Privacy Policy

Effective Date: January 1, 2026

1. Introduction

This Privacy Policy describes how Overmind Dominion LLC ("Company," "we," "us," or "our") collects, uses, discloses, and safeguards personal information in connection with the Verbo Speak application, website, and related services (collectively, the "Service").

By using the Service, you consent to the data practices described in this Policy.

Developer and Operator:

Overmind Dominion LLC
Phoenix, Arizona, United States

2. Information We Collect

We collect information directly from adult users and automatically through use of the Service. All accounts are held by adults (18+); any information about a child is entered by and remains under the control of the adult account holder.

A. Information You Provide

  • Account credentials (email address and encrypted password)
  • Profile information (name, communication preferences, accessibility settings)
  • Saved phrases, communication boards, and speech content
  • Child profile information entered voluntarily by a parent or guardian account holder
  • Digital consent records where legally required
  • Communications sent to support

We do not intentionally collect unnecessary sensitive personal information.

B. Automatically Collected Information

  • Device type, operating system version
  • Log data (IP address, timestamps, session activity)
  • Feature usage metrics
  • Crash reports and diagnostic data
  • Performance metrics
  • AI interaction session data (processed transiently unless user saves content)

Analytics data is aggregated where possible.

3. How We Use Information

We use collected information to:

  • Provide, operate, and maintain the Service
  • Authenticate users and secure accounts
  • Provide AI-assisted writing and speech synthesis
  • Personalize communication tools and analytics
  • Improve functionality and accessibility
  • Monitor and prevent fraud, abuse, or misuse
  • Comply with legal obligations, including COPPA and applicable educational privacy laws
  • Enforce our Terms of Service and EULA

We do not sell personal information.

4. AI Processing & Data Handling

Certain features use AI services to generate or refine text or speech.

  • AI processing may be performed by third-party providers.
  • Content submitted for AI processing may be transmitted securely to those providers.
  • We configure third-party AI providers not to use submitted data to train their public models where contractually available.
  • AI outputs are generated automatically and may not always be accurate.
  • Users control whether AI features are enabled.

5. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information.

Security measures include:

  • Encryption in transit (TLS)
  • Encryption at rest (industry-standard AES-256 or equivalent)
  • Role-based access controls
  • Access logging and monitoring
  • Secure cloud infrastructure
  • Incident response procedures

While we design systems consistent with recognized security frameworks such as SOC-2 principles, no method of transmission or storage is 100% secure.

6. Third-Party Service Providers

We use service providers to support functionality, including but not limited to:

  • Google Firebase – authentication, cloud storage, backend services
  • RevenueCat – subscription and purchase management
  • OpenAI – optional AI writing and voice features

These providers process data on our behalf under contractual agreements. Their privacy practices are governed by their respective policies.

We are not responsible for third-party services outside our control.

7. Children's Privacy (COPPA Compliance)

Verbo Speak is designed exclusively for adults. Accounts may only be created by individuals who are 18 years of age or older. We do not knowingly allow children to create accounts or use the Service directly.

Accounts & age requirement:

  • You must be at least 18 years old to register for and use the Service.
  • By creating an account, you represent and warrant that you are 18 or older.
  • We do not knowingly permit minors to create accounts. If we learn that an account was created by a minor, we will promptly delete it.

Information entered about a child:

  • A parent or guardian who holds an account may enter information about their child (e.g., a patient profile) as part of the Service's caregiver features.
  • Any such information is entered voluntarily by the adult account holder and remains under that adult's control at all times.
  • The parent or guardian may review, correct, or permanently delete any information about their child at any time from within the app or by contacting us.
  • We do not use child-related information for advertising and do not share it with third parties except as required to operate the Service or comply with law.
  • We collect only the minimum information necessary to provide the requested features.

8. Educational Use & FERPA Considerations

When used by educational institutions, we act as a service provider processing student information on behalf of the institution.

  • Student data remains under institutional control.
  • We process such data only for authorized educational purposes.
  • Data sharing is limited to service functionality and legal compliance.
  • School districts may request additional documentation under a separate agreement.

9. Data Retention

We retain personal information:

  • For the duration of the account's active status
  • As necessary to comply with legal obligations
  • As reasonably required for fraud prevention or dispute resolution

Upon verified deletion request:

  • Active account data is removed or de-identified
  • Backup systems may retain residual copies for a limited period (typically not exceeding 90 days)

10. User Rights

Depending on jurisdiction, users may have rights to:

  • Access personal information
  • Correct inaccurate information
  • Request deletion
  • Request data portability
  • Restrict or object to certain processing

Parents may exercise these rights on behalf of their child.

Requests may be submitted via the contact information below.

11. No Sale or Targeted Advertising

We do not:

  • Sell personal information
  • Use student or child data for behavioral advertising
  • Use communication content for unrelated marketing

12. Biometric and Face Data

Our application does not collect, store, process, or share facial recognition data, biometric identifiers, face geometry, or depth mapping information from the device camera. Any camera access is used solely for user-initiated functionality and does not perform facial analysis or identification.

13. International Users

The Service is operated in the United States. By using the Service, you understand that your information may be transferred to and processed in the United States.

14. Changes to This Policy

We may update this Privacy Policy periodically.

If material changes are made:

  • We will provide notice via the Service or email.
  • Continued use after the effective date constitutes acceptance.

15. Contact Information

Privacy inquiries and data requests:

Overmind Dominion LLC

Phoenix, Arizona, United States

Email: hello@overminddominion.com

Phone: Available upon request for accessibility accommodations

Last updated: January 1, 2026