Privacy Policy

Effective date: [DD Month YYYY]

Contents

1. Who is responsible
2. Data stored on your iPhone
3. Data sent to other services
4. What we don't collect
5. Why we use data (legal bases)
6. How long data is kept
7. International transfers
8. Your rights
9. Children
10. Changes to this policy
11. Contact

1. Who is responsible

The controller of your data for the LearnScrumble app is [Developer or company name], [full postal address], [company registration number, if any]. Contact: support@learnscrumble.com.

2. Data stored on your iPhone

This data is created by you while using the app. It stays on your device and is not sent to us.

You can delete your answers for one language with Settings → Progress → Reset progress, and all app data by deleting the app (except the daily free-word counter, see above). The data may also be included in your own iPhone backups.

Spoken words are produced by your iPhone's built-in text-to-speech, on the device.

For troubleshooting, the app also writes short technical messages to the iPhone's own system log. Your job is marked private there, so iOS hides it outside of development tools. These messages stay on the iPhone; only the last few steps, without your job or words, are included in a crash or error report (see section 3).

3. Data sent to other services

OpenAI — creating words and pictures

We ask first. Before any request is sent, the app asks you to agree: on the setup screen ("I agree"), or once in a separate question if you set up the app before this question existed. Without your agreement the app can't create words, so no game starts and nothing is sent. The same explanation stays visible in Settings → Legal and support.

When the app needs new words, it sends a request to OpenAI, L.L.C. (United States) with:

• your job (as chosen or typed by you);
• the language you speak and the language you learn;
• the English names of words you've already practised in that language, so they aren't repeated;
• for new pictures: a short description of the object to draw.

In the same request, OpenAI is asked for the common English name of your job, for the job list described below.

The app doesn't send your name or any account or device identifier. As with any internet request, OpenAI receives your IP address. Please don't type personal information (such as names) into the job field. According to OpenAI's policies, data sent through its API is not used to train its models by default and may be kept for a limited time (currently up to 30 days) to monitor abuse.

Google Firebase — the shared word library

Words and pictures are stored in a library shared by all LearnScrumble users, on Google Firebase (Cloud Firestore and Cloud Storage), operated by Google LLC / Google Ireland Ltd. The app:

• reads words that already exist (by their English name), so known words and pictures are reused instead of created again;
• adds new words: the English name, the word in your two languages, and a link to the picture;
• uploads new pictures (images of objects, never photos of you).

Nothing that identifies you, and not your job, is stored with these words. Google receives your IP address and technical information (such as the app and SDK version and device type) needed to deliver the service. Data location: the United States (Cloud Firestore: Google's “nam5” United States multi-region; Cloud Storage: United States multi-region). See section 7 for how transfers outside the EU are protected.

Google Firebase — the list of jobs people learn for

To decide which jobs to add to the menu, we count which jobs are used, in a list on Google Firebase (Cloud Firestore). When you start learning for a job (once per job on your iPhone):

• if you chose it from the menu, its English name (for example "electrician") is counted;
• if you typed it yourself, OpenAI also returns its common English name in the same request that creates your words (for example "kucharz" becomes "cook"), and that English name is counted. Text that isn't a real job — such as a name or random text — is not counted.

The list stores only the English job name, how many times it was chosen or typed, and when it was first and last seen. It never stores the text you typed, and nothing that identifies you or your iPhone.

Firebase Crashlytics — crash and error reports

The app sends a report to Firebase Crashlytics (Google) the next time you open it if it crashed, or if something went wrong without a crash — for example when new words couldn't be loaded because there was no internet. A report contains:

• where in the app's code the problem happened, the type of error (for example "no internet" or "server busy") and a short technical description of it from iOS or the server;
• the language you speak and the language you learn;
• the app's last technical steps before the problem, such as "round finished" or "10 words loaded" — counts and steps only;
• the iPhone model, iOS version, app version, free memory and disk space, and whether the app was in the foreground;
• a random installation ID created by Firebase, so repeated problems on the same iPhone are counted once. It isn't linked to your name, your Apple ID or any other identifier.

Reports don't contain your job, the words you practise or your answers. We use them only to find and fix bugs. Crashlytics keeps them for 90 days, after which Google starts removing them from its systems.

Google Analytics for Firebase — usage statistics (only if you switch it on)

"Share usage statistics to help improve the app" is off until you turn it on, on the setup screen or in Settings → Legal and support. You can turn it off again at any time. Only while it's on, the app sends Google Analytics for Firebase:

• which parts of the app are used, for example "setup finished", "round finished", "review started" or "daily limit reached", with simple details such as the number of review words or the type of error when words couldn't be loaded;
• the language you speak and the language you learn (sent when you finish the setup);
• which job from the menu you chose, or only that you typed your own (never the text you typed);
• the iPhone model, iOS version, app version, app language and approximate country (from the IP address);
• a random app-instance ID created by Firebase, so visits from the same iPhone can be counted. The app doesn't use the advertising identifier (IDFA).

The statistics are about how the app is used, not about who you are. They don't include your job, the words you practise or your answers. Analytics keeps them for 2 months.

Apple

• Time check: before a game starts, the app asks apple.com for the current time (only the time, no page content), so the daily free words are counted correctly. Apple receives your IP address.
• Purchases: subscriptions are bought, renewed and restored through Apple's App Store. Apple processes your payment; we don't receive your payment details. See Apple's Privacy Policy.
• Notifications: if you allow them, daily reminders are local notifications scheduled on your iPhone; no notification server or push token is used.

4. What we don't collect

• No account, name, email address or phone number.
• No location, contacts, photos, camera or microphone.
• No advertising, no advertising identifier, no tracking across other apps or websites.
• No usage statistics unless you switch them on (see section 3).
• We don't sell or rent data to anyone.

5. Why we use data (legal bases)

• To provide the app you asked for — creating words and pictures for your job and languages, remembering your settings and progress (performance of a contract, Art. 6(1)(b) GDPR).
• To keep the free limit fair and the service working — the daily counter and the time check (legitimate interests, Art. 6(1)(f) GDPR).
• To improve the job menu by counting jobs in English, without anything that identifies you (legitimate interests, Art. 6(1)(f) GDPR).
• To build the shared word library so words and pictures are reused for all learners (legitimate interests, Art. 6(1)(f) GDPR). It contains no personal data.
• Reminders only if you allow notifications (consent, Art. 6(1)(a) GDPR) — you can switch them off at any time in the app or in iOS Settings.
• Crash reports to keep the app working and fix bugs (legitimate interests, Art. 6(1)(f) GDPR).
• Usage statistics only if you switch them on (consent, Art. 6(1)(a) GDPR) — you can switch them off at any time in Settings.

6. How long data is kept

• On your iPhone: until you reset your progress or delete the app. The daily free-word counter stays in the Keychain until the iPhone is erased.
• Shared word library: for as long as the service runs; it contains no personal data.
• OpenAI: according to OpenAI's API data policy (see above).
• Crash reports and usage statistics: for the periods given in section 3.
• Emails to support: for as long as needed to answer you, then deleted after 12 months.

7. International transfers

OpenAI and Google may process data in the United States. These transfers are protected as follows: Google is certified under the EU–U.S. Data Privacy Framework (with its UK Extension and the Swiss–U.S. framework) and also offers the European Commission's Standard Contractual Clauses in its Firebase data processing terms. OpenAI relies on the European Commission's Standard Contractual Clauses (with the UK Addendum for UK data) in its Data Processing Addendum.

8. Your rights

If you are in the EU/EEA or the UK you have the right to access, correct, delete and restrict processing of your personal data, to object to processing based on legitimate interests, to data portability, and to withdraw consent at any time. Because the app has no account and keeps your data on your iPhone, most of it is already under your control (see section 2). For anything else, contact us.

You can also complain to a data protection authority — in Poland the President of the Personal Data Protection Office (UODO, uodo.gov.pl), or the authority where you live or work.

9. Children

LearnScrumble is made for adults learning the language of their workplace. It is not directed at children under [16].

10. Changes to this policy

If we change what the app collects — for example by sending OpenAI requests through our own server instead of directly from the app — we'll update this page and the effective date before the change reaches the app.

11. Contact

Questions about privacy: support@learnscrumble.com, or by post to [postal address].