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This privacy policy explains which personal data is processed when you use the Dutch Flashcards app for iPhone and iPad, for what purposes and on what legal basis, and what rights you have. In short: the app needs no account, keeps your learning progress on your device only, and contains no advertising or tracking.
1. Controller
The controller responsible for data processing under the General Data Protection Regulation (GDPR) is:
Melih Firat, email: melihfiratapps@gmail.com
For questions about data protection or to exercise your rights, please write to melihfiratapps@gmail.com. We are not required to appoint a data protection officer.
2. Overview
Dutch Flashcards works without a user account and without a server of our own. We only process:
- in-app purchase data if you buy Pro (through Apple and RevenueCat),
- your message and email address if you write to us.
We use no advertising, analytics or tracking services and do not sell any data. The app does not access your microphone, camera, location or contacts.
3. Data on your device
Your learning progress (e.g. words learned, test results, XP, streaks and achievements), your settings and your chosen language are stored only on your device. They are not sent to us, and we have no access to them.
The learning content and audio are part of the app. The pronunciation of single words may be generated by your device’s text-to-speech; this happens on the device.
Deleting the app deletes this data. Whether it is included in your iCloud or device backup depends on your Apple settings.
4. In-app purchases (Apple and RevenueCat)
The app is free; you can unlock all content with an in-app purchase (Pro). Purchase and payment are handled entirely through your Apple Account by Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland. We receive no payment details and do not learn your name or Apple ID. Apple’s privacy policy applies.
To verify, unlock and restore purchases, we use RevenueCat (RevenueCat, Inc., USA) as our processor (Art. 28 GDPR). This involves: a random identifier created by the app (no name, no email address), Apple’s purchase receipt and the purchase history (product, time, price, term, status), the app version, the operating system and the country or currency of your App Store account, as well as technically necessary connection data such as the IP address. More information: RevenueCat’s privacy policy.
The legal basis is Art. 6(1)(b) GDPR (performing the purchase contract). We keep purchase data as long as it is needed for access to Pro and for commercial and tax law obligations (Art. 6(1)(c) GDPR).
5. App Store, ratings and crash reports
When you download, update or rate the app, Apple processes data for this as its own controller. The app may occasionally ask you for a rating through Apple’s rating prompt; whatever you enter there goes to Apple.
If you have agreed in your device settings to share analytics with app developers, Apple gives us aggregated, non-personal usage statistics and crash reports. You can change this at any time under Settings › Privacy & Security › Analytics & Improvements.
6. Contact by email
If you write to us, we process your email address, your message and anything you choose to tell us in order to answer. The legal basis is Art. 6(1)(b) GDPR where it concerns a purchase, otherwise Art. 6(1)(f) GDPR (our legitimate interest in answering enquiries). We delete messages once they are dealt with, unless we must keep them by law.
7. Transfers to third countries
RevenueCat and Apple also process data in the USA. For the USA, the European Commission has adopted an adequacy decision (EU-U.S. Data Privacy Framework), which applies to companies certified under that framework. Where a provider is not certified, we base the transfer on the European Commission’s Standard Contractual Clauses (Art. 46(2)(c) GDPR). You can request a copy of the safeguards from us.
8. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), data portability (Art. 20 GDPR) and objection (Art. 21 GDPR).
Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you can object to this processing at any time on grounds relating to your particular situation.
As the app doesn’t know who you are, please include the order ID from Apple’s purchase receipt when your request is about a purchase. Simply write to melihfiratapps@gmail.com.
You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).
9. Children
The app is meant for learners aged 13 and over. We do not knowingly collect personal data from children.
10. Changes
We update this privacy policy when the app or the law changes. The version published here applies. The web app at dutch.lingotivo.com has its own privacy policy.