Privacy Policy

1. Who we are

The apps and this website are provided by individual entrepreneur (ФОП) Artur Ahapov, registered in Ukraine and trading as Smart Learning Solutions (“we”, “us”). We are the controller of your personal data. Location: Kyiv, Ukraine. Email: englishidioms@ukr.net.

2. What we collect

• Learning progress: what you have learned, your answers, your review schedule and your settings. It is stored on your device. If you turn on sync (Pro), a copy is kept in our cloud database so it can be restored on your other devices.
• Account details: if you sign in to sync, your user ID and the email address or identifier that Apple or Google shares when you use Sign in with Apple or Sign in with Google. With Sign in with Apple you can choose to hide your real email address.
• Purchase information: which plan you have, when it started and renews, and which store or payment provider processed it. We never see or store your full card details.
• Usage and diagnostic data: screens opened, lessons completed, device model, operating system, app version, approximate country and crash reports, collected with Google Analytics for Firebase and Firebase Crashlytics.
• Advertising data: the free version shows ads from Google AdMob. AdMob uses your device’s advertising identifier, IP address and device information to show ads, limit how often you see them and measure their performance. In the EEA, the UK and Switzerland we ask for your consent before personalised ads are shown; on iOS the advertising identifier is used only if you allow tracking. You can change your choice at any time under Settings → Privacy choices.
• Advertising measurement: when we advertise the apps elsewhere, we measure which ads lead to installs and purchases, on the same consent terms.
• Messages you send us: your email address and what you write to support.

We do not collect your name, contacts, precise location, photos or microphone audio. Pro removes ads.

3. This website

The website is hosted on Google Firebase Hosting, which processes your IP address and browser details to deliver pages and protect the site from abuse. The site remembers your language choice in your browser’s local storage and sets no cookies. We count visits with Cloudflare Web Analytics, which uses no cookies and builds no profile of you: it records page views, the referring site, country and device type in aggregate.

If you buy Pro on this website, payment is handled by the payment provider shown at checkout, which collects the details needed to take the payment under its own privacy policy.

4. Why we use it

• To provide the apps and your purchases, and to sync your progress when you ask for it. This is necessary to perform our contract with you.
• To keep the apps working, fix crashes and understand which features help people learn. This is our legitimate interest in running and improving the apps.
• To show ads in the free version, which keeps it free, and to measure our own advertising. Personalised ads and tracking are used only with your consent where the law requires it, for example in the EEA and UK and with App Tracking Transparency on iOS.
• To answer your messages and keep the records that tax and accounting law require.

We do not sell your personal data and do not use it for automated decisions that have legal effects on you.

5. Service providers

• Google Firebase (Google LLC and Google Ireland Ltd): Firebase Authentication (sign-in), Cloud Firestore (synced progress), Google Analytics for Firebase, Firebase Crashlytics and Firebase Hosting (this website).
• Google AdMob (Google LLC and Google Ireland Ltd): shows ads in the free version and asks for consent where required.
• Cloudflare, Inc.: domain name service for this website and cookie-free visit statistics.
• RevenueCat, Inc.: manages subscriptions and purchase status across the App Store, Google Play and the web.
• Apple and Google: take in-app payments through the App Store and Google Play under their own terms.
• The payment provider shown at checkout: takes payments made on this website.
• ukr.net: our support mailbox.

They process data on our behalf, or as independent controllers for their own services, under data protection terms.

6. International transfers

Some providers are based in the United States or elsewhere outside Ukraine and the European Economic Area. Where the law requires, transfers rely on safeguards such as the EU Standard Contractual Clauses or adequacy decisions.

7. How long we keep data

• Account and synced progress: until you delete your account, then removed within 30 days.
• Progress kept only on your device: until you delete the app.
• Analytics data: 14 months.
• Purchase records: as long as tax and accounting law requires.
• Support emails: up to 2 years after the conversation ends.

8. Your rights

Depending on where you live, you can ask us to access, correct, delete or export your data, object to or restrict some processing, and withdraw consent at any time.

You can delete your account and synced progress in the app under Settings → Account → Delete account, or write to englishidioms@ukr.net. We reply within 30 days. You can also complain to your data protection authority; in Ukraine this is the Ukrainian Parliament Commissioner for Human Rights.

9. Children

The apps are made for teenagers and adults learning English. They are not directed at children under 13, and we do not knowingly collect their personal data. If you believe a child has given us personal data, contact us and we will delete it.

10. Security

Data travels over encrypted connections and is stored with providers that use industry-standard security. Access is limited to what is needed to run the apps.

11. Changes to this policy

If we change this policy, we will update the date above and, for significant changes, tell you in the app or on this website.

12. Contact

Questions or requests about your data: englishidioms@ukr.net.