Privacy Policy
Effective date: 19 August2026
Who we are
We’re a small start-up registered in Vienna, Austria. You can find our company information under our Impressum: https://lingophant.com/impressum/
We treat your data like we want our data to be treated.
As a sole-proprietorship business (e.U.) Alex is personally liable for any violations. Lingophant therefore handle your data with utmost care and sensitivity. We’ll try to write this Privacy Policy in understandable English, in case of questions, please contact our founder under alex@lingophant.com.
This policy explains what personal data Lingophant collects, why, who we share it with, and the rights you have over it. We’ve tried to write it in plain language. Where a section gets technical, that’s usually because the law requires the detail — we’d rather be precise than vague.
The service is operated by Lingophant e.U., a sole proprietorship registered in Austria. We are the data controller responsible for your personal data.
Contact for privacy matters: team@lingophant.com
Full legal details: Impressum
We don’t have a statutory Data Protection Officer, as we’re not required to appoint one. Alexander Hartveld handles data protection questions personally.
1. The short version
- We collect what we need to run the app, understand how it’s used, and — if you allow it — measure which ads bring people to Lingophant. So we can pay less money to the big tech platforms.
- We never sell your data. Voices and phrases are super private. We cannot see the phrases on your mobile app.
- On iOS, we only access advertising identifiers if you tap “Allow” on Apple’s tracking prompt. On Android, only if you consent.
- You can withdraw consent, export your data, or delete your account at any time.
The rest of this policy is the detailed version.
2. Who we share your data with (processors and partners)
We use the following third parties to run the Service. Each processes data on our behalf or as an independent controller for the purposes described. The services do not receive any email addresses, usernames, etc. The server only sends an alphanumeric string.
| Partner | What they do | Data involved |
|---|---|---|
| Google (Firebase, Google Analytics/GA4, BigQuery) | App analytics, crash-free usage metrics, product insight | Device identifiers, usage/event data, advertising ID (when consented) |
| Google (Google Ads) | Measuring ad campaign performance | Advertising ID (when consented), conversion events |
| Google (Sign-In) | “Sign in with Google” | Your Google account email and basic profile |
| Google Translate | Voice-to-text | Audio you record for transcription (we pay 50% more so Google does not store this data!) |
| Apple (AdServices / Search Ads) | Measuring which Apple Search Ads bring users | Campaign attribution token (no advertising identifier) |
| Apple (Sign in with Apple, iOS speech) | Authentication and iOS voice-to-text | Relay email, audio for transcription |
| Meta Platforms | Measuring which ads bring users; social login | Advertising ID (when authorised), event data, Facebook profile via login |
| RevenueCat | Managing your subscription and receipts | An anonymous user ID, purchase/subscription status |
| Sentry | Crash and error diagnostics | Error reports tied to an anonymous user ID |
| (not active yet, an MMP) | ||
| Amazon Web Services (AWS) | Hosting our servers and your uploaded data | All data you store with us |
We sign data processing agreements with these partners where required by GDPR.
3. What we collect and why (purposes and legal bases)
Under GDPR (Art. 6), every use of your data needs a legal basis. Here’s ours, purpose by purpose.
To provide the app and your account — legal basis: performance of a contract (Art. 6(1)(b))
Your account email and login credentials, the phrases and sentences you create, your learning progress, and your subscription status. If you sign in with Apple, Google or Facebook, we receive basic profile information from them to create your account.
To process subscriptions — legal basis: contract (Art. 6(1)(b)); legal obligation for records (Art. 6(1)(c))
Purchase and subscription status via RevenueCat. Payment itself is handled entirely by Apple or Google — we never see your card or bank details.
To transcribe your voice — legal basis: contract (Art. 6(1)(b))
When you use voice input, the audio is sent to Apple (iOS) or Google (Android) for transcription. We don’t store your voice recordings.
To understand how the app is used — legal basis: your consent (Art. 6(1)(a))
Usage and event data through Firebase / Google Analytics — which features are used, where people get stuck, crash diagnostics. This runs only if you agree to product analytics.
To measure and optimise advertising — legal basis: your consent (Art. 6(1)(a))
We wanna pay less to Google, Meta and the likes. If you consent, we collect your device’s advertising identifier — the IDFA on iOS (only if you tap “Allow” on Apple’s App Tracking Transparency prompt) or the Google Advertising ID (GAID) on Android — and share advertising events with Meta and Google to measure which campaigns bring learners to Lingophant. See Section 4.
To keep the Service secure and fix problems — legal basis: legitimate interests (Art. 6(1)(f))
Crash and error diagnostics through Sentry, and security/fraud protection. Our legitimate interest is running a reliable, secure service; we’ve balanced this against your rights and limited what’s collected.
4. Advertising, tracking, and profiling — the detailed part
We run ad campaigns to help people discover Lingophant, and we measure whether those campaigns work. This involves cross-context advertising, which the law treats seriously, so here’s exactly what happens.
On iOS: When you first reach the relevant point in the app, we ask for your consent to ad measurement. Only if you agree, Apple then shows its App Tracking Transparency prompt. Only if you tap “Allow” can we access your IDFA and share advertising events with our partners on that prompt. If you decline either step, no IDFA is accessed, and we fall back to Apple’s privacy-preserving aggregate measurement (SKAdNetwork), which doesn’t identify you.
On Android: We access your Google Advertising ID only if you consent (and only where consent is legally required — for users outside the EU/EEA it may be collected by default, subject to your device’s “Opt out of Ads Personalisation” setting, which we respect).
What this data is used for. Measuring ad performance and optimising which ads are shown — this includes using their automated profiling for advertising purposes, carried out by Meta and Google on the advertising identifier and event data. This profiling does not produce legal or similarly significant effects on you; it determines which ads you may see. It has no effect on your account, your access to the app, or the price you pay. This happens in a “black box”, we don’t see anything about your ad profile, only they receive an information about your behavior in the app.
What it is NOT. The advertising identifier is never linked to the content of your phrases, and it’s never used as your account identity (like email / username). You can withdraw consent at any time (Section 8), after which we stop accessing it.
5. International data transfers
Some of our partners (Google, Meta, Apple, RevenueCat, AWS) process data outside the EU/EEA, including in the United States. Where they do, transfers are safeguarded under the EU–US Data Privacy Framework and/or the European Commission’s Standard Contractual Clauses.
Sentry specifically: we use Sentry’s EU region, so your application error and event data is stored in the EU (Frankfurt). Some account and integration metadata may still be processed outside the EU under the safeguards above.
6. How long we keep your data
- Your account, phrases and profile data: deleted immediately when you delete your account. You can do this yourself from the Profile section of the app, or by emailing us.
- Financial and transaction records: retained for 7 years, as Austrian accounting law (UGB §212) requires. This obligation overrides a deletion request for these specific records only.
- Analytics data (Google Analytics): retained according to Google’s settings, typically up to 14 months.
- Crash/error data (Sentry): retained for a limited diagnostic window, typically around 90 days.
- Advertising identifiers and attribution data: retained by Meta and Google per their own policies for the measurement window.
7. Your rights
Under GDPR you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Delete your data (“right to be forgotten”)
- Export your data in a portable format
- Restrict or object to certain processing
- Withdraw consent at any time, without affecting processing that already happened
To exercise any of these, email team@lingophant.com, or use the in-app tools (account deletion and data export are in the Profile section).
Right to complain. If you believe we’ve mishandled your data, you can lodge a complaint with the Austrian data protection authority:
Österreichische Datenschutzbehörde, Barichgasse 40–42, 1030 Wien — dsb.gv.at
8. Managing your consent
You can change your privacy choices at any time in the app’s settings — both the product-analytics and ad-measurement toggles, and (on iOS) a link to Apple’s tracking settings. Withdrawing consent takes effect immediately: we stop the relevant collection and, where applicable, tell our partners to stop using your data for advertising.
9. Children
Lingophant is not directed at children under 16. We don’t knowingly collect data from children under 16. If you believe a child has provided us data, contact us and we’ll delete it.
10. Signing in with Apple, Google, or Facebook
If you use social login, that provider authenticates you and shares limited profile data (such as your email) so we can create your account. With Sign in with Apple, you can choose to hide your email, in which case Apple gives us a private relay address. Your use of these logins is also subject to each provider’s own privacy policy.
11. Changes to this policy
If we make material changes, we’ll update the effective date above and, for significant changes, notify you in the app or by email. Continuing to use the Service after a change means you accept the updated policy.
12. Contact
Alexander Hartveld, Lingophant e.U.
Linzer Straße 421a/2/7, 1140 Wien, Austria
team@lingophant.com · Impressum