detect, investigate, or prevent fraud, abuse, cheating, security incidents, or illegal activity;
• protect the rights, property, privacy, safety, or security of Ultraland, our users, employees, partners, or the public;
• respond to claims, disputes, or potential legal liability.

C. Business Transfers

If Ultraland is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar business transaction, user information may be disclosed or transferred as part of that transaction.

D. Affiliates and Related Entities

We may share information with our affiliates, subsidiaries, parent companies, or related entities, if any, for purposes consistent with this Privacy Policy.

E. With Your Direction or Consent

We may share information when you choose to export, publish, share, connect, or otherwise make your information available to another user, platform, or third-party service. For example, if you export your battle records or learning history and share them outside Ultraland, your use of that exported information is your responsibility.

Ultraland may use cookies, local storage, pixels, SDKs, and similar technologies to:

• keep you logged in;
• remember your settings and preferences;
• understand how users interact with the Service;
• improve performance and reliability;
• detect fraud, abuse, or security risks;
• measure marketing performance, if applicable.

We use essential cookies and local storage for sign-in, security, and your preferences, and first-party product analytics (PostHog) to understand how the Service is used. We also use Google’s advertising tags (Google Ads conversion tracking and remarketing), which set Google advertising cookies and share online identifiers with Google, to measure the performance of our own advertising and, in some cases, to show our ads to you on other websites. We do not display third-party ads inside the Service. You can opt out of personalized Google ads in Google’s Ads Settings (adssettings.google.com).

You may be able to control cookies through your browser settings. However, disabling cookies may affect some features of the Service.

We keep personal information for as long as reasonably necessary to provide the Service and for legitimate business, legal, security, and operational purposes.

The length of time we retain information may depend on:

• the type of information;
• whether you have an active account;
• whether the information is needed to provide learning records, gameplay history, or Pro features;
• whether we need the information for security, fraud prevention, dispute resolution, payment records, tax, accounting, legal compliance, or enforcement of our Terms of Use.

If you request deletion of your account or certain personal information, we will process your request in accordance with applicable law. However, we may retain certain information where reasonably necessary or legally permitted, including for security, fraud prevention, backup, legal compliance, dispute resolution, accounting, or enforcement purposes.

For example, if an account is suspended for abuse, cheating, fraud, or violation of our Terms, we may retain certain information to protect Ultraland, other users, and the integrity of the Service.

Depending on the features available in your account, you may be able to:

• update your account information;
• change your profile or language preferences;
• review learning history or battle records;
• export certain Pro learning records;
• delete certain saved content or account information;
• unsubscribe from marketing emails using the unsubscribe link;
• manage cookies through your browser settings;
• request access, correction, deletion, or a copy of your personal information.

To make a privacy request, contact us at hello@ultraland.app. We may need to verify your identity before responding to your request. If we cannot verify your identity, we may not be able to fulfill the request.

Depending on where you live, you may have certain rights regarding your personal information, such as the right to:

• know what personal information we collect, use, disclose, sell, or share;
• access a copy of your personal information;
• correct inaccurate personal information;
• request deletion of personal information;
• request portability of your information;
• opt out of certain uses of personal information;
• withdraw consent where processing is based on consent;
• appeal our decision regarding a privacy request, where required by law;
• not be discriminated against for exercising your privacy rights.

These rights may be subject to limitations and exceptions under applicable law. To exercise your rights, please contact us at hello@ultraland.app.

Certain U.S. state privacy laws may require additional disclosures. Depending on your state of residence and whether those laws apply to Ultraland, the following categories of personal information may be collected, used, and disclosed as described in this Privacy Policy:

• identifiers, such as name, email address, username, IP address, and device identifiers;
• account information, such as login credentials, profile information, and subscription status;
• commercial information, such as transaction history, subscription plan, and billing status;
• internet or electronic network activity, such as log data, usage data, gameplay activity, and device information;
• geolocation information, such as approximate location based on IP address;
• user content, such as answers, translations, prompts, learning inputs, battle records, feedback, and messages;
• education-related or learning activity information created through your use of Ultraland;
• communication information, such as support requests and messages you send to us;
• inferences, such as learning preferences, performance patterns, and feature recommendations.

We use these categories of information for the purposes described in this Privacy Policy, including providing the Service, improving Ultraland, personalizing learning, processing payments, securing the Service, preventing abuse, and complying with legal obligations.

Sale or Sharing of Personal Information

We do not sell your personal information for money. We do use Google’s advertising tags (Google Ads conversion tracking and remarketing), which may share online identifiers and activity with Google for advertising measurement and remarketing; under some U.S. state privacy laws this may be treated as “sharing” or “targeted advertising.” You can opt out of personalized Google advertising through Google’s Ads Settings (adssettings.google.com) and your browser or device controls, or by contacting us at hello@ultraland.app. We will provide any further notice and opt-out options required by applicable law.

Sensitive Personal Information

Ultraland is not designed to collect sensitive personal information. Please do not submit sensitive information unless it is necessary for your use of the Service. We do not intend to use sensitive personal information to infer characteristics about you, except where permitted or required by law.

Ultraland is not directed to children under 13, and we do not knowingly collect personal information from children under 13 without legally required parental consent.

If you are under the age of majority in your location, you may use Ultraland only with permission from a parent or legal guardian.

If you believe a child under 13 has provided personal information to Ultraland, please contact us at hello@ultraland.app. We will review the request and take appropriate steps in accordance with applicable law.

We use commercially reasonable technical, administrative, and organizational measures designed to protect personal information from unauthorized access, loss, misuse, alteration, or disclosure.

However, no online service, website, app, database, or transmission method is completely secure. We cannot guarantee absolute security. You are responsible for keeping your account credentials confidential and for using the Service carefully.

Ultraland is operated from the United States and is available to learners in many countries. If you use Ultraland from outside the United States, your information may be processed and stored in the United States or in other countries where we or our service providers operate. These countries may have data-protection laws that differ from those in your country. We will handle your personal information as described in this Privacy Policy.

Users in the European Economic Area and United Kingdom

If you are in the European Economic Area (EEA) or the United Kingdom, the following additional information applies. The data controller is PalmLab AI LLC.

We process your personal information on the following legal bases: (a) performance of a contract, to provide the Service you request; (b) our legitimate interests, such as securing, maintaining, and improving the Service and preventing fraud and abuse, balanced against your rights; (c) your consent, where we ask for it (for example, certain cookies or marketing); and (d) compliance with legal obligations.

Subject to applicable law, you have the right to access, correct, delete, restrict, or object to our processing of your personal information, the right to data portability, the right to withdraw consent at any time, and the right to lodge a complaint with your local data-protection supervisory authority.

Where we transfer personal information out of the EEA or the United Kingdom, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum), or another lawful transfer mechanism. To exercise your rights or request more information, contact us at hello@ultraland.app.

Ultraland may contain links to, integrate with, or rely on third-party services, including payment processors, app stores, login providers, analytics providers, AI providers, and external websites.

This Privacy Policy does not apply to third-party services. We are not responsible for the privacy practices, security practices, policies, content, or actions of third parties. You should review the privacy policies of any third-party services you use.

We may send you service-related messages, such as account notices, payment notices, subscription updates, security alerts, and changes to our policies.

We may also send promotional messages, product updates, or learning-related content where permitted by law. You can opt out of marketing emails by using the unsubscribe link or contacting us. Even if you opt out of marketing messages, we may still send non-promotional service messages.

We may update this Privacy Policy from time to time. When we update it, we will revise the “Last updated” date above.

If we make material changes, we may provide additional notice, such as through the Service or by email, where required by law. Your continued use of Ultraland after the updated Privacy Policy becomes effective means you acknowledge the updated policy.

If you have questions, concerns, or requests about this Privacy Policy or Ultraland’s privacy practices, please contact us: