Privacy Policy

Sprachnest

1. Overview

Sprachnest (the "App") is a personal German-learning companion: vocabulary cards, grammar drills and exam-style practice. It has no accounts and no sign-up and shows no ads. Everything you learn stays on your device: HollyByte runs no servers for the App and never receives your cards, answers, texts or progress.

The App works offline. Data leaves your device only in three cases: crash reports (technical data, Section 6), usage statistics — only if you turn them on (Section 6), and the optional AI assistant (Section 4), which is off by default and, when you turn it on with your own API key, talks directly to the AI provider you chose. This policy explains what data the App touches, where it lives and when anything leaves your device.

2. Data We Collect

We (HollyByte) never collect your learning data — your cards, answers, texts, transcripts, photos, profile and progress stay on your device. What reaches us, through Google Firebase, is limited to:

• Crash reports — technical data sent automatically when the App crashes (Section 6);
• Usage statistics — only with your consent, off by default (Section 6);

And nothing else:

• No registration, no account;
• No advertising SDKs, no ads and no advertising identifiers;
• No access to your contacts, location or any other personal information. The microphone and a photo you pick are used only when you practise Sprechen yourself (Sections 3–5), and nothing reaches us;
• No other requests to us or to any third party — the optional AI requests described in Section 4 go directly from your device to the provider you chose and never pass through us.

3. Your Data on the Device

The following is stored in a local database and the App's settings inside its private storage on your device. Only the App can read it; we have no copy and no way to access it:

• the words, cards, notes, own associations and learning progress you create;
• your study plan (target level, pace, exam date, streak and reminder time);
• your optional "About me" profile (name, where you are from, city, work, family, hobbies — every field is optional);
• your Schreiben (writing) practice: the texts you write, your self-checks and the AI feedback you requested — deleting an attempt erases its text and feedback;
• Lesen & Hören sets written by the AI assistant at your request and your practice attempts with them — deleting a set erases its texts, your note and those attempts;
• your Sprechen (speaking) conversations: the recognised text of your answers (never audio), the examiner's lines, the cards used, your self-check and the AI feedback you requested — deleting a conversation erases all of it;
• cards made from your own photos: the photo you picked (downscaled, without location or camera data) and the card text — deleting a card erases the photo and the card;
• the answers of the AI assistant, kept so that the same suggestion can be shown again without a new request;
• your AI settings: the chosen provider, quality mode and the consent you gave.

Your AI provider API key is not stored there — see Section 4.

• Deleting the App deletes all of this data.
• Your operating system's own device backup (iCloud Backup on iOS, Google backup on Android) may include the App's data under your account, governed by Apple's or Google's terms — Sprachnest does not control or use those backups. Your API key is excluded from these backups.
• Backup file. Only when you tap "Create backup" in Settings, the App writes one file with your cards and progress, study plan and settings, "About me" profile, Schreiben texts, Sprechen transcripts and the photos of your own cards. It does not contain your API key, your AI consents or reminder settings. The file is not encrypted; the App hands it to the system share sheet, and you decide where it goes (for example Files, a cloud drive or a message to yourself) — it never passes through us. "Restore from backup" reads a file you pick and replaces the data on the device.

4. Optional AI Assistant (Your Own API Key)

Off by default. To use it, you choose a provider — Anthropic (Claude) or OpenAI (ChatGPT) — in Settings → AI assistant and enter an API key from your own account with that provider. Before the first key for a provider is saved, the App shows what will be sent and asks for your explicit consent. Without a key, every other part of the App works as usual.

When data is sent. Only when you tap an AI action yourself — for example, "Suggest" in "My association", "Evaluate with AI" for a finished Schreiben text or Sprechen conversation, "Create" for a new Lesen & Hören set or "Create card" for your own photo. A Sprechen conversation "With AI examiner" is one action you start yourself; during it, each answer you finish sends one request for the examiner's next line, and nothing is sent while you are silent or listening. Nothing is sent in the background, at start-up or during a review session without such an action. When you save a key, the App makes one request to check it (it asks the provider for the model's metadata; no learning data is sent).

What is sent. Only the data of that task:

• for associations: the German word, its translation, its grammatical gender, your explanation language (Ukrainian or Russian) and the fields of your "About me" profile that you filled in (empty fields are never sent);
• for Schreiben feedback: the writing task (situation, points to cover, formal or informal address), the text you wrote, your explanation language and the list of the App's grammar topics — without your "About me" profile, the model answer or your other attempts;
• for a new Lesen & Hören set: your target level, the exam part, the topic, the note you typed (if any), the titles of the sets that already exist for that part and — only if you keep "Use my About me profile" switched on — the fields of your "About me" profile that you filled in. To check the set before it is saved, the App sends the generated set back to the same provider (up to four requests for one "Create") — without your profile. Your answers, attempts and scores are not sent.
• for Sprechen with the AI examiner: your level, the exam part, the text of the card or task (words, situation, a written description of the photo — never a photo), the recognised text of your answers in the current part (text, never audio) and the examiner's lines — without your "About me" profile;
• for Sprechen feedback: your level, whether it was a full practice run or one part, the cards and tasks of the conversation, its transcript (typed answers are marked), your explanation language and the list of the App's grammar topics — without your "About me" profile, audio, your self-check or other conversations;
• for a card from your own photo: the photo you picked (downscaled to at most 1280 pixels and re-encoded without location or camera data), your target level and explanation language — only when you tap "Create card" (a second request with the same photo if the first card needs a fix). Please do not photograph people without their consent, documents or personal data.

Your review history, progress, statistics, other words, other writing attempts and any device or app identifiers are never sent. Please do not put personal details into a practice text that you would not want the provider to see.

Where it goes. Directly from your device to the provider's API over an encrypted connection (HTTPS): api.anthropic.com or api.openai.com. There is no HollyByte server in between — we never see your requests, the answers or your key. The provider processes, bills and may retain this data under your account and its own terms and privacy policy: Anthropic, OpenAI. HollyByte receives none of this data; the provider processes it as its own controller under your account, and its servers may be outside the EU (for example in the USA) under the safeguards described in its privacy policy.

Your API key. It is kept only in the device's secure storage — the iOS Keychain (accessible on this device only, not included in backups or transferred to a new device) or Android's Keystore-encrypted storage (excluded from Android backup). It is never written to the App's database, settings or logs, and is sent only to the API of its own provider. You can delete the key or turn the AI assistant off at any time in Settings → AI assistant; turning it off stops all AI requests.

5. Permissions

• Notifications — requested only when you turn on the daily reminder (during setup or in Settings). Reminders are local notifications scheduled by the operating system on your device; no push servers (APNs/FCM) are involved and nothing is sent anywhere. You can turn the reminder off in the App or revoke the permission in your system settings at any time.
• Network access — used only for the optional AI assistant (Section 4). On Android it is granted at install time and shown as "full network access"; iOS does not ask for it.
• Microphone and speech recognition — requested only when you first tap the microphone in Sprechen, after an explanation in the App. Your speech is recognised by your phone's system: on iOS by Apple's speech recognition (on the device where supported, otherwise on Apple's servers), on Android by Google's or your manufacturer's speech service, which may process the audio on its servers under its own terms. The App does not record or store audio; only the recognised text is kept on your device. The microphone is on only while you record an answer. Without these permissions you can type your answers instead.
• Camera and photos — only when you add your own photo in Sprechen. The App uses the system photo picker, which shares only the photo you pick, not your whole library; iOS asks for camera access when you take a photo, and on Android the system camera app is used.

Pronunciation is synthesised on your device – by the voice built into the app or, if you choose it in the settings, by your device's text-to-speech – and needs no permission; no text or audio leaves the device. The photos on the built-in Sprechen cards ship with the App (Unsplash License; the author is shown on each card); the App never downloads photos.

6. Crash Reports and Usage Statistics

To keep the App stable and to understand which parts of it are used, the App uses Google Firebase. Neither stream ever contains your learning content.

• Crash reports (Firebase Crashlytics) — sent automatically when the App crashes: where in the code the error happened (stack trace), device model, operating system and App version, and a Firebase installation identifier. No answers, texts or other learning data are added to them. Retained by Google for 90 days. You can turn crash reports off at any time in Settings → Privacy → Crash reports: sending stops immediately, and reports not yet sent are deleted;
• Usage statistics (Google Analytics for Firebase) — only with your consent. The switch is on the last onboarding step and is off by default; you can change it at any time in Settings → Privacy → Usage statistics, and collection stops immediately when you turn it off. With consent, the App sends which screens are opened (as route templates, without record identifiers) and facts about actions — for example "lesson completed", the level, the exam part, or which AI feature was used and whether it succeeded — plus your learning plan (target level, explanation language, pace), App version, device model and language. Events never contain your answers, texts, transcripts, photos, scores, exam date, "About me" profile or AI keys. A pseudonymous app-instance identifier is used; Google Analytics does not log or store IP addresses. Retained for 2 months;
• No advertising identifiers: the App collects neither the Android advertising ID nor the iOS IDFA, shows no App Tracking Transparency prompt and does no tracking. Data is never sold;
• Firebase data is processed by Google LLC on our behalf under the Firebase Data Processing Terms. Processing takes place in part on servers in the USA, safeguarded by the EU-U.S. Data Privacy Framework and Standard Contractual Clauses.

Usage statistics rely on your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time; crash reports rely on our legitimate interest in keeping the App working (Art. 6(1)(f) GDPR), and you can object to them with the switch above. Both streams are pseudonymous — we cannot identify you from them. Your rights are described in Section 9.

7. Beta Testing

While Sprachnest is in closed testing, you can join through Apple TestFlight or Google Play testing. Apple and Google run these programmes under their own terms and privacy policies.

• TestFlight. If you join through our public link, App Store Connect shows us neither your name nor your email address — only that an anonymous tester installed the build, the number of sessions and crashes. If we invite you by email, we see the address we used. If you send feedback from TestFlight, we receive your comment, screenshot and device information as Apple delivers them;
• Google Play. You join by becoming a member of our Google Group: as its owner we can see the email address of your Google account. Play Console shows us only aggregated numbers about testers; private feedback you send in Google Play reaches us as you wrote it.

We use this data only to run the test and to answer your feedback (Art. 6(1)(f) GDPR — our interest in testing the App before release). You can leave the group or TestFlight at any time; we delete the group members and their feedback when the beta ends.

8. This Website

The Sprachnest pages on hollybyte.com use no cookies, no analytics and no tracking, and load no third-party resources: fonts are served from our own server. The server, hosted by Contabo GmbH in Germany, keeps a standard access log — IP address, date and time, the page requested, the referring page and your browser's user agent — to deliver the site and keep it secure (Art. 6(1)(f) GDPR). The log is kept only for that purpose and is deleted automatically by regular log rotation.

9. Your Rights

Under the GDPR the controller is Oleksandr Nesterov (HollyByte), contact: sprachnest@hollybyte.com. You have the right to access your data (Art. 15), to have it rectified (Art. 16) or erased (Art. 17), to restrict its processing (Art. 18), to data portability (Art. 20) and to object to processing based on legitimate interest (Art. 21) — for crash reports, simply turn them off in Settings → Privacy. You can withdraw your consent to usage statistics at any time in the same place; this does not affect processing before the withdrawal.

Crash reports and usage statistics are pseudonymous: we can relate them to you only if you give us the identifiers (Art. 11 GDPR). Reinstalling the App resets them. Your learning data never reaches us, so we hold nothing else about you.

You are not obliged to provide any personal data: the App works fully with both switches off and without the AI assistant. No automated decision-making within the meaning of Art. 22 GDPR takes place — AI scores are practice feedback only.

You can lodge a complaint with a supervisory authority — in Austria the Datenschutzbehörde — or with the authority in your EU country of residence.

10. Children

Sprachnest is designed for adults preparing for German exams and is not directed to children. If you are under 16 (14 in Austria), please ask a parent or guardian before you turn on usage statistics. We do not knowingly collect personal data from children; the App collects no learning data from any user, and crash reports and usage statistics (Section 6) are pseudonymous technical data. The optional AI assistant requires your own account with an AI provider and is subject to that provider's age requirements.

11. Future Versions

Future versions may add further optional features, such as an encrypted backup option or synchronisation through your own cloud account. Any feature that sends your learning data off the device will be opt-in, the App will ask for consent where such data leaves the device, and this policy will be updated before that version ships, with a new "Last updated" date and a clear description of what changes. Crash reports (Section 6) are the one exception that does not need opt-in: they contain no learning data, and you can turn them off.

12. Contact

Questions about privacy: sprachnest@hollybyte.com.