Privacy Policy

Last updated: 20 October 2026
Effective: 2 August 2026

This Privacy Policy explains what personal data The Verbarium
(“we”, “us”, “our”) collects when you use https://theverbarium.com
(the “Site”), why we collect it, who we share it with, and what rights you have over it.

It covers the whole Site: the articles, the writing tools, the contact form and the
assistant called The Verbarium AI.

1. Who is responsible for your data

The data controller for the Site is:

• Kleoniq Kosova, operating as The Verbarium
• Pallatet Deli Jorgji, Tirana, Albania
• Email: TheVerbarium@gmail.com

We are established in Albania and process personal data in line with Albanian
Law No. 124/2024 “On Personal Data Protection”, which is aligned with the EU
General Data Protection Regulation (GDPR). Where you are in the European
Economic Area or the United Kingdom, we also process your data in line with the
GDPR and UK GDPR.

2. The short version

• The Site has no accounts. You can read every article and use every writing tool without giving us anything.
• The writing tools run in your browser. The text you paste into them is not sent to us, unless you press a button marked “The Verbarium AI” (section 3.1).
• We ask for personal data only when you choose to give it, by using the contact form. Like any website, our server also keeps logs of the requests it receives (section 3.2).
• If you use The Verbarium AI, what you type is sent to Google, whose model writes the reply. We do not keep it.
• We count visits with Google Analytics, and the Site carries Google’s AdSense code. Both are loaded when you open a page, and both use cookies. The Site has no cookie banner of its own; Google may show its own consent message to visitors in the European Economic Area, the United Kingdom and Switzerland.
• We never sell your personal data, and we don’t run a newsletter or share your email with advertisers.

3. What we collect, and why

3.1 Information you give us directly

Contact form. When you use the form on our
Contact page, you provide a name,
an email address, and a message. The message is saved in the Site’s
administration area, where only we can read it, and a copy is sent to us by email
when email delivery is available. We use them only to read and reply to you. To stop floods of messages, we count how many are saved from one connection in an hour, under a hash of the IP address. Legal basis: legitimate interests, responding to people
who deliberately contact us.

Messages to The Verbarium AI. The Verbarium AI is an automated
assistant. It answers questions about wording, and it writes or improves a short text for work:
an email, a CV, a notice or a reply to a customer, a product description. Where it is switched on, it is a button marked “Verbarium AI” at the foot of the page, and inside articles a box called “Ask The Verbarium”, with a short summary of the article, a few questions about it and a field for a question of your own. The summary, the questions and their answers are written from the article’s text and stored on our server: reading them sends nothing anywhere. Where Google’s model writes them, it does so once, when the article is first opened, which sends the article’s text to Google and nothing about the reader. Nothing you write is sent anywhere until you send a message. In Voice & Standards, the writing checker on the home page, pressing a button marked “The Verbarium AI” on a finding is such a message: it sends the one sentence the finding is in, with the expression to do without or the longest sentence you allow and the spelling you chose, and the reworded sentence is put into your text. The button there for the whole text, shown while the setting “Tone rewrite” is on, sends the text you are checking, with your spelling choice, the expressions you avoid, the rules you switched on for contractions, sentence length and exclamation marks, and a one-line description of your usual style, and the text rewritten in a plain tone is put in its place. When you send a message, our server sends the text of your message to Google’s Gemini service,
together with the earlier messages and replies of the same conversation and text taken from our
own pages, including the page you are on, and Google’s model writes the reply. The conversation is held in your browser’s memory
while the page is open, which is how it can be sent again with each new message. It is gone when
you close or reload the page. We do not store your messages or the replies. To limit misuse we
count how many messages come from one device and from one internet connection. Devices are told apart by what the browser
sends with every request: its name, its version and its language. Only the times of recent messages are kept, under a hash
of the IP address and of that description, never the address or the description itself, and they are deleted 24 hours after
the last message. Nothing is stored on your device for this. Google handles the messages as our processor under the terms of its paid service: it does not use them or the replies to improve its products, and it logs them for a limited period only to detect abuse. Please leave names, contact
details and anything confidential out of what you type. When the assistant writes a CV it leaves
marked gaps for your name and contact details, for you to fill in yourself. The replies are
automated and can be wrong. Legal basis: legitimate interests, answering a message
you chose to send.

3.2 Information collected automatically

Server logs. Our web server keeps standard logs. For each request
it records the IP address, date and time, the page requested, referring page, browser and
operating system, and it keeps a separate log of errors. These exist for security, abuse
prevention and diagnosing faults. Legal basis: legitimate interests, keeping the Site secure and
operational.

Analytics. We use Google Analytics to understand how the Site is used in
aggregate: which pages are read, how people arrive, which devices they use. Its script is loaded
when you open a page; it sets cookies in your browser and sends information about your visit to
Google. Section 4 says how to refuse it. Legal basis: our legitimate interest in knowing how
the Site is used.

Advertising. See section 5 below.

3.3 Information stored on your own device

The writing tools keep your settings in your browser, and your details where you ask them to. The Verbarium AI keeps nothing there.

• fdw_send: the three choices of the “Before you send” check (where your reader is, which way round you write dates, and whether sound-alike words are underlined), kept in localStorage so that you do not have to set them again. The message you paste is never kept.
• fdw_keep_ooo, fdw_keep_hours and fdw_keep_closure: details you typed into the out-of-office form, the opening-hours form and the closure-notice form, kept in localStorage only if you tick that form’s “Remember … on this device” box, and removed when you untick it. They are not sent to us.
• fdw_vs: the editorial rules you set in Voice & Standards, whether its tone rewrite is switched on, and the writing profiles you save there (counts taken from the samples you paste, and the expressions you list), kept in localStorage. The samples themselves and your drafts are not kept, and none of it is sent to us. The one exception is a button marked “The Verbarium AI” (section 3.1), which sends what that section says.

You can clear these at any time through your browser’s “clear site data”
setting. Doing so removes the settings and details the tools were keeping.

3.4 What we do not collect

• We do not collect precise geolocation (GPS) data.
• We do not collect special-category data, such as health, biometrics, religion, political opinions or sexual orientation.
• We do not take payments and never see card details.
• We do not sell personal data, and we do not share it with data brokers.

4. Cookies and similar technologies

Cookies are small text files placed on your device. We and our partners use
them for the purposes below.

Managing your choices. The Site has no cookie banner of its own. Google
Analytics and the AdSense code are loaded when you open a page.

Google’s AdSense code can show Google’s own consent message to visitors in the European Economic
Area, the United Kingdom and Switzerland. It is a consent platform Google has certified under the
IAB Europe Transparency and Consent Framework. Whether it is shown, what it asks, and what Google’s
advertising code does with your answer are Google’s; where it is shown, it keeps your answer in a
cookie on your device (FCCDCF). We keep no record of it ourselves.

You can refuse these cookies whether or not you are asked: by blocking or deleting cookies in
your browser settings, with Google’s
Analytics opt-out add-on, and
through the advertising choices listed in section 5.

5. Advertising and Google AdSense

The Site is intended to be funded by advertising, through Google AdSense.
That is what keeps it free to read. The AdSense code is on every page; it is also what shows
Google’s consent message, where Google shows one (section 4).

Where ads are served:

• Third-party vendors, including Google, use cookies to serve ads based on your prior visits to this Site and other websites.
• Google’s use of advertising cookies enables it and its partners to serve ads to you based on your visit to this Site and/or other sites on the internet.
• You can opt out of personalised advertising by visiting Google Ads Settings.
• You can opt out of some third-party vendors’ use of cookies for personalised advertising at aboutads.info/choices or youronlinechoices.eu.
• For visitors in the European Economic Area, the United Kingdom and Switzerland, Google’s rules allow personalised ads only with consent collected through a consent platform it has certified, such as its own message. Without that consent it may still show ads that are not personalised, which Google calls limited ads.

For details of how Google uses information from sites that use its services,
see How
Google uses information from sites or apps that use our services. Google lists
the advertising companies it works with on its
ad technology providers page.

Legal basis: consent, where Google’s message asks for it; otherwise our legitimate interest in funding the Site.

6. Who we share data with

We do not sell your personal data. We share it only with the service providers
we need in order to run the Site, and only for the purposes described here:

• Contabo GmbH (Munich, Germany): website hosting and server logs.
• Google Ireland Ltd / Google LLC: analytics, advertising (AdSense) and Google’s consent message (section 4).
• Google LLC (Gmail): receiving and storing emails sent to our address, and copies of contact-form messages when email delivery is available.
• Google LLC / Google Ireland Ltd (Gemini API): writing the replies of The Verbarium AI from the messages you send it.

We may also disclose data where we are legally required to, or where it is
necessary to establish, exercise or defend legal claims, or to protect the
rights and safety of our users.

7. International transfers

The Site itself is hosted by Contabo GmbH, a German company, on servers located in the European Union. Some of our other
providers, notably Google, are based outside Albania and
outside the EEA, principally in the United States.

Where personal data is transferred outside Albania or the EEA, we rely on
appropriate safeguards, including the European Commission’s Standard Contractual
Clauses and, where applicable, the EU–US Data Privacy Framework. You may request
a copy of the relevant safeguards by contacting us.

8. How long we keep things

9. Security

The Site is served exclusively over HTTPS. We keep software updated and limit
administrative access.

No method of transmission or storage is completely secure, so we cannot
guarantee absolute security. If a personal data breach occurs that is likely to
result in a risk to your rights, we will notify the Commissioner for the Right
to Information and Personal Data Protection, and you, without undue delay.

10. Your rights

Under Albanian Law No. 124/2024 and the GDPR you have the right to:

• Access the personal data we hold about you and receive a copy.
• Rectify data that is inaccurate or incomplete.
• Erase your data.
• Restrict or object to processing based on our legitimate interests.
• Portability: receive the data you gave us in a structured, machine-readable format.
• Withdraw consent at any time, without affecting processing carried out before you withdrew it.
• Not be subject to decisions based solely on automated processing that produce legal or similarly significant effects. We do not carry out such processing.

To exercise any of these, email
TheVerbarium@gmail.com. We will
respond within 30 days. We may ask you to verify your identity before acting on a
request, so that we don’t disclose your data to someone else.

Complaints. If you think we have handled your data
improperly, please contact us first. We would rather fix it. You also have the
right to complain to the Albanian Commissioner for the Right to Information
and Protection of Personal Data (idp.al),
or, if you are in the EEA or UK, to your local data protection authority.

11. If you are in the United States

We do not sell personal information, and we do not share it for cross-context
behavioural advertising in exchange for money. Depending on your state, you may
have the right to know what personal information we collect, to request its
deletion or correction, and not to be discriminated against for exercising those
rights. Use the contact address above to make a request.

Visitors in the United States are not shown a consent message: Google Analytics and the AdSense
code load when you open a page. The opt-outs in sections 4 and 5 are open to you, and you can ask
us at the address above to stop.

12. Children

The Site is intended for a general audience and is not directed at children
under 13 (or the applicable minimum age in your country, which is up to 16 in
parts of the EEA). We do not knowingly collect personal data from children, and
we do not permit personalised advertising to be targeted on the basis of activity
by users we know to be under 13.

The Verbarium AI is meant for adults. Please do not use it if you are under 18.

If you believe a child has provided us with personal data, contact us and we
will delete it promptly.

13. Links to other sites

Our articles link to third-party sites. Following
those links takes you outside our control; we are not responsible for their
content or their privacy practices. We recommend reading the privacy policy of
any site you visit.

14. Changes to this policy

We may update this policy as the Site changes or the law does. The revised
version will be posted here with a new “Last updated” date. If a change
materially affects how we use your personal data, we will make that clear on the
Site.

15. Contact

Questions about this policy, or about your data:

Kleoniq Kosova, The Verbarium
Pallatet Deli Jorgji, Tirana, Albania
TheVerbarium@gmail.com