DE EN TR RU AR

Privacy Policy

Last updated: June 2025

1. Controller

The data controller is: Devcode LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. Email: [email protected]. Company Number: 14284192.

Devcode LTD provides services to users in the European Union and complies with both UK GDPR and EU GDPR where applicable.

2. Data we collect

We process only the data necessary to operate the app:

  • Email address (if you create an account – optional)
  • Anonymous user ID (assigned on first app launch)
  • Device identifier (for app operation and troubleshooting)
  • Purchase information and subscription status (processed by RevenueCat)
  • App usage interactions: learning progress, session duration – no personal notes or content
  • Crash reports and error logs (anonymised, processed by Firebase Crashlytics)

3. Third parties

We use the following third-party services:

  • RevenueCat, Inc. (USA): subscription and in-app purchase management. Privacy policy: https://www.revenuecat.com/privacy
  • Google LLC / Firebase Crashlytics (USA): crash reports and app stability monitoring. Privacy policy: https://firebase.google.com/support/privacy
  • Meta Platforms, Inc. (USA): Meta integration is currently inactive (App ID not configured). This policy will be updated when activated.

4. Legal basis

Contract performance (Art. 6(1)(b) GDPR): data necessary to provide the app and subscription.

Legitimate interests (Art. 6(1)(f) GDPR): operating, securing and improving the app (e.g. crash analysis).

Consent (Art. 6(1)(a) GDPR): for optional account registration.

5. Retention

Account data is retained while the account is active and deleted within 30 days of account deletion.

Anonymous usage data and crash logs are deleted after 12 months at the latest.

Purchase records are retained in accordance with applicable tax retention requirements (up to 7 years).

6. Your rights

You have the following rights under GDPR:

  • Access (Art. 15): request a copy of the data we hold about you.
  • Rectification (Art. 16): correct inaccurate data.
  • Erasure (Art. 17): delete your data (see also Section 7).
  • Data portability (Art. 20): receive your data in machine-readable format.
  • Object (Art. 21): object to processing based on legitimate interests.
  • Restriction (Art. 18): restrict processing in certain circumstances.
  • Lodge a complaint with a supervisory authority: primarily the UK Information Commissioner's Office (ICO) at https://ico.org.uk; EU users may also contact their national data protection authority.

7. Delete your account and data

You can delete your account at any time in the app: Profile → Settings → Delete account. All personal data is permanently removed within 30 days.

Alternatively, contact us by email: [email protected]

8. EU Representative (Art. 27 GDPR)

As a UK-based company processing data of EU residents, we are evaluating our obligations under Art. 27 GDPR regarding the appointment of an EU representative. This policy will be updated accordingly.

9. Contact

Privacy enquiries: [email protected]