TripleTalk Privacy Policy

1. The controller of your personal data is craftApp ("we").
2. Contact for all data protection matters: support@tripletalk.app.

• We collect only the data needed to run the App.
• We do not sell data, show ads or track you for advertising.
• In School a student provides only a first name, and the teacher does not see students' detailed progress.
• Content you send to AI features goes to the AI provider only to perform the selected feature.
• You can delete your account and data at any time in the App.

Legal bases under Art. 6(1) GDPR: (b) performance of the contract (Terms), (a) consent, (c) legal obligation, (f) our legitimate interest.

We do not process special categories of data (e.g. health data) unless you put them in your own content. Please do not.

Providing data is voluntary, but the App cannot be used without account data. We do not make decisions based solely on automated processing that produce legal effects for you. You can challenge automated anti-abuse measures (e.g. refusal of the welcome bonus) by contacting us, and a person will review the case.

1. A student provides a first name (a nickname is fine) and receives a permanent student code. We also process: class list, invitation statuses (pending, accepted, declined, expired) with dates, the list of blocked teachers, lesson progress (which flashcards were marked as known; each "Know" also adds to the study statistics on the student's account, which the teacher does not see) and the date the student confirmed being at least 16 or having a parent's or guardian's consent.
2. A teacher provides a display name. We also process: the teacher's classes, lessons (including those in the teacher's archive), flashcards, audio, shares and counters needed for limits (e.g. invitations per day, lessons in the archive).
3. Who sees what:
   • the teacher sees a student's first name, code and status in the class, and the total number of students who have started a lesson. The teacher does not see a student's detailed progress,
   • the student sees the teacher's name, the class name and shared lessons,
   • students cannot see each other,
   • when looking up a student by code, the teacher sees only the first name linked to that code.
4. Students decide who to give their code to. A teacher cannot invite a student without the code.
5. When School data is deleted:
   • leaving a class or being removed from it: membership and progress in that class,
   • deleting a class: the class, memberships, shares and students' progress,
   • moving a lesson to the teacher's archive: its shares in all classes, with students' progress, and photos uploaded for that lesson. The lesson, flashcards and audio stay in the archive, visible only to the teacher, until the lesson is restored, deleted from the archive, the role is reset or the account is deleted,
   • deleting a lesson from the archive for good: the lesson, flashcards and audio,
   • role reset: data for that role. The student code, the student's blocks and the teacher's daily invitation counters remain until the account is deleted, so a reset cannot be used to bypass protections and limits,
   • account deletion: all School data, including the student code and blocks.
6. School lessons are not added to the archive described in section 8. The teacher's archive in point 5 is a different feature: it keeps lessons on the teacher's account, fully linked to it, only so the teacher can restore them.
7. If a teacher uses School as part of work at a school or other institution and the institution needs a data processing agreement or additional information, contact us.

1. To make sure the welcome bonus goes to one person only once, the App saves a random installation identifier on your device. It is kept in a protected part of the device's storage.
2. Only an irreversible hash of this identifier, and similar hashes of your sign-in details (email address, Google or Apple account), are sent to our server. Neither the identifier nor your email address can be recovered from a hash.
3. The hashes are used only to check whether the bonus has already been granted. They remain after account deletion, unlinked from the account, so that deleting and re-creating an account cannot be used to get around the rules. We keep them for 3 years from granting the bonus and then delete them automatically. If the account still exists, the hash is written again at the next sign-in so the bonus cannot be claimed twice.
4. The legal basis is our legitimate interest (preventing abuse). You may object (section 11).
5. We also check that requests come from the genuine App installed on a real device, using Apple and Google services (App Check). They do not collect content from your device.

1. Photos and text you send to AI features are passed to the AI provider (Google) only as needed to perform the feature: text recognition, translation, examples, language information, pronunciation audio and picking a lesson icon that fits its name (also in School).
2. In School, class names, lesson titles and flashcard words and examples are sent to AI before they are saved, to check automatically that they contain no vulgar or offensive content (Terms section 8(6)). Based on the result the content is saved or rejected. You can challenge this by contacting us.
3. Do not send photos containing personal data (e.g. faces, documents, students' names). If a photo contains such data, it will be processed together with the rest of the photo.
4. AI content may contain errors. Check it before you study.

1. Service providers processing data on our behalf and on our instructions:
   • Google Firebase and Google Cloud: sign-in (Authentication), database (Firestore), files (Cloud Storage), server functions (Cloud Functions), notifications (Cloud Messaging), App Check, Crashlytics, Analytics, Performance Monitoring,
   • Google Gemini: AI features,
   • Google Cloud Text-to-Speech: pronunciation audio,
   • RevenueCat: handling and verifying in-app purchases (receives your account ID and store transaction data),
   • Cloudflare: serving the tripletalk.app website (section 14),
   • Google Analytics: visit statistics for the tripletalk.app website, only with your consent (section 14).
2. Apple and Google as operators of the app stores and sign-in services. Purchases and sign-in via Apple or Google are also subject to their privacy policies.
3. Other users in School, as described in section 4(3).
4. Public authorities, where required by law.

We may change the list of providers. The current list is always in this Policy.

1. Your own flashcards and lessons that you delete (including on account deletion) may be moved to an internal archive without data about your account.
2. We use them to improve learning materials and AI features and to create public collections, in a way that does not identify the author.
3. If a flashcard contains personal data (e.g. your name or someone else's data), contact us and we will remove it from the archive.
4. Identical pronunciation recordings are shared in the audio library without being linked to an account and remain after the account is deleted.

Some providers (Google, RevenueCat, Apple, Cloudflare) may process data outside the European Economic Area, in particular in the USA. In that case we rely on safeguards required by the GDPR: a European Commission adequacy decision (the EU-US Data Privacy Framework, where the provider is certified) or Standard Contractual Clauses. You can obtain a copy of the safeguards by contacting us.

You have the right to:

• access your data and receive a copy,
• rectify your data,
• erase your data,
• restrict processing,
• data portability for data you provided to us,
• object to processing based on our legitimate interest (including analytics and welcome bonus safeguards),
• withdraw consent at any time (e.g. by turning off notifications in your phone settings or changing your choice with the "Cookies" button in the website footer), without affecting the lawfulness of earlier processing,
• lodge a complaint with the Polish supervisory authority (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw) or the supervisory authority in your country of residence.

Write to support@tripletalk.app from the email address linked to your account. We reply within 14 days and may ask you to confirm your identity.

1. You may create an account on your own from the age of 16. Younger people may use the App only with the consent of a parent or guardian.
2. School is designed with students in mind, including minors: it requires only a first name, has no chat, students cannot see each other and the teacher does not see detailed progress.
3. A parent or guardian may exercise the rights in section 11 on the child's behalf, including requesting deletion of the account. If we learn that we process a child's data without the required consent, we will delete it.

1. The App may ask for access to: camera (photo of text), photo library (choosing a photo) and notifications (reminders, School invitations). You can turn off any permission in your device settings.
2. On your device we store, among other things, settings, a cache of audio and flashcards, and the installation identifier described in section 5. Deleting the App removes most of this data. On iOS the secret in Keychain may remain after the App is deleted, as the system works this way.

1. The tripletalk.app website is served through Cloudflare. On every visit Cloudflare processes your IP address, browser details and the address of the page you open, to deliver the website and protect it from attacks. The website also uses this to recognise the visitor's country and show it in the right language. The legal basis is our legitimate interest (f).
2. If you consent in the cookie banner, we use Google Analytics to understand how visitors use the website: which pages they view, how they scroll, which outbound links they click, their approximate country or city, and the device and browser they use. Google Analytics stores the _ga and _ga_* cookies with a pseudonymous identifier in your browser. The legal basis is your consent (a).
3. Without consent, Google Analytics is not loaded and stores no cookies. We do not use website data for advertising and do not link it to your App account.
4. You can change or withdraw your consent at any time with the "Cookies" button in the website footer. Withdrawing consent deletes the Google Analytics cookies. The website remembers your consent and language choice in your browser's storage and does not send them to us.

We apply technical and organisational measures appropriate to the risk: encrypted connections, database access rules (e.g. a teacher's lessons are visible only to the teacher and their classes), App Check verification, rate limiting, and server-side enforcement of permissions and limits. If a personal data breach is likely to result in a high risk to you, we will inform you without undue delay.

We will inform you of material changes in the App before they take effect. The current version is always available in the App and at tripletalk.app.