Privacy Policy

for the app Vocab Trainer

Deutsche Fassung · Support

1. Controller

The controller responsible for data processing under the General Data Protection Regulation (GDPR) is:

2. Summary

The app itself does not collect any personal data. There is no user account, no registration and no login. Your vocabulary lists and your learning progress stay locally on your device; we do not read, transfer or store them. Photos of vocabulary pages are analysed on the device and not kept. Only if you download the additional AI voice does the app fetch files from our server once (section 3b).

The app shows ads. The service used for this, Google AdMob, processes data from your device; this cannot be avoided when delivering ads. Because people of all ages use the app, ads are never personalised. Section 4 explains exactly what this involves.

3. Data processed by the app itself

Your content in the app (vocabulary lists with word and translation, your learning progress per word, and settings such as the app language) is stored exclusively in your device's local storage. It does not leave the device. We do not operate any server for this app to which such data would be transferred, and we have no access to it.

You can delete each list in the app (open the list, then Delete list). Uninstalling the app removes all locally stored data at once. A separate deletion request to us is neither necessary nor possible, because the data never reaches us.

If you pass on a list via Pass list on (AirDrop, QR code or a message), it goes directly to the device or app you choose. You decide who receives it. Nothing passes through us or a server.

With Create backup (in the settings) the app creates a file containing all your lists, folders and learning progress and hands it to your device's share menu. You decide where the file goes (for example your Files folder, a cloud storage of your choice or a message). With Restore backup you pick such a file in the system's file picker; the app reads only that one file. Nothing passes through us here either.

If you enter a test date for a list, the app can remind you in the days before. These reminders are scheduled on your device as local notifications. No push service is used, and nobody but you learns of them. You can turn them off in the app's settings or in your device's notification settings.

3a. Camera and photos: processed on the device only

The app uses the camera and your photo library only when you scan a vocabulary page or pick a photo yourself. Text recognition runs entirely on the device: on the iPhone with Apple's built-in text recognition "Vision", on Android with Google's document scanner and text recognition "ML Kit". Photos are not transferred to us, to Google or to anyone else and are not stored permanently: they remain in the app's temporary cache only while you review the recognised word pairs. Only the word pairs you keep are saved.

From your photo library, the app only sees the photos you select in the system picker.

On Android, ML Kit and the document scanner come from Google (the scanner via Google Play services). Google may receive technical information about these features (for example version, performance and errors), but no photos and no recognised text.

The Read aloud feature uses your device's speech output or, if you have downloaded it, the app's AI voice (section 3b). Both generate speech on the device; the words read aloud are not transmitted. The ads receive no data from your lists, photos or learning progress.

3b. AI voice: optional download (from app version 1.0.4)

For English, French, Spanish, Italian and Portuguese, the app offers an additional, more natural-sounding AI voice in the settings under Read aloud (called “Natural voice” in the app). It is not included in the app. Only when you tap Download does the app fetch the voice package (about 140 MB) once from our website devforge.world. After that the voice runs entirely on your device, even without an internet connection.

During the download our server logs the request like any web server: IP address, time, requested file and technical details of the request (such as the identifier of the requesting software). Your lists, learning progress or words read aloud are not transmitted. The log is limited in size and overwrites itself after a short time; we do not analyse it in relation to individuals and do not combine it with other data. The legal basis is our legitimate interest in operating the server securely and reliably (Art. 6(1)(f) GDPR). You can delete the voice again at any time in the settings.

4. Advertising (Google AdMob)

To fund the app, we show ads via Google AdMob, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When delivering and measuring an ad, Google processes, among other things:

• your IP address and the approximate region derived from it,
• technical information about the device (model, operating system version, language setting) and identifiers Google uses for fraud prevention and frequency capping,
• information about which ad was shown when and whether it was tapped.

The purpose is to deliver and bill ads and to prevent click fraud. The app requests non-personalised ads only, meaning ads that are not selected based on your past behaviour, and only ads suitable for a young audience. The app does not ask for permission to track you across apps.

Age question (from app version 1.0.2): before the first ad, the app asks once for your year of birth. The answer is stored only on your device and is not sent to us or to Google. If it shows that you may be younger than 13, every ad request is marked as directed to children (Google's "child-directed treatment", for the US law COPPA) and as coming from a user under the age of consent. Google then applies its rules for children, and only ads rated for all ages (G) appear. For everyone else, ads rated up to PG appear. Until the question is answered, the app requests no ads at all.

Google is independently responsible for this processing; details can be found in Google's privacy policy at policies.google.com/privacy and in the overview of how Google uses data from partner apps at policies.google.com/technologies/partner-sites.

In the EU, the EEA, the United Kingdom and Switzerland, the app asks for your consent to store information on the device in a Google dialog on first launch. You can change your decision at any time in the app under Settings → Change ad settings. Users under the age of consent (see the age question above) are not asked, because their ads are already limited to Google's rules for children. No full-screen ads appear during a practice round.

5. Legal bases

Where consent is obtained for advertising, the legal basis is Art. 6(1)(a) GDPR and Section 25(1) TDDDG; you can withdraw it at any time with effect for the future. Where processing takes place without consent, we base it on our legitimate interest in an economically viable app that is free of charge for you, Art. 6(1)(f) GDPR. The server log when downloading the AI voice is based on Art. 6(1)(f) GDPR (see section 3b).

6. Recipients and transfers to third countries

Apart from the advertising described in section 4, we do not pass any data on to third parties. Google may also process data outside the European Union, in particular in the USA. Google bases such transfers on the European Commission's Standard Contractual Clauses and on the EU-US Data Privacy Framework.

7. Retention

We do not store any personal data ourselves, apart from the server log when downloading the AI voice, which overwrites itself after a short time (section 3b). How long Google retains data collected for advertising is set out in Google's own privacy policy (see section 4).

8. App permissions

The app only requests the permissions it needs to work: camera and access to selected photos, each only for scanning vocabulary pages (see section 3a), and notifications, only once you enter a test date (see section 3). On Android, the app also declares the permission to read the advertising ID, which Google AdMob uses for fraud prevention and frequency capping (see section 4); you can reset or delete the advertising ID in your device settings. Internet access is needed only to deliver ads and for the optional download of the AI voice (section 3b); the app works without an internet connection.

9. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and the right to object to processing based on legitimate interest (Art. 21). Please contact the address given in section 1.

Please note: since we hold no data about you, we cannot identify you in our own records. Please direct claims concerning ad delivery to Google.

10. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement.

11. Younger users

The app is meant for anyone who learns vocabulary, at school, university, in a language course or at work. It is not specifically directed at children. Because younger people may still use it, the app itself collects no data, there is no account, and ads are delivered exclusively non-personalised and only with content suitable for a young audience. Anyone who may be younger than 13 according to the age question receives ads only under Google's rules for children (section 4). For users under 16, parents decide on the consent in the ad dialog.

Parents can contact us at any time at the address in section 1. Since the app stores nothing about your child with us, there is nothing we could look up or delete; the data on the device disappears when the app is uninstalled. Without an internet connection, the app shows no ads and sends nothing.

12. Users in the United States

This section supplements the policy for users in the United States, in particular under the California Online Privacy Protection Act (CalOPPA), the California Consumer Privacy Act (CCPA) and the Children's Online Privacy Protection Act (COPPA).

• What is collected and by whom: the app itself collects no personal information. Only if you download the AI voice does our server briefly log your IP address and the time (section 3b). Google AdMob receives the categories listed in section 4 (IP address and approximate region, device information and identifiers, ad interactions) in order to deliver and measure ads and prevent fraud. Google is the only third party that receives such information.
• No sale, no sharing for targeted advertising: we do not sell personal information and do not share it for cross-context behavioural (targeted) advertising. The app requests only non-personalised ads.
• Do Not Track: the app does not track you across other apps or websites and does not ask for permission to do so. It therefore does not respond differently to "Do Not Track" signals; there is no tracking to switch off.
• Children under 13 (COPPA): the app is intended for a general audience and is not specifically directed at children. We do not knowingly collect personal information from children under 13. For users whose year of birth means they may be younger than 13, ad requests are marked as child-directed (section 4), and Google applies its rules for children. Parents with questions can contact us at the address in section 1.
• Reviewing and changing information, your rights: we hold no information about you that you could review, correct or have deleted. Your lists are only on your device, where you can change or delete them. For information Google receives through ads, you can reset or delete your device's advertising ID and contact Google directly (see section 4). You can also write to us at any time (section 1). We will not treat you differently for exercising a privacy right.

13. Changes to this policy

We update this policy when the app or the legal situation changes. The version published here applies. We indicate changes by updating the date below.

Updated: 9 October 2026