Drillo: Language Practice
1.1 This Privacy Policy explains how information is handled in Drillo: Language Practice (the "App"), a language-learning application for iOS and Android. It applies to all versions of the App.
1.2 The App is published by the independent developer of Drillo ("we", "us"), who is the data controller for the purposes of Regulation (EU) 2016/679 ("GDPR").
1.3 This Policy does not cover the application stores that distribute the App, your device's operating system, or any service to which you choose to send information yourself.
2.1 We collect no personal data. The App has no accounts or sign-in, no analytics, no crash reporting, no advertising, no tracking technologies and no third-party data-collection software. The sole third-party component is the platform rating library described in clause 5.3, which collects nothing for us.
2.2 The App makes no network connections of its own. The Android edition is published without the INTERNET permission and the iOS edition contains no networking code; the App is therefore technically incapable of sending information to us.
2.3 We consequently hold no information about you, and we sell, share and disclose none — including in response to any legal request, as there is nothing to disclose.
3.1 To provide spaced repetition, the App stores on your device: your learning progress and its scheduling data; your answers, including incorrect ones, so that mistakes can be explained and repeated; a local record of your practice sessions; and your settings.
3.2 This is written to the private storage area assigned to the App by the operating system, is protected by your device's own security including device encryption where enabled, and is never transmitted to us. We have no means of accessing or requesting it.
3.3 If you have enabled iCloud Backup or the Google backup service, App data may be included in those backups, which are created and controlled by Apple or Google under their own privacy policies and your device settings.
4.1 Microphone. The optional "Say it" exercise uses the microphone to evaluate the phrase you pronounce. Permission is requested only when that exercise is first used and may be declined or revoked at any time in your device settings; all other functions of the App remain available.
4.2 Speech recognition. The captured audio is passed to the speech-recognition service built into your operating system — Apple's on iOS, Google's on Android, where offline recognition is requested if the device supports it. Depending on your device, language and settings, that service may process the audio on Apple's or Google's servers, under their own privacy policies and as independent controllers. The App does not record audio to a file, retain audio, or transmit audio itself; the recognised text is compared with the expected phrase and then discarded.
4.3 Notifications. Reminders, if you enable them, are scheduled locally by your device. No push-notification server is used and nothing is transmitted. They may be switched off in the App or in your device settings.
5.1 The only third-party processing that may arise is the operating-system speech recognition described in clause 4.2, provided by Apple Inc. or Google LLC. See the Apple Privacy Policy and the Google Privacy Policy.
5.2 The App Store and Google Play may collect information in connection with your download of the App. That collection is governed by Apple's and Google's privacy policies and is outside our control.
5.3 The App may invite you to rate it using the rating prompt built into the platform — the App Store rating request on iOS, and on Android the Google Play in-app review provided by the Google Play In-App Review library. The prompt is presented and handled entirely by the operating system or by the Play Store application; we are told nothing about whether it appeared, was dismissed or was acted upon, and no information about you is sent to us.
5.4 No other party receives any information, and we carry out no international data transfer, because no data leaves your device by any act of ours.
6.1 Everything the App stores is on your device and under your sole control at all times.
6.2 Selecting Settings → "Start over from zero" erases the stored progress for the language then selected. Uninstalling the App removes all of its data from the device.
6.3 We retain nothing and cannot delete anything on your behalf, for the reason that nothing ever reaches us.
7.1 The App is suitable for users of all ages and contains no user-generated content, messaging or social features.
7.2 We do not knowingly collect personal information from children under 13, or under the equivalent minimum age in the user's jurisdiction, because we collect no personal information from any user. No verifiable parental consent mechanism is required under COPPA or Article 8 GDPR.
8.1 Under the GDPR and the UK GDPR you hold rights of access, rectification, erasure, restriction, portability and objection. As we hold no personal data relating to you, there is nothing to which such a request could relate; the controls in clause 6.2 give you complete control over all information the App stores. Your right to lodge a complaint with your supervisory authority is unaffected.
8.2 For residents of California: we collect none of the categories of personal information listed in Cal. Civ. Code § 1798.140, have not sold or shared personal information in the preceding twelve months, and do not treat anyone differently for exercising a right under the CCPA as amended by the CPRA.
8.3 The App's Apple App Store privacy disclosure and Google Play Data safety disclosure both state that no data is collected, consistent with this Policy.
9.1 Should this Policy change, the revised version will be published at this address with an updated effective date, and any material change will be noted in the release notes of the relevant version of the App.
9.2 Questions about this Policy may be sent to swarog46@gmail.com. We aim to reply within thirty days.