Privacy Policy

1. Overview

This policy describes how the Lingly app handles your data. Lingly has no server of its own. We collect nothing about you, store nothing about you, and see neither your progress nor the texts you write. The free version shows advertising from Google AdMob — that is the only point at which any data leaves your device, and only after you have consented. With Lingly Pro, no advertising appears. We have no analytics tools and no usage statistics of our own, and we share nothing with any other third parties.

2. Controller

Luis Fynn Schenk (Lufy Studios)
Alter Hohlweg 5
58285 Gevelsberg
Germany
info@lufystudios.de

3. What data is involved

• Account data: an anonymous user identifier from Apple, your name and your email address — if you sign in with “Sign in with Apple” and choose to share them.
• Learning data: which lessons you have completed, which words and rules are due when, your XP, your streak, results from the placement and unit tests, and the texts you write in the writing tasks.
• Settings: course direction, daily goal, reminder time, sound, speech rate and feedback.
• Microphone: only during a speaking exercise, and only while you are recording.
• Advertising: in the free version, Google processes device data in order to serve an ad — such as device type, approximate region, language and, if you have consented, your device’s advertising identifier. See section 10.

4. Where the data lives

All of it lives in the app on your device. The course content — words, grammar, conversations, reading texts — is part of the app and never leaves it. Lingly needs no internet connection in order to teach.

5. Sync via iCloud

If you are signed in to iCloud, the app syncs your progress between your own devices. The data then lives in your private iCloud database under your Apple ID, not with us. Apple is responsible for that storage; Apple’s privacy terms apply. We have no access to it and can neither view nor restore your data. Only your progress is synced, not the course content.

6. Sign in with Apple

If you sign in with Apple, the app receives an anonymous identifier, your name and — if you allow it — an email address. Apple offers to hide your real address in the process. These details stay on your device and in your iCloud and are not transmitted to us. The legal basis is your consent under Art. 6(1)(a) GDPR. You can withdraw it at any time by signing out or deleting your account.

7. Microphone and speech recognition

Speaking exercises need the microphone, and only while recording. Recordings are not stored and not sent to us. Apple performs the recognition: if your device can recognise the language itself, everything stays local — the app explicitly requests this wherever it is possible. If your device cannot, the recording is sent to Apple for recognition, and Apple’s terms then apply. Speaking exercises can be switched off entirely under Settings → Sound & Feedback.

8. Notifications

Lingly can remind you at two points: once a day at the time you set, and once when something you have just learned is due for its first review. Both notifications are scheduled and delivered on your device. They pass through no server, contain no data about you, and can be switched off in the settings.

9. Purchases and subscription

Lingly Pro is handled through the App Store. Payment details go to Apple only; we see neither your payment method nor your billing address. All the app learns from Apple is whether a valid subscription exists — no name, no number, no amount. Apple’s terms apply to payment processing.

10. Advertising

The free version is supported by advertising, served by Google AdMob (Google Ireland Limited). In doing so, Google processes device data in order to deliver an ad at all and to detect fraud. We ourselves see none of it — we learn only how often ads appeared, never to whom.

Before the first ad appears, Google asks you in its own form whether personalised advertising is allowed. The legal basis is your consent under Art. 6(1)(a) GDPR. If you say no, advertising still appears — just without personalisation. Apple then additionally asks whether your device’s advertising identifier may be used; there too, saying no does not change whether ads appear, only how they are selected.

You can change your decision at any time: Settings → Ad settings reopens Google’s form. Apple’s prompt lives under iOS Settings → Privacy & Security → Tracking.

With Lingly Pro, no advertising appears. In that case no advertising SDK is started and no consent is requested.

The videos that earn back a heart are a special case: they appear only if you tap them yourself.

What Google receives is your device’s advertising identifier, your interaction with the ads, and technical details about how the SDK runs. Lingly has no analytics tools of its own: apart from Google’s advertising SDK we include no third-party libraries, and we ourselves receive neither usage statistics nor crash reports.

11. Retention and deletion

Your data stays for as long as you use the app. Under Profile → Reset data you delete your learning progress. Under Profile → Delete account you additionally delete your sign-in and your texts — including from your iCloud, and therefore from your other devices. Neither can be undone, not even by us, because we hold no copy. If you delete the app, the iCloud state remains until the next installation.

12. Your rights

You have the rights of access, rectification, erasure, restriction of processing, data portability and objection (Art. 15 to 21 GDPR). Since we hold no data about you, the fastest route is through your device and your Apple ID. For anything else, you can reach us at info@lufystudios.de.

13. Right to complain

You can lodge a complaint with a data protection supervisory authority. The authority responsible for us is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Postfach 20 04 44
40102 Düsseldorf
Germany
Phone: +49 211 38424-0

14. Children

Lingly is not directed at children under 13, or under the minimum age that applies in your country. We do not knowingly collect data from children below that age.

15. Security

We rely on the platform’s security mechanisms: iOS device encryption, “Sign in with Apple”, the private iCloud database and the operating system’s permission system. The app brings no encryption of its own and transmits nothing to servers of ours. No storage is completely secure, but keeping data on the device limits the risk considerably compared with a service in the cloud.

16. Changes

This policy may change, for example when the app gains new features. The date at the top is updated accordingly.

17. Contact

Questions about this policy or about your data: info@lufystudios.de