Privacy Policy for Learn Apps

This policy applies to you and Philipp Straub the developer, irrespective of your country of residence or location. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum to make sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information.

This Privacy Policy applies from 10 October 2021.

The Data Controller

The person that is responsible for your information under this Privacy Policy (the “data controller”) is:
Philipp Straub
info@philstraub.com

(hereinafter we, us or our)

Where This Privacy Policy Applies

This privacy policy applies to all flashcard learning apps (Flags of the World, Hiragana and Katakana, Chemical Elements, Capital Cities, American States, US President...). For simplicity we refer to all of these as our “services” in this Privacy Policy. When the word “we” is used, it describes the controller of the APP and includes the relevant service providers that help us to make the services available to you.

When designing the apps we have made sure that no information that directly identifies you is collected. As however some countries including the EU have a broader definition of personal data this policy covers it. In this sense we would need to first of all explore the definition of personal data.

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Information We Collect

To help you enjoying our services, we collect some basic data as you use them, for example access logs, as well as information from third parties. If you want additional info, we go into more detail below.

However, we do not directly collect personal data when you are using our services. In this sense, we will not ask you to provide any personal information when you are using our app.

If you contact us the data you provide will be stored so that your message can be forwarded to the correct contact person. This is done in accordance with Article 6 lit. f) GDPR to process your request. Your data provided will not be used for any other purposes, in particular not for advertising.

Usage Information

We collect information about your activity on our services, for instance how you use them and how you interact with our services. Further details you can find below.

Device information

We collect information from and about the device(s) you use to access our services, including:

• hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);

Google Firebase

Our apps use services from Google. Some Google services process personal data from you as an end user. This is necessary for the provision of Google services. You can find out which data is processed and for what purpose in the Google Privacy Policy. Google often uses "instance IDs" which, according to Google's information, are stored until the end customer makes an API call to delete the ID. After that, the data is deleted from the live and backup system 180 days after the call. More information can be found here. These instance IDs are determined, for example, to know which device notifications should be sent to. However, we do not receive any personal data from Google and make no effort to personalise this data afterwards. We only use the data to analyse user behaviour.

We do not assume any guarantee for the above-mentioned data from Google and only refer to the information provided. Google is entitled to change or delete this information at any time, to delete or change the URL (link to Google web sites) or to provide the information on another page. Google constitutes a data processor for the App pursuant to Art. 28 of the GDPR.

As a data processor outside the European Economic Area (EEA), Google is subject to certain framework conditions that they must comply with in order to ensure equivalent protection as within the EEA. This protection is secured by the standard contractual clauses between Google and you can read them when following this link.

For Firebase Analytics, Google also uses the advertising ID of the mobile device in addition to the "instance ID" described above. You can restrict the use of the advertising ID in the device settings of your mobile device.

For Android: Settings > Google > Ads > Reset Ad ID

Google Admob

The app also uses the Google Admob service to display ads. Ads are personalised based on the device you are using. You can disable this via the settings on your device. You can find more information about ad tracking using this ad ID in the Settings app on your device.

The Google Admob service is provided by Google (Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA). General information on the handling of user data can be found in Google's privacy policy.

How We Use Information

The main reason we use your information is to deliver and improve our services. Additionally, we use this info to help keep you safe. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

• To provide our services to you,
• To create and manage our App and provide new features,
• To improve our services and develop new ones,
• To conduct research and analysis of users’ behaviour to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour),
• To prevent, detect and fight fraud or other illegal or unauthorized activities,
• To perform data analysis to better understand and design countermeasures against these activities
• To ensure legal compliance
• To assist law enforcement
• To enforce or exercise our rights.

To process your information as described above, we rely on the following legal bases:

Provide our service to you

Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service or when you purchase additions to the game through Google Play Services.

Legitimate interests

We may use your information where we have legitimate interests to do so. For instance, we analyse users’ behaviour on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

Consent

From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

How We Share Information

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, payment for additional content and security operations.

We may also share information with our secure payment gateway provider Google Pay, and you may need to provide credit or debit card information directly to Google in order to process payment details and authorise payment following a secure link. The information which you supply to in such cases is not within our control and is subject to Google’s own Privacy Notice and Terms of Use which you can find here and here.

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioural data,), as well as personal information in hashed, non-human readable form, under any of the above circumstances.

Your Rights

We want you to be in control of your information, so we have provided you with the following:

Information, deletion and correction

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if necessary, a right to correction or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.

If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.

If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request restriction of the processing of your personal data instead of erasure.

Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact us to provide their written consent before the information is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you any more.

Uninstall

You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

Accountability

In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

How We Protect Your Information

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security.

How Long We Retain Your Information

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services any more.

In practice, we delete or anonymise your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

• we must keep it to comply with applicable law;
• we must keep it to evidence our compliance with applicable law ;
• there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
• the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.
• Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.

Changes

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

How To Contact Us

If you have questions about this Privacy Policy, please contact us using the details provided.