Privacy Policy

This policy explains what personal data the Pretzly app for Android and iPhone (formerly Faultier and Faulingo; “the app”) collects, why, who processes it on our behalf, and the rights you have. “We” and “us” mean the data controller named below.

Data controller

Pavel Vaitsikhouski, Germany. Contact: faulingo.app@gmail.com.

What we collect

Your account

• A random user ID. The app signs you in anonymously the first time it opens. No name or email is needed to use it.
• Email address and name, only if you sign in with Google or Apple, as that provider shares them on your first sign-in. Apple may give us a relay address instead of your own.
• Nickname and display name, which you choose.
• Learning settings: native language, German level and daily goal.

What you do in the app

• The words you add or edit, with notes and example sentences, and the tags you file them under.
• Your answers to exercises, your streaks and daily progress.
• Tags you share or join. Everyone who joins a shared tag sees its name and its words.

Usage and device data

• Which screens and features you use, and errors the app runs into, linked to your user ID (and, once you sign in, to your email, name and nickname), recorded by PostHog.
• Device type, operating system and app version, IP address, and similar technical data sent with every request.

Purchases

Subscriptions are paid through Google Play or the App Store; we never see your card or account details. RevenueCat tells the app what you bought and keeps the record of your subscription, linked to your user ID, email and name.

Kept only on your device

• Reminder times and whether you allowed notifications.
• Listen Mode settings and similar preferences.
• On iPhone, Focus Mode (below).

The app shows no ads and does not use your device’s advertising ID. We do not sell your data.

Why we use it, and the legal basis

• To provide the app — your account, your words, exercises, progress, shared tags and subscriptions (performance of a contract, Art. 6(1)(b) GDPR).
• To understand and improve the app — usage analytics and error reports, and to keep the service secure (legitimate interests, Art. 6(1)(f) GDPR).
• To contact you about your account or a request you made, and to send reminders you turned on (performance of a contract; consent for notifications, which you can withdraw in your phone’s settings).
• To meet legal obligations, such as keeping purchase records (Art. 6(1)(c) GDPR).

Who processes your data

• Supabase — sign-in and the database that holds your account and learning data. supabase.com/privacy
• PostHog (EU hosting) — usage analytics, error reports and the settings that tell the app when an update is needed. posthog.com/privacy
• RevenueCat — subscription management. revenuecat.com/privacy
• Google — Sign in with Google, Google Play Billing and Android backup (below). policies.google.com/privacy
• Apple — Sign in with Apple and App Store purchases. apple.com/legal/privacy
• ElevenLabs — the voices that read words aloud in Listen Mode and in exercises. Only the text being read (a German word, its translation or an example sentence) is sent, without your user ID or anything about your device. elevenlabs.io/privacy
• OpenAI — completes a word you add with Autofill (its gender, forms and example sentences) and writes some practice sentences. Only the word and the languages involved are sent, without your user ID or anything about your device. openai.com/policies/privacy-policy

Android backup

On Android, the app allows the system’s own backup. If backup is on in your phone’s settings, Android saves the app’s sign-in session and preferences to your Google account, encrypted, so a new phone restored from it opens the app as you, with your progress. Google stores this backup; we cannot read it. You can turn backup off in Android’s settings.

Focus Mode (iPhone only)

Focus Mode uses Apple’s Screen Time framework to block apps you choose until you finish the day’s practice. Your choice is stored as tokens Apple’s framework gives the app, which cannot be turned back into app names or websites; we never see which apps you chose or what you do in them. All Focus Mode data stays on your iPhone and is removed when you turn Focus Mode off or delete the app.

Where your data is processed

Our providers may process data outside your country, including in the United States. Where data leaves the EU, it is protected by the provider’s Standard Contractual Clauses or an adequacy decision such as the EU–US Data Privacy Framework.

How long we keep it

Account and learning data are kept until you delete your account. Usage analytics are kept while they help us improve the app, and deleted on request. Purchase records are kept as long as tax and accounting law requires. Deleted data can remain in encrypted database backups for up to 30 days.

Deleting your account

You can delete your account in the app, or by email. What is deleted and what is kept is explained on Delete your Pretzly account.

Your rights

Under the GDPR you have the right to access your data, to have it corrected or erased, to restrict or object to its processing, to receive it in a portable format, and to withdraw consent at any time without affecting earlier processing. Write to faulingo.app@gmail.com; we answer within one month. You can also complain to a data protection authority, in particular in the EU country where you live or work. Ours is the Berliner Beauftragte für Datenschutz und Informationsfreiheit (datenschutz-berlin.de).

Disclosure

We disclose personal data only to the processors above, when the law requires it (for example a court order), to protect the rights and safety of users or of the service, or, if the app changes hands, to its new owner, who would be bound by this policy and of which we would tell you in advance.

Security

Data travels encrypted between the app and our servers, and only the app’s own functions can read or change it. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Children

The app is not directed at children under 13, and we do not knowingly collect their data. If you believe a child under 13 has given us personal data, write to us and we will delete it.

Changes to this policy

We may update this policy. The date at the top shows the latest version; for significant changes we will also tell you in the app before they take effect.

Contact

faulingo.app@gmail.com