Privacy Policy for "Learn German with Practice"

Introduction: This Privacy Policy explains how Nextstapp UG (Haftungsbeschränkt) ("Nextstapp", "we", or "us"), as the developer of the mobile application Learn German with Practice (the "App"), collects, uses, and protects user data. By using the App, you agree to the data practices described in this Privacy Policy.

No Personal Information Collected

We do not collect any personally identifiable information (PII) about you. This means we do not ask for or store your name, email address, phone number, or any other information that can identify you as an individual.

Data We Collect (Anonymous Usage Data)

The only data we collect from the App is anonymous usage statistics and information about your interactions with the App’s AI features. This usage data may include, for example, how often you use the App, which lessons or exercises are accessed, and general trends in how users answer or practice. Any AI interaction data (such as the prompts or responses you provide during practice sessions) is also collected anonymously. We collect this information for educational purposes and to improve the App’s features and content. None of this data contains personal details, and it cannot be used to identify you.

Advertising and Performance Measurement

To support and promote our App, we run advertising campaigns on third-party platforms, such as Meta (Facebook and Instagram). To measure the performance of these campaigns (a process called "attribution"), we have integrated the Meta Ads SDK.

This SDK helps us understand how users find our App. For example, it allows us to know if you installed the App after seeing one of our ads. To make this work, the SDK may collect and share certain data with Meta, including app events (like 'App Install' or 'Purchase'), your approximate location (derived from your IP address), and your device's Advertising ID (IDFA for iOS or GAID for Android). This data is used by Meta to provide aggregated reports to us about our ad performance and is not used by us to personally identify you.

For iOS Users (App Tracking Transparency): On iOS devices (version 14.5 and newer), we are required by Apple to ask for your permission to "track" you across apps and websites. This permission (known as App Tracking Transparency or ATT) is requested via a pop-up.

• If you "Allow" tracking, it enables us to receive more accurate attribution data for our ads and for purchase events, which helps us optimize our campaigns.
• If you "Do Not Allow" tracking, we will not receive your device's Advertising ID for tracking purposes. We will instead rely on Apple's SKAdNetwork framework, which provides us with anonymous, aggregated, and delayed data about installs resulting from our ads.

Third-Party Services

To operate and enhance the App, we rely on a few trusted third-party services. These services process data on our behalf. The third-party services we use are:

• Meta Ads SDK (Facebook): As detailed in the "Advertising and Performance Measurement" section, this SDK is used for ad attribution and performance analytics. It collects device identifiers (like the Advertising ID), app interaction data, and approximate location.
• Google Analytics: Used to track and analyze aggregate usage information (e.g., number of users, session duration, screens viewed). This helps us understand how the App is used and improve user experience. Google Analytics collects usage data such as device information and app interactions.
• Firebase: Used as our cloud backend to store anonymous data (such as usage statistics, progress, or preferences) and to support app functionality. All data stored in Firebase is anonymous and not linked to your identity. We keep this anonymous data in Firebase indefinitely, or as long as needed to support the App and monitor its performance.
• OpenAI ChatGPT API: Used to generate learning exercises and process your responses during AI-driven practice sessions. When you use the AI practice features, your exercise prompts and answers may be sent to the OpenAI ChatGPT service so that the AI can generate a reply or feedback. This data exchange is anonymous – we do not include any information that could identify you. We retain ChatGPT interaction data (for example, the questions you asked and the AI’s replies) for up to 3 months. We do this to review and improve the educational content and AI performance. After 3 months, such interaction data is deleted from our systems.
• RevenueCat: Used to manage subscription purchases and in-app purchases. RevenueCat helps us determine if you have an active subscription and what features to unlock. It processes purchase data from the app stores (Google Play or Apple App Store). No personal payment information (such as your name or credit card details) is ever seen or stored by us – all payment processing is handled by the app stores. RevenueCat provides us with anonymous identifiers, subscription status, and purchase history (e.g., whether your subscription is active or expired) so we can grant access to premium features.

Data Storage and Retention

All anonymous data collected by the App is stored securely using the third-party services mentioned (for example, on Firebase servers). We retain anonymous usage data in Firebase indefinitely, since it helps us track long-term trends and improve the App over time. ChatGPT interaction data is kept for a shorter period (up to 3 months) as noted above. These retention periods mean that, unless we delete it sooner, usage logs and AI interaction records may remain in our database for those durations. However, remember that this data is not linked to you personally.

Data Security

We take data security seriously. All data transmissions between the App and our third-party providers are encrypted via SSL (Secure Sockets Layer). This means that whenever data (such as your usage activity or AI session content) is sent from your device to our servers (or to our service providers), it is protected and cannot be easily intercepted by others. We also rely on the security practices of Google Analytics, Firebase, OpenAI, RevenueCat, and Meta to safeguard the data they process or store for us. Nextstapp UG does not maintain separate servers for user data; we do not store any user data on our own servers outside of the third-party systems described. Because we do not collect personal information, there is a minimized risk in terms of data sensitivity. Nevertheless, we will promptly notify users in the unlikely event of any data security incident affecting the App.

Data Sharing

We do not share or sell any data about our users with any third-party companies, advertisers, or marketers for their own purposes. The anonymous data we collect is used solely for our own analysis and to improve the App. It is only processed by the third-party services listed above on our behalf. The only exception is the data shared with our advertising partners (like Meta) for the specific and limited purpose of measuring our own ad campaign performance and attribution, as detailed in the 'Advertising and Performance Measurement' section. We do not provide your data to any external parties except as needed for the services outlined in this policy, or if required by law (for example, if we are compelled by a legal process to provide data, though since we have no personal data, we generally would have nothing identifiable to provide).

Children’s Privacy

Children may use this App to learn German; however, the App is not specifically directed toward children under the age of 13. We do not knowingly collect any personal information from users, regardless of age. Since the data collected is anonymous and not tied to an identity, the App complies with privacy protections for all ages. Parental supervision is advised for young children using the App, to ensure the content is appropriate and to assist in their learning process. If you are a parent or guardian and you have concerns about your child’s use of the App, feel free to contact us. Because we do not collect personal data, there is no personal information about your child in our systems.

Data Deletion and User Rights

Because we do not collect or store personal data (like your name or email), there is no personal user information for you to request or delete in the traditional sense. However, you have rights regarding your device's Advertising ID and your subscription data.

• Advertising ID: You can reset your Advertising ID or opt-out of interest-based ads at any time through your device's system settings (e.g., in iOS under 'Settings > Privacy & Security > Tracking' or in Android under 'Settings > Google > Ads').
• Data Deletion Request: If you wish to request the deletion of data associated with your anonymous user identifier (such as your subscription status or usage analytics linked to your RevenueCat ID), you may contact us using the details below, and we will process your request in accordance with data protection laws (like GDPR).

If you wish to stop sharing usage information altogether, you can discontinue using the App. Uninstalling the App will stop any future data collection.

Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time. If we make significant changes to how we collect or use your data, we will notify you by a prominent means. This may include an in-app notification, a message on the app’s interface, or an update in the app store listing notes. We encourage you to review this Privacy Policy periodically for any changes. Your continued use of the App after any modifications to the Privacy Policy will signify your acceptance of the updated terms.

Contact Information

If you have any questions, concerns, or feedback about this Privacy Policy or the data practices of the App, please contact us. Our contact details are as follows:

Nextstapp UG (Haftungsbeschränkt) Attn: Serdar Degirmenci (Representative) t Address: Bartschiner Straße 31b, 12355 Berlin, Germany Mobile Phone: +49 178 616 65 81 Email: [Please contact via the app or official store contact information]

Subscription Information

This section explains our App’s subscription service and how it relates to your usage and data.

• The App offers an optional monthly subscription plan. This subscription is designed to unlock unlimited AI-driven practice sessions and other premium features to enhance your learning experience. The exact pricing for the monthly subscription is displayed within the App at the time of purchase (pricing may vary depending on your region or app store requirements).
• Users who do not subscribe can still use the App with some limitations. Free users have a limit of 3 AI practice attempts per day. These daily free attempts allow you to practice and get feedback, but if you reach the limit, you will need to wait until the next day or consider subscribing for more practice.
• The subscription is auto-renewing. This means that once you subscribe, your subscription will automatically renew each month on its renewal date, and your app store account (Google Play or Apple App Store) will be charged for the next month, unless you cancel the subscription beforehand.
• Cancellation of the subscription can be done at any time. You are always in control: if you decide you no longer want the subscription, you can cancel through the Google Play Store or Apple App Store account settings on your device. Once canceled, the subscription will not renew for the next period. You will still have access to the premium features until the end of the current paid month, after which your account will revert to the free version limitations.
• Payments and Billing: All subscription payments are handled through the respective app store platforms. We (Nextstapp UG) do not process your payment information directly and do not store any credit card or billing details. Google Play or Apple handle the transaction securely on their side, and we simply receive a notification that you have purchased or canceled a subscription (via RevenueCat, as mentioned above, which provides us the subscription status).
• Refunds: Any refund requests for subscriptions or in-app purchases are subject to the policies of the app store where you made the purchase. This means if you require a refund or have a billing issue, you will need to request it through Google or Apple support. We, as the developer, do not have the ability to issue refunds directly since all transactions are controlled by the app stores.
• By purchasing a subscription, you gain immediate access to the premium content (unlimited AI practice sessions, etc.). Please note that if you do not cancel at least 24 hours before the end of the current billing cycle, the subscription will auto-renew for the next month. The cost of renewal will be the same as the original price (unless we notify you of a change in price and you agree to it, or you cancel).
• We do not share any information about your subscription outside of the services needed to provide it (i.e., the app stores and RevenueCat for verification). Subscription status is treated as part of your app usage data and thus is anonymous from our perspective (we only see an anonymous user has a valid subscription, not who that user is).