Privacy Policy

Effective date: [publication date] · Last updated: [publication date]

1. Who processes the data

[To be filled in before publication: full name or company name, registered address, country of registration.]

Contact us: hello@kiralang.app

2. What data and why

2.1. Learning progress — stored on your device

Completed lessons, learned words, experience (XP), day streak, crystals, the level and interests you chose, the answers you gave at first launch. This data is stored on your phone and is used to show your progress and pick scenes for you. It is not uploaded to us as a whole. The exception is the conversation with Kira: together with your message, a small anonymised slice is sent (level, interface language, the words you are working on, the topics you chose). Details are in §2.5.

2.2. Google backup

If Google backup is switched on in your phone settings, the app’s data goes into your backup on Google Drive. This is done by Android, not by us: we have no access to your backup. You can turn it off in your phone settings.

2.3. Microphone and speech recognition

The microphone switches on only while you hold the talk button down. Nothing is ever recorded in the background. Speech is recognised by your device’s system tools — either on the device itself or through Google’s recognition service, depending on your Android settings. We neither receive nor store audio recordings: the app gets back only the recognised text.

2.4. Voice playback

Replies are spoken aloud by your device’s built-in speech synthesiser. Nothing is sent anywhere.

2.5. Conversation with Kira

So that Kira can reply, the text of your message and a few earlier messages from the dialogue are sent to our server and on to the language model provider. Anonymised learning context is sent too: your level, interface language, the lesson’s topic and words, review words and the topics you chose. Without this Kira couldn’t hold a conversation at your level.

Not sent: your name, your contacts, anything on your phone, audio recordings.

Please don’t type or say personal data, passwords, card numbers or other sensitive information in the dialogue — this is a learning conversation and it is processed automatically. We do not use your messages to train models.

2.6. Reports about AI replies

If you report one of Kira’s replies, the app saves the reason for the report and the text of the reply on your device. This is used to tune the filters. There is no personal data in a report.

2.7. Purchases

The subscription is set up and paid for through Google Play. We never see, receive or store your card details — Google handles them. All that comes back to us is the confirmation that the subscription is active.

2.8. Analytics in the app

The app sends anonymised events to Google Firebase Analytics: app open, onboarding steps, conversation start, lesson completion, paywall view. They show where people get stuck — without that, changes to the teaching would be made blind.

The content of your conversations with Kira is never sent to analytics. Neither is your name, your email or the words you are learning. What is sent are event names tied to the anonymous identifier (see 2.9) and the technical device details Firebase collects itself: model, OS version, country, language.

You can switch collection off. In the app: Profile → “How it all works” → the “Analytics” toggle at the bottom. Events stop going out immediately, not from the next launch. For website analytics see section 7.

2.9. Anonymous identifier

So that the server can tell whose requests it is dealing with, the app receives an anonymous Firebase identifier at first launch. It is not linked to your name, your email or your Google account: we have no sign-up, and we don’t know who you are.

What it is for: counting the daily limit of free minutes, telling a subscriber from everyone else, and not handing paid replies out to just anyone. Without it, these rules would apply “to everybody at once” or not at all.

The same identifier is shown to you in the app as your “Support ID” (Profile → “How it all works”): support uses it to find your subscription if you write to us. It lives until you delete the app or clear its data; after that the app receives a new one.

3. What we don’t do

• We don’t sell data or pass it to advertising networks and data brokers.
• We don’t show ads.
• We don’t build profiles for targeting.
• We don’t require sign-up: there is no account and no password in the app.
• We don’t collect contacts from the app. The only exception is described below in “Closed test request”, and it depends entirely on you.
• We don’t read your files, contacts, calls or messages.

4. Who the data is shared with

All recipients process the data on our instructions and for the purposes described here.

5. How long we keep it

• On the device — until you delete the app or clear its data.
• Dialogue messages on the server — not kept once the reply has been produced.
• Technical logs — the server keeps no request log containing content; service logs are limited in size and are automatically pushed out by newer entries.
• Subscription details — for as long as the subscription is active and thereafter for the periods required by accounting and tax law.
• The email address from the form — until you unsubscribe or until the closed test ends, whichever comes first.

6. Closed test request

The home page of the site has a form where you can leave an email address to get on the tester list. This is the only place where we receive a contact detail of yours, and filling in the form is entirely voluntary. There is no such form in the app itself: it still works without any sign-up.

The address has to be confirmed. After you submit the form we send one email with a confirmation link. Until you follow it, the address goes nowhere and there will be no more emails. That is how we make sure the address was left by its owner and not by someone else.

• What we collect: the email address, the date of the request and the language of the page.
• Why: to confirm the address, add it to the Google Play tester list and write to you once when access opens.
• Legal basis: your consent, confirmed by following the link in the email.
• Where it is stored: on our server. This is an exception to the general “everything on the device” rule, and we say so plainly.
• Who we share it with: the email delivery service Resend, so the email arrives, and Google, when we add the confirmed address to the tester list in the Play Console. Nobody else.
• There is no newsletter. We don’t send regular emails.

Unsubscribing deletes the address. The link is in every email, and in Gmail the built-in button works too. We don’t move you to an “unsubscribed list” — we erase the address; all that stays with us is an irreversible hash from which neither the address nor the list of recipients can be reconstructed, and which exists for one purpose only: so that we don’t accidentally write to you again.

Separately, a service delivery log is kept: when an email went out and with what result. There are no addresses in it, only the domain and the same irreversible hash, and it is kept to a limited number of the most recent entries.

7. Analytics on the kiralang.app website

Everything above concerns the app. The website works differently.

On your first visit the site asks for consent to analytics and advertising pixels. Until you press “Accept”, no third-party script is loaded and no cookie is set. If you press “Decline”, nothing is loaded at all; the site keeps working in full.

If you consent, we load:

• Google Analytics 4 — how many people visit, from which pages and countries. The IP address is anonymised.
• Meta Pixel and TikTok Pixel — to understand which ads bring people in, and to avoid showing ads to those who already installed the app.

These services set their own cookies and receive your IP address, device type and page address. They are independent controllers, and their processing is governed by their own policies — Google, Meta, TikTok.

You can change your mind at any time: reopen the choice. Your choice is kept in the browser’s local storage under the key kira:consent — it is not a cookie and is never transmitted.

Apart from that, the site sets no cookies and runs no counters of its own.

8. Your rights

You have the right to request access to your data, its correction or deletion, to restrict processing, to object to it and to receive a copy of your data.

Since we have no accounts and almost everything is stored on your device, the fastest way to delete your data is to clear the app’s data or delete the app. Details are on the data deletion page.

If you are in the European Economic Area, processing is carried out on the basis of your consent and of the necessity to perform a contract (GDPR, Art. 6). You have the right to lodge a complaint with the supervisory authority of your country. For users in Ukraine, processing is carried out in accordance with the Law of Ukraine “On the Protection of Personal Data”.

Requests go to hello@kiralang.app.

9. Data deletion

There is a separate page with the procedure: kiralang.app/delete. In short: delete the app or clear its data in your phone settings. If you took out a subscription, cancel it in Google Play — that is a separate operation, and we can’t do it for you.

10. Age

The service is intended for people aged 18 and over — that is also how the app is declared in Google Play. We do not knowingly collect data from minors. If a minor has given us data, write to hello@kiralang.app and we will delete it.

11. Changes to this policy

We may update this policy. Material changes will be shown in the app before they take effect. The date of the last update is given at the top.