Privacy Policy

This English version is provided for convenience. In case of doubt, the German version applies.

This policy applies to the website sayumi.app and to the iPhone app “Sayumi”. In short: there is no account, no tracking and no advertising. Your learning data stays on your device and in your private iCloud. Data is only sent to an AI if you have explicitly agreed.

1. Controller

[First and last name / company]
[Street and number]
[Postcode and city]
Email: [email address]

2. This website

Hosting and server logs. The website is hosted by [name and address of the hosting provider]. When you visit it, the server processes technically necessary data: IP address, date and time, the page requested, the amount of data transferred, the referrer, and your browser and operating system. This serves the secure and stable delivery of the site (Art. 6(1)(f) GDPR). The logs are deleted after [number] days.

No cookies, no tracking, no third-party content. The website sets no cookies, uses no analytics or advertising services and loads no content from third parties (no external fonts, no maps, no embedded videos).

Contact. If you email us, we process your details only to answer your request (Art. 6(1)(b) or (f) GDPR) and delete them once they are no longer needed.

3. The app: your learning data stays with you

Sayumi works without a user account and without its own server. The following is stored on your device – and, with iCloud sync, in your private iCloud:

Profile: optional display name and native language
Vocabulary sets, cards, example sentences, notes and memory aids
Learning progress and history (reviews, ratings, statistics, achievements)
Settings, including your consent to AI use and the time for reminders

Sayumi uses no analytics, advertising or tracking services and does not track you across other apps or websites.

4. AI features (OpenAI)

Only when you use an AI feature – creating or extending a set, loading missing cards, completing a card with AI, requesting a memory aid or tapping “Why?” after a mistake – does the app send the necessary information to the OpenAI API ([contracting party and address according to the current OpenAI agreement]):

native and target language, level and focus
your description of what you are learning for
when extending a set: the set’s existing word pairs, so that no duplicates are created
for memory aids and completion: the word concerned with its translation, pronunciation and example sentence
for “Why?”: the exercise, your answer and the correct solution

Your name, your learning progress and your statistics are not transmitted. Please do not enter sensitive personal data in your description.

The legal basis is your explicit consent (Art. 6(1)(a) GDPR), which the app asks for before the first transmission. You can withdraw it at any time under Settings → Privacy. Sets you have already created remain usable.

Transfers to third countries: OpenAI may process data in the USA. [Add the basis for the transfer, e.g. the EU-US Data Privacy Framework or standard contractual clauses.] Retention by OpenAI: according to OpenAI’s privacy policy.

5. Speaking exercises

In “Speaking” and “Shadowing”, your iPhone’s speech recognition converts your voice into text directly on the device. The recording is compared with the solution and discarded immediately – it is neither stored nor sent to a server. iOS asks for microphone permission for this feature.

6. Sync via iCloud

If you are signed in to iCloud and Settings → iCloud sync is turned on (default), Sayumi also stores the data listed in section 3 in the private CloudKit database of your iCloud account. This database belongs to your account; we have no access to it. Apple processes the data according to its privacy policy. You can turn sync off at any time.

Reminders are local notifications on your device and are not sent through a server. The feature is off by default and needs your permission in iOS. The widget reads its data locally from the app.

8. App Store

Apple’s privacy policy applies to downloads and any purchases. Sayumi does not receive any personal data about you in the process.

9. Retention and deletion

Your data is kept until you delete it. Under Settings → Delete all data you remove all Sayumi data from your device and – if sync is on – from your iCloud as well. Deleting the app only removes the data on that device; a copy in iCloud remains until you delete it.

10. Your rights

You have the right to access, rectification, erasure, restriction of processing, data portability and objection, as well as the right to withdraw consent at any time. Much of this works directly in the app:

Data portability: Settings → Export data
Erasure: Settings → Delete all data
Withdrawal: Settings → Privacy → Withdraw consent

For anything else, you can reach us at [email address]. You also have the right to lodge a complaint with a data protection supervisory authority.

11. Changes

We update this policy when the website or app changes. Last updated: [date]