Privacy policy
Version 1.0, effective 2026-09-14. This English text is the governing version; the German, Russian and Serbian pages say the same things in their own words.
In short
- Peroglot works without an account. The moment the app first reaches our server it creates an anonymous account so your progress is backed up; you can attach an email address, Apple ID or Google account later to keep it across devices.
- We store your learning progress: which items you practised, how you answered, and what the app should show you next. That is the product, not a side effect.
- No advertising, no ad identifiers, no tracking across other apps or websites, no selling of data. The app contains no analytics or crash-reporting SDK today; if we add one, this policy changes first.
- Speech input is handled by your phone's speech service (Apple or Google). We never receive your voice.
- Payments run through the App Store or Google Play. We never see card numbers.
- You can export or delete everything from inside the app. Deletion removes everything that identifies you and keeps only anonymous learning statistics.
1. Who is responsible
LEV RIABOV PR BEOGRAD, a sole proprietor (preduzetnik) registered in the Republic of Serbia, Kneza Miloša 15, Beograd, registration number 68551366, tax ID 115681569, is the data controller for the Peroglot app and the website peroglot.com. Contact: support@peroglot.com. Full details are on the business details page.
2. What the app collects, and why
2.1 Device and account
On installation the app generates a random device identifier and stores it in the operating system's secure storage. When the app first connects to our server it creates an anonymous account: an opaque account ID with no name, email or phone number. The server keeps the device identifier, the platform (iOS or Android), the session token that authorises the device, and the times the account was created and last synced.
Purpose: to save your progress before you have ever seen a sign-in screen, and to let the same account run on more than one device. Legal basis: performance of the contract (Art. 6(1)(b) GDPR and the equivalent provision of the Serbian Personal Data Protection Act).
2.2 Sign-in identities
If you choose "Save my progress" the app attaches an identity to the anonymous account: your email address (verified with a six-digit code we send you), or the user identifier and email that Apple or Google hand us when you sign in with them. Apple may give us a private relay address instead of your real one; that is fine with us. We never receive a password from any of these providers.
Purpose: to recover the account on a new phone and to sign in on a second device. Legal basis: performance of the contract.
2.3 Learning progress
Every exercise you do in the app is recorded locally on your phone and synced to our server: the state of each word, sentence, rule, text and exam (level, next review date, streak), a log of review and lesson-step events (which item, when, what you answered, whether it was accepted), the "feathers" you earned and spent, and your onboarding profile (the course you chose, your goal, your daily target).
Purpose: the sync and backup feature is the reason the data exists. On top of that we aggregate the review events across all learners per item, so that a sentence most people fail is flagged to us as a content bug. The aggregates contain no account identifiers. Legal basis: performance of the contract for the sync; our legitimate interest in keeping the course correct for the aggregates (Art. 6(1)(f)).
2.4 Reports you send
The app has a "my answer should be accepted" button. A report carries the item you were on, the answer you typed, and any text you added. It is stored with your account so that our reply can reach you and is read by the people who maintain the course. Legal basis: performance of the contract.
2.5 Purchases
Subscriptions are sold by Apple and Google through their stores. When you subscribe, the store tells our billing provider, RevenueCat, that your account ID has an active entitlement, and RevenueCat tells our server. We receive the store's transaction and product identifiers and the entitlement's start and end dates. We never receive your name, address or payment card. Apple's and Google's own privacy policies apply to the purchase itself. Legal basis: performance of the contract.
2.6 Speech input
If you allow the microphone, the app hands your speech to the speech-recognition service built into your phone (Apple's on iOS, Google's on Android) and receives text back. The audio never reaches our servers. Apple's and Google's terms govern what their services do with it; on most devices recognition happens on the phone. You can revoke the permission at any time in the phone's settings and keep typing instead.
2.7 Reminders
Practice reminders are local notifications scheduled on your phone. No notification server is involved and nothing about them leaves the device.
2.8 Updates and content delivery
The app downloads course content from our content network (Cloudflare) and checks for app updates through Expo's update service. Both see your IP address and the app version, as any download does. We do not tie those requests to your account.
2.9 Server logs
Our API and content network keep short-lived technical logs (IP address, time, requested path, response code) for security and to diagnose faults. They are deleted or rotated within 30 days. Legal basis: legitimate interest in running a secure service.
3. What the website collects
peroglot.com is a static site. It sets no cookies and runs no analytics or advertising scripts. Our hosting provider, Cloudflare, records the same technical logs as any web server. If we add a privacy-preserving, cookieless visitor counter later, this section will say so.
4. Who we share data with
We use these processors, each bound by a data-processing agreement:
| Provider | What for | Where |
|---|---|---|
| Amazon Web Services | Database and email delivery (sign-in codes) | Frankfurt, Germany (EU) |
| Cloudflare | Content delivery, website hosting, network security | Global network; EU entry points for EU users |
| RevenueCat | Subscription status, purchase receipts | United States |
| Apple, Google | App distribution, payments, sign-in, on-device speech recognition | Per their policies |
| Expo (EAS) | App update delivery | United States |
We do not sell personal data and do not share it with advertisers. We disclose data to authorities only where the law obliges us to.
5. Where data is stored and international transfers
Your account and progress live in a database in Frankfurt, Germany. Serbia is not a member of the European Union; it has a data-protection law modelled on the GDPR, and we apply that standard to everyone regardless of where they live. Transfers to providers in the United States rely on the EU standard contractual clauses or the EU–US Data Privacy Framework, as available for each provider.
6. How long we keep data
- Account and progress: for as long as the account exists.
- Anonymous accounts that never synced anything: deleted by a monthly sweep.
- Review and step event logs: rolled up into per-item statistics after 90 days; the per-event rows are then deleted.
- Sessions and sign-in codes: until they expire or are revoked; sign-in codes live minutes.
- Reports: until you delete your account.
- Server logs: up to 30 days.
- Backups: encrypted database backups are kept for up to 35 days and then expire, so deleted data disappears from backups within that window.
7. Your rights
You can, at any time:
- Export everything we hold about you, from the app (Settings → Account → Export my data) as a machine-readable file.
- Delete your account from the app, or by email; the account deletion page explains exactly what is erased and what remains as anonymous statistics.
- Correct your email address by signing in with the new one.
- Object to the aggregate use of your review events, or ask us to restrict processing, by writing to support@peroglot.com.
- Complain to a supervisory authority: in Serbia, the Commissioner for Information of Public Importance and Personal Data Protection (Poverenik); in the EU, the authority of your member state.
We answer requests within 30 days and never charge for them.
8. Children
Peroglot is for people aged 16 and over. We do not knowingly create accounts for younger children; if you believe one exists, write to us and we will delete it.
9. California residents
We do not sell or share personal information as those terms are defined in the California Consumer Privacy Act, and we do not use it for cross-context behavioural advertising. The rights in section 7 (access, deletion, correction) are available to you in the same way, without discrimination.
10. Security
Session tokens are stored hashed on our server and in your phone's secure storage. Data is encrypted in transit and at rest. Access to production data is limited to the people who run the service.
11. Changes to this policy
When we change this policy we raise the version number and date at the top and, for material changes, tell you in the app before they apply. Earlier versions are available on request.
12. Contact
support@peroglot.com, or by post to the address on the business details page.