Privacy Policy
Privacy Policy
1. Privacy at a Glance
General Information The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can personally identify you. For detailed information on the topic of data protection, please refer to our privacy policy listed below. Data Collection on This Website Who is responsible for data collection on this website? Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the Responsible Party” in this privacy policy. How do we collect your data? Your data is collected when you provide it to us. This may include data entered into a contact form, for example. Other data is automatically collected by our IT systems when you visit the website. This includes technical data (e.g., browser, operating system, or time of page view). This data is collected automatically as soon as you enter the website. What do we use your data for? Some of the data is collected to ensure the website functions properly. Other data may be used to analyze user behavior. If contracts are concluded or initiated via the website, the transmitted data will also be used for contract offers, orders, or other business inquiries. What rights do you have regarding your data? You have the right to obtain information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request correction or deletion of your data. If you have given consent to data processing, you can withdraw this consent at any time. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the relevant supervisory authority. You can contact us at any time with further questions on the topic of data protection. Analysis Tools and Third-Party Tools When visiting this website, your surfing behavior may be statistically evaluated. This is mainly done using analysis programs. Detailed information on these analysis programs can be found in the following privacy policy.2. Hosting
We host the content of our website with the following provider: Strato Provider is Strato AG, Otto-Ostrowski-Straße 7, 10249 Berlin (hereinafter referred to as “Strato”). When you visit our website, Strato collects various log files including your IP addresses. For more information, please refer to Strato’s privacy policy: https://www.strato.de/datenschutz/ The use of Strato is based on Art. 6 (1) lit. f GDPR. We have a legitimate interest in the most reliable presentation of our website. If consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and § 25 (1) TDDDG, provided the consent includes the storage of cookies or access to information in the user’s terminal device (e.g., device fingerprinting) as defined by the TDDDG. Consent can be withdrawn at any time. Data Processing Agreement We have concluded a data processing agreement (DPA) for the use of the above service. This is a contract required by data protection law that ensures that the provider processes personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.3. General Notes and Mandatory Information
Data Protection The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy. When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done. We point out that data transmission over the internet (e.g., when communicating by e-mail) can have security gaps. A complete protection of data against access by third parties is not possible. Information on the Responsible Party The responsible party for data processing on this website is: Uchim Lukas Stoll Rhoenstrasse 17 71083 Herrenberg Germany Phone: +49 157 36152251 Email: hi@uchim.app The responsible party is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g., names, e-mail addresses, etc.). Storage Duration Unless a more specific retention period is stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you make a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, deletion takes place after these reasons cease to apply. General Information on the Legal Basis for Data Processing on This Website If you have consented to data processing, we process your personal data on the basis of Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR, if special categories of data are processed according to Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49 (1) lit. a GDPR. If you have consented to the storage of cookies or access to information in your terminal device (e.g., via device fingerprinting), data processing is additionally based on § 25 (1) TDDDG. Consent can be revoked at any time. If your data is necessary for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 (1) lit. b GDPR. Furthermore, we process your data if it is necessary for the fulfillment of a legal obligation on the basis of Art. 6 (1) lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest according to Art. 6 (1) lit. f GDPR. The relevant legal basis in each individual case is explained in the following paragraphs of this privacy policy.Recipients of Personal Data
In the course of our business activities, we work with various external parties. In some cases, this also requires the transmission of personal data to these external parties. We only disclose personal data to external parties if this is necessary for the performance of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest pursuant to Art. 6 (1) lit. f GDPR in the disclosure, or if another legal basis permits the data disclosure. When using processors, we only disclose personal data of our customers based on a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.Revocation of Your Consent to Data Processing
Many data processing operations are only possible with your explicit consent. You can revoke a previously given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation. Right to Object to Data Collection in Special Cases and to Direct Advertising (Art. 21 GDPR) IF DATA PROCESSING IS BASED ON ART. 6 (1) LIT. E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OUTWEIGH YOUR INTERESTS, RIGHTS, AND FREEDOMS OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION UNDER ART. 21(1) GDPR). IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION UNDER ART. 21(2) GDPR).Right to Lodge a Complaint with the Competent Supervisory Authority
In the event of violations of the GDPR, data subjects have a right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or the place of the alleged infringement. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedy. Right to Data Portability You have the right to have data which we process automatically based on your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible. Right to Access, Rectification, and Erasure Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient, and the purpose of the data processing and, if applicable, a right to rectification or erasure of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time. Right to Restriction of Processing You have the right to request the restriction of the processing of your personal data. You can contact us at any time to do so. The right to restriction of processing applies in the following cases:- If you contest the accuracy of your personal data stored with us, we usually need time to verify this. During the verification period, you have the right to request restriction of the processing of your personal data.
- If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of erasure.
- If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
- If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your and our interests. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
SSL and TLS Encryption
For security reasons and to protect the transmission of confidential content, such as orders or inquiries you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the browser’s address line changes from “http://” to “https://” and by the lock symbol in your browser line. When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.4. Data Collection on This Website
Cookies Our websites use so-called “cookies.” Cookies are small data packets and do not harm your device. They are either temporarily stored for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted after your visit ends. Permanent cookies remain stored on your device until you delete them yourself or your web browser automatically deletes them. Cookies can be set by us (first-party cookies) or by third-party companies (third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services). Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or video display). Other cookies are used to evaluate user behavior or for advertising purposes. Cookies that are necessary to carry out electronic communication, to provide certain functions you requested (e.g., for the shopping cart function), or to optimize the website (e.g., cookies for measuring the web audience) are stored based on Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent has been requested for the storage of cookies and similar recognition technologies, processing is based exclusively on this consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent can be revoked at any time. You can set your browser to inform you about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for specific cases or in general, and activate the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website. Which cookies and services are used on this website can be found in this privacy policy. Server Log Files The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These include:- Browser type and browser version
- Operating system used
- Referrer URL
- Hostname of the accessing computer
- Time of the server request
- IP address
5. Analysis Tools and Advertising
WP Statistics This website uses the analysis tool WP Statistics to statistically evaluate visitor access. The provider is Veronalabs, Tatari 64, 10134, Tallinn, Estonia (https://veronalabs.com). With WP Statistics, we can analyze the use of our website. WP Statistics records, among other things, log files (IP address, referrer, used browsers, origin of the user, used search engine) and actions that website visitors have carried out on the site (e.g., clicks and views). The data collected with WP Statistics is stored exclusively on our own server. The use of this analysis tool is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the anonymized analysis of user behavior in order to optimize both our web offering and our advertising. If corresponding consent has been requested, processing is based exclusively on Art. 6(1)(a) GDPR and § 25(1) TDDDG, provided the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined by the TDDDG. Consent can be revoked at any time. IP Anonymization We use WP Statistics with anonymized IP. Your IP address is shortened so that it can no longer be directly assigned to you. Google Analytics This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, duration of visit, operating systems used, and origin of the user. Google may combine this data in a profile assigned to the respective user or their device. Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). The information collected by Google about the use of this website is usually transmitted to a Google server in the USA and stored there. The use of this service is based on your consent in accordance with Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time. More information on data protection at Google: https://policies.google.com/privacy?hl=en Opt-Out: https://tools.google.com/dlpage/gaoptout Hotjar This website uses Hotjar. The provider is Hotjar Ltd., Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta. Hotjar is a tool for analyzing your user behavior on this website. With Hotjar, we can record your mouse and scroll movements and clicks, among other things. Hotjar can also determine how long your mouse pointer stayed in a certain position. From this information, Hotjar creates so-called heatmaps, which can be used to determine which areas of the website visitors prefer to look at. The use of this analysis tool is based on your consent (Art. 6(1)(a) GDPR). Consent can be revoked at any time. More info: https://www.hotjar.com/legal/policies/privacy/ Opt-Out: https://www.hotjar.com/legal/compliance/opt-out/ Cookiebot This website uses the Cookiebot service. The provider is Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark. Cookiebot is used to obtain and document consent for the storage of certain cookies in your browser or for the use of certain technologies. When you enter our website, your consent is obtained via Cookiebot. The use of Cookiebot is to obtain the legally required consents for the use of cookies. The legal basis is Art. 6(1)(c) GDPR. More information: https://www.cookiebot.com/en/privacy-policy/6. Newsletter
Newsletter Data If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the provided email address and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties. The processing of the data entered into the newsletter subscription form is based solely on your consent (Art. 6(1)(a) GDPR). You can revoke your consent to the storage of the data, the email address, and its use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation. The data you provide to us for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe. Data stored by us for other purposes remains unaffected by this. After you unsubscribe from the newsletter distribution list, your email address may be stored in a blacklist by us or the newsletter service provider to prevent future mailings. The data from the blacklist is used only for this purpose and is not merged with other data. This serves both your interest and our interest in complying with legal requirements for sending newsletters (legitimate interest under Art. 6(1)(f) GDPR). Storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.7. Plugins and Tools
YouTube with Enhanced Privacy Mode This website integrates videos from the YouTube website. The operator of the site is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. When you visit one of our pages on which YouTube is embedded, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you allow YouTube to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. We use YouTube in enhanced privacy mode. According to YouTube, videos played in enhanced privacy mode are not used to personalize browsing on YouTube. Ads shown in enhanced privacy mode are also not personalized. No cookies are set in enhanced privacy mode. However, local storage elements are stored in the user’s browser, which can contain personal data and be used for recognition purposes. Details about the enhanced privacy mode can be found here: https://support.google.com/youtube/answer/171780. After activating a YouTube video, further data processing operations may be triggered, over which we have no influence. The use of YouTube is in the interest of an attractive presentation of our online offerings. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, provided the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined by the TDDDG. Consent can be revoked at any time. Further information about data protection at YouTube can be found in their privacy policy at: https://policies.google.com/privacy?hl=en. The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA to ensure compliance with European data protection standards in data processing in the USA. Each company certified under the DPF commits to comply with these data protection standards. More information: https://www.dataprivacyframework.gov/participant/5780. Google Fonts (Local Hosting) This site uses Google Fonts for uniform font representation. The Google Fonts are installed locally. No connection to Google servers is established. More information on Google Fonts: https://developers.google.com/fonts/faq Google’s privacy policy: https://policies.google.com/privacy?hl=en Font Awesome (Local Hosting) This site uses Font Awesome for consistent font representation. Font Awesome is installed locally. No connection to servers of Fonticons, Inc. is established. More information about Font Awesome can be found in their privacy policy: https://fontawesome.com/privacy Google Maps This site uses the Google Maps map service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. This service allows us to display interactive maps directly on our website. To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. When Google Maps is activated, Google may use Google Fonts for uniform font representation. When accessing Google Maps, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. The use of Google Maps is in the interest of an appealing presentation of our online offerings and to make the locations we indicate on the website easy to find. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, provided the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting). Consent can be revoked at any time. Data transfer to the USA is based on the EU Commission’s standard contractual clauses. Details: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/ Further information about how Google handles user data can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en Google is certified under the “EU-US Data Privacy Framework” (DPF): https://www.dataprivacyframework.gov/participant/5780 Google reCAPTCHA We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. reCAPTCHA is used to check whether data entry on this website (e.g., in a contact form) is made by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. reCAPTCHA evaluates various information (e.g., IP address, time spent on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google. The reCAPTCHA analyses take place entirely in the background. Website visitors are not informed that an analysis is taking place. The storage and analysis of the data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its web offerings from abusive automated spying and SPAM. If consent has been requested, processing is based exclusively on Art. 6(1)(a) GDPR and § 25(1) TDDDG, provided the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting). Consent can be revoked at any time. Further information about Google reCAPTCHA and Google’s privacy policy can be found at: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en Google is certified under the “EU-US Data Privacy Framework” (DPF): https://www.dataprivacyframework.gov/participant/57808. Partner Programs & Affiliate Links
Our website and our social media profiles (e.g., Instagram, TikTok, YouTube) contain so-called affiliate links or partner links. If you click on such a link and make a purchase or register through it, we may receive a commission or other benefits from the respective provider. There are no additional costs for you. What are Affiliate Links? Affiliate links are specially marked links to external services or shops. When you click on such links, cookies or similar technologies may be set by the partner network to track successful referrals. Processing of Personal Data When you click an affiliate link, technical data (e.g., IP address, browser used, time) may be processed by the respective partner service. These processes are the responsibility of the respective partner network. We do not process any personal data in this context ourselves. Legal Basis The use of such links is based on your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG), insofar as tracking technologies are used. Consent is given via the cookie banner or actively by clicking the link. It can be revoked at any time. Partner Programs and Networks Used- Amazon EU Partner Program: https://affiliate-program.amazon.de/help/operating/agreement
- Digistore24: https://www.digistore24.com/page/privacy
- Awin Affiliate Network: https://www.awin.com/de/datenschutzerklarung
- TikTok Creator Marketplace: https://ads.tiktok.com/help/article?aid=6688399483093483522
- Instagram Branded Content Tools (Meta): https://www.facebook.com/privacy/policy/
9. Communication via Social Networks and Messaging Services
If you communicate with us via platforms such as Instagram, TikTok, or similar social networks (e.g., via direct message), the privacy policies of the respective platform providers also apply in addition to this privacy policy. Please note that these platforms independently collect and process personal data, over which we have no control. Contact via Instagram or TikTok Direct Messages (DMs) If you contact us via direct message on Instagram or TikTok, the personal data you provide (e.g., username, message, possibly profile information) will be processed by us exclusively for handling your inquiry. This data will not be shared with third parties and is solely used for communication with you. The legal basis for processing is Art. 6(1)(b) GDPR (contract or pre-contractual measures) or Art. 6(1)(f) GDPR (legitimate interest in efficient communication). Messages are regularly deleted unless statutory retention obligations apply. Processing of Personal Data by Platform Providers (Instagram, TikTok, YouTube) Please note that when visiting our profiles on platforms such as TikTok, Instagram, or YouTube, personal data may be processed by the respective platform operators. This includes, for example, your IP address, device information, content interactions, and possibly your usage behavior. These data are often also used for market research and advertising purposes and may be linked to other data (e.g., your account). We do not have full access to the data collected there and therefore recommend reviewing the privacy policies of the respective providers:- Meta (Instagram): https://privacycenter.instagram.com/policy
- TikTok: https://www.tiktok.com/legal/page/eea/privacy-policy
- YouTube (Google): https://policies.google.com/privacy?hl=en
Mobile App
Scope. This section explains how we process personal data when you install and use the Uchim mobile application (“App”) on iOS/Android. It complements the information provided for our website.
Categories of Data Processed
- Account & Profile (Art. 6(1)(b) GDPR): email, password hash, username/alias, preferences, subscription status, timestamps.
- Learning Data (Art. 6(1)(b), (f) GDPR): lesson progress, scores, streaks, custom lists, notes, recordings you choose to save.
- Device & Technical Data (Art. 6(1)(f) GDPR): app version, OS version, device model, crash logs, performance metrics.
- Usage Analytics (Art. 6(1)(a) GDPR; §25(1) TDDDG): events like feature usage, funnels, session length — only with consent where required.
- Push Notification Tokens (Art. 6(1)(a) GDPR or Art. 6(1)(f) where strictly service-related): device token to deliver notifications.
- Support Requests (Art. 6(1)(b), (f) GDPR): messages and attachments you send via in-app support or email.
- In-App Purchases (Art. 6(1)(b) GDPR): app store receipts, product IDs, timestamps (payment details handled by Apple/Google).
App Permissions
The App may request device permissions you can allow or deny:
- Notifications: to send reminders and updates.
- Microphone: for speech and pronunciation exercises (audio stored only if you save it).
- Photos/Media: if you upload a profile picture or support attachments.
Permissions can be managed in your device settings. Refusing a permission may limit related features.
Purposes & Legal Bases
- Service provision (Art. 6(1)(b) GDPR): account sync, progress storage, in-app communication.
- Security (Art. 6(1)(f) GDPR): fraud prevention, abuse detection, incident response.
- Analytics & product improvement (Art. 6(1)(a) GDPR): optional usage metrics, A/B testing.
- Notifications (Art. 6(1)(a) or (f) GDPR): reminders, updates; opt-out at any time.
- Purchases (Art. 6(1)(b) GDPR): manage subscriptions and entitlements.
- Support (Art. 6(1)(b), (f) GDPR): respond to inquiries, fix issues.
Hosting & Transfers
Hosting. App backend and data are hosted on secure servers provided by IONOS SE and Strato AG. These providers may process IP addresses and log data for reliable operation.
- Legal basis: Art. 6(1)(f) GDPR (reliable hosting) and Art. 6(1)(b) GDPR (contract performance).
- DPA: Data Processing Agreements are in place with IONOS and Strato.
- International transfers: If sub-processors outside the EU/EEA are engaged, we apply GDPR safeguards (Art. 46 SCCs, adequacy decisions, or DPF) with supplementary measures.
Retention
- Account & profile: stored while account is active, deleted within 30 days after deletion unless longer retention required.
- Learning data: stored while account is active, erased with deletion request.
- Crash/diagnostics: usually kept 90–180 days, then aggregated/anonymized.
- Purchase records: stored as required by tax/commercial law.
Third-Party Disclosures
- App Stores: Apple App Store and Google Play handle purchases as independent controllers.
- Analytics/Diagnostics: used only with consent; data includes aggregated usage events and crash reports.
- Support: If you contact us from within the app, your email/message is processed by our mail provider to answer your request.
We do not sell personal data and do not integrate third-party advertising SDKs without your prior consent where required.
Children
The App is not directed to children under 16 (or higher local minimum). If we become aware that we processed data of a child without proper consent, we will delete it.
User Choices
- Manage permissions in device settings.
- Disable notifications in system or in-app settings.
- Consent to/withdraw analytics tracking in the App’s privacy controls or consent banner.
- Exercise access, deletion, or portability rights by contacting hi@uchim.app or using in-app account deletion.
Automated Decision-Making
No automated decision-making with legal or similarly significant effects takes place. Recommendations are based on your learning progress and settings.