Privacy notice
Memotongue is an app for learning words, made for families. This notice explains what personal data the app and its server process during the Closed Beta, why, for how long, and what you can do about it.
1. Who is responsible
During the Closed Beta Memotongue is run by one person, Maxim Kirilchuk, Bulgaria, who is the controller of your personal data under the EU General Data Protection Regulation (GDPR).
Contact for anything about your data: privacy@memotongue.com.
2. What we process and why
Your account
Email address, password (stored only as an Argon2 hash, never in readable form), country of residence, your confirmation that you are 18 or older, the app language, the time zone, and the version and time at which you accepted the beta terms and this notice.
Why: to create and protect your account, sign you in, keep your data in the region of your country and send you sign-in codes. Legal basis: the beta terms you accept (GDPR Art. 6(1)(b)); the record of your acceptance lets us show which version you accepted (Art. 5(2)).
Your learning
Profiles (name and settings), the words and cards you add, decks, your answers and reviews, study days and streaks, and the schedule of each card.
Why: this is the service — teaching you words and keeping your devices in sync. Legal basis: Art. 6(1)(b).
Signed-in devices
For each device you sign in on: iOS or Android, an optional device name, when it signed in and when it was last used. The sign-in token is stored only as a hash.
Why: to keep you signed in and let you sign a device out. Legal basis: Art. 6(1)(b).
Protection against misuse
Your IP address, held for at most one hour in counters that limit sign-up and sign-in attempts. Server logs record the time, the request path, the result and the account and profile identifiers; they hold no IP address, email, password or learning content.
Why: to stop password guessing and to find and fix faults. Legal basis: our legitimate interest in a secure, working service (Art. 6(1)(f)).
Backups
Encrypted copies of the database, so it can be restored after a failure.
Legal basis: our legitimate interest in not losing your data (Art. 6(1)(f)).
You need to give an email address and a password to create an account: without them you cannot take part in the beta. Everything else you enter is up to you.
What Memotongue does not do:
- no advertising, no selling or renting of data;
- no third-party analytics, tracking or advertising components in the app;
- no AI services: at the moment the app sends nothing to an AI provider. When AI features arrive (for adult profiles only), this notice is updated first and names the providers;
- no automated decisions about you with legal or similarly significant effects.
3. Kids profiles
A parent who holds the account can add profiles for children aged 4 to 10. Children never create an account or a profile themselves. Before a Kids profile is created the parent signs in again and gives consent to the processing described here; the version and time of that consent are recorded (Art. 6(1)(a) and Art. 8).
About a Kids profile we hold only:
- a nickname, an age band and a preset avatar (no photo);
- the child's learning: answers and reviews;
- Star Cookies and screen-time records, the mascot's state and the parent's settings.
No free text, audio, photos, location or contacts. In a Kids profile there is no AI, no voice recording or speech recognition, no advertising, no analytics or tracking, no crash reports, no notifications, no purchases and no links out of the app. A Kids profile talks only to Memotongue's own server.
The parent can withdraw consent at any time: the profile is then frozen (it cannot be opened) and its data is deleted after 30 days unless consent is given again. A deleted Kids profile is removed from the server within 30 days. Kids data is otherwise kept while the profile exists.
4. Who else receives data
Only these service providers, each bound by a data processing agreement and each only for its task:
- Hetzner Online GmbH, Germany — the server and its backups, in Hetzner's data centre in Nuremberg, Germany.
- Brevo (Sendinblue SAS), France — sends the emails with sign-up and sign-in codes; it receives your email address and the content of those emails. Brevo keeps the data in the EU; where its subcontractors are outside the EEA, Brevo's data processing agreement binds them with the EU standard contractual clauses (GDPR Art. 46).
- Spaceship, Inc., USA — forwards the messages you send to privacy@memotongue.com, so it receives your email address and your message. The transfer to the USA rests on the EU standard contractual clauses in Spaceship's data processing agreement (Art. 46).
Apple (TestFlight) and Google (Google Play testing) distribute the beta app as independent controllers under their own privacy policies, which may include processing outside the EEA. To invite you we give them the email address you name for the invitation. If you send feedback through TestFlight or Google Play, they pass it to us with your email and any screenshot you attach: please never attach a screenshot of a Kids profile. A monitoring service (Healthchecks.io) receives only reports on the server's health, with no personal data.
Your account and learning data are stored only in the European Economic Area. A new provider is added to this notice before it receives any data.
5. Where the data is kept
In the EU, in Germany. The app also keeps a copy of your data on your device so that it works offline; it syncs with the server when there is a connection.
6. How long
- Account, profiles and learning data: as long as the account exists. When you delete the account, its data is removed from the server within 30 days. Backups older than 30 days are deleted, so the data leaves the backups within the same 30 days.
- If the beta ends without a public launch, all data is deleted within 30 days after the end; you can export it before.
- An unconfirmed sign-up and its code: 15 minutes.
- IP addresses in the attempt counters: at most one hour.
- Server logs: in files of a fixed size (30 MB per service) that newer entries overwrite; they hold no IP address, email or learning content.
- Consent records: as long as the account exists.
- Messages to privacy@memotongue.com: until your request is settled, and at most one year.
7. Your rights
You can ask for access to your data, a copy in a machine-readable form, correction, deletion and restriction of processing. Where processing rests on consent, you can withdraw it at any time; this does not affect what was done before.
Right to object. You can object at any time, on grounds relating to your situation, to processing based on our legitimate interests (section 2: protection against misuse and backups). We then stop it unless we have compelling legitimate grounds that override your interests, or need it to establish or defend legal claims.
The app will offer export and deletion of the account in its settings during the beta. Until then, and at any time, write to privacy@memotongue.com from the email of your account; we answer within one month (in complex cases the law allows two more months, and we tell you why). A postal address for legal correspondence is given on request.
You may also complain to a data protection authority: in Bulgaria the Commission for Personal Data Protection (Комисия за защита на личните данни), 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, www.cpdp.bg, or the authority of the EU country where you live.
8. Security
All traffic is encrypted (HTTPS). Passwords and sign-in tokens are stored only as hashes. Backups are encrypted before they are written. The server accepts administrator sign-in only with cryptographic keys, never with a password. Every profile's data is separated, and a Kids profile can reach only its own data.
9. Age
An account and its adult profiles are for adults aged 18 or older. Children aged 4 to 10 use Memotongue only through a Kids profile in their parent's account. Profiles for young people aged 11 to 17 are not part of the beta.
10. Changes
This notice changes before the app processes new kinds of data or uses a new provider. Each change gets a new version; we tell you in the app and, for important changes, ask for your agreement again.