Privacy Policy

Effective date: 5.08.2025

Data Controller: Daniel Dimitrov

Contact Email: daniel@snaptolearn.ai

Registered in: Germany

Who Is This App For?

This language learning app is designed for learners of all ages — especially children aged 9 and up. It helps users practice vocabulary by scanning real-world materials and interacting with them through handwriting or keyboard input.

We believe in privacy-first learning. This policy explains what data we collect, why we collect it, and how we keep it safe — all in simple terms.

Summary: What We Do and Don't Do

• ✅ We do not collect names, emails, or any personal account info in this version

• ✅ We do not track your handwriting or store your strokes

• ✅ We do not store your learning data online (it stays on your device)

• ✅ We use on-device AI and secure cloud AI (Google Gemini) to help with learning

• ✅ We use analytics and error tracking to improve the app — but no ads, and no data selling

• ❌ We do not use data for identification

• ❌ We do not use handwriting to recognize who you are

What Data Do We Collect?

1. Anonymous Usage Data

We collect non-personal information to understand how the app is used and how to improve it. This includes:

• Screens visited

• Time spent practicing

• Device type and language

• Crash and error reports

This is done using Firebase Analytics and Firebase Crashlytics.

Legal Basis: Legitimate interest (improving the service)

2. Scanned Content

When users scan vocabulary (e.g., a book, magazine, handwritten notes), the image is sent securely to Google Gemini, a cloud-based AI, to extract words, examples, and hints.

We do not collect or store these images — they are sent anonymously, processed, and deleted after use.

Content may include third-party authored text (e.g., from books). The user is responsible for ensuring that the content is appropriate for scanning.

Legal Basis: Consent (user-initiated scan)

Dictations: when you check a dictation, the photos or screen pages of your handwriting are uploaded and read by Google Gemini to find your mistakes. The uploaded pages are deleted as soon as they are read. A copy of each page and the result stay on your device. The text of a dictation is read aloud by ElevenLabs; it receives only that text, which the app writes from your deck words.

Legal Basis: Consent (user-initiated check)

3. Local Learning Progress

Your learning history (words practiced, mistakes, streaks) is saved only on your device, using secure local storage (MMKV). We do not sync this data to the cloud unless you explicitly opt in when sync features are introduced in the future.

Legal Basis: Performance of contract (providing the learning service)

4. Push Notifications

If you allow notifications, we can tell you when a scan is ready and remind you to study at the time you choose. If you also say yes to New features & tips, we send a short note when something new arrives, at most once a month. It can be tailored to the language you are learning.

For this we store a device token (a random ID from Firebase Cloud Messaging), your app language and your notification settings. It is not linked to your name or email, and it is deleted once it is no longer valid.

You can turn notifications off at any time in Profile or in your device settings. Turning off news doesn't affect scan and reminder notifications.

Legal Basis: Performance of contract for scan and reminder notifications; consent for news, which you can withdraw at any time

Future Features (Optional)

We plan to introduce features like:

• Account creation (e.g., Google login)

• Cloud sync for learning history

• Duel mode and multiplayer learning

• Cross-device usage

When those features become available, we will request your consent before collecting any personal data. Parents will have full control over children's accounts.

Children and Parents

This app is suitable for children aged 9 and up, but children under 13 (as per German law) must not use any future account or multiplayer features unless a parent or guardian provides verifiable consent.

Parents can contact us anytime at daniel@snaptolearn.ai to:

• Ask about their child's data

• Request data deletion

• Ask questions about this policy

Data Storage and Retention

• Learning progress is stored locally on your device.

• Analytics and errors are stored in Firebase (Google Cloud), in the EU or US, for a limited time.

• Notification device tokens and settings are stored in Firebase (Google Cloud) while the app can still receive notifications.

• Scanned content images are not stored by us or Google Gemini after processing.

• Dictation pages are stored in Firebase (Google Cloud) only until they are read, then deleted. Copies stay on your device until you delete the dictation or its deck.

Who Do We Share Data With?

We do not sell or share your personal data.

We do use trusted service providers as data processors:

All providers comply with GDPR and implement strong security standards.

Your Rights (GDPR)

If you're located in the EU or EEA, you have the right to:

• Access your data

• Request correction or deletion

• Object to certain processing

• Withdraw consent at any time

• File a complaint with your local data protection authority

You can exercise your rights by contacting us at daniel@snaptolearn.ai.

Security

We take privacy and security seriously. All transmissions to cloud services use end-to-end encryption (HTTPS). We minimize the data we collect and keep everything stored securely.

Updates to This Policy

We may update this policy as the app evolves. We'll notify users of major changes and ask for consent again if needed.

Last updated: 13.10.2026

Questions?

We're happy to talk! Contact us at daniel@snaptolearn.ai with any questions, concerns, or requests.