Privacy Policy
This Privacy Policy explains what Congiugno collects when you use congiugno.com (the “Website”) and the Congiugno iOS app (the “App”). The Service is designed to collect as little personal data as possible.
1. Who we are
The Service is operated by Anton Platonov, established in Bologna, Italy, holding Italian VAT number IT04308291204. Full operator details are published at congiugno.com/note-legali. We are the data controller for the personal data described here.
For privacy questions or requests, contact [email protected] or, for formal legal correspondence, [email protected].
2. Data we process
2.1 Data stored only on your device
The following data is created and stored only on your device. We do not receive it:
- drill progress, spaced-recall schedule, day counter, and app settings;
- onboarding and first-run prompt state;
- your analytics-consent choice.
On the Website this data is held in browser localStorage. In the App it is held inside the iOS sandbox. You can erase it by clearing browser data or deleting the App. Apple device backups, if enabled, are governed by Apple’s privacy policy.
2.2 App Store purchases
When you buy Congiugno Pro on iOS, Apple processes the transaction as merchant of record. From Apple we receive only purchase-status data needed to unlock Pro, such as product identifier, purchase date, transaction identifier, and verified purchase status.
We do not receive your Apple ID, payment card, billing address, or other payment details. Apple is an independent controller for App Store payments and its privacy policy applies: apple.com/legal/privacy.
2.3 Optional App analytics
The Website does not collect usage analytics. If you enable Analytics in the App, the App sends PostHog Inc. a random installation identifier, app and device information, and limited information about App use, learning progress, and purchase or restore outcomes. It also sends session replays showing interactions with the App.
Session replays may include on-screen text, images, and text entered in drill fields. System views remain masked. We do not collect names, email addresses, payment details, logs, network contents, or crash reports. We use this data only to improve the App. PostHog processes it for us in its EU cloud. You can disable Analytics at any time in Settings → Privacy. To request deletion, use the link there or email [email protected] with your Analytics ID. PostHog’s privacy policy is at posthog.com/privacy.
2.4 Local notifications
If you enable the daily reminder in the App, iOS schedules it locally on your device. We do not receive notification content, delivery confirmations, or open data.
3. Purposes and legal bases
- Operate and secure the Service: legitimate interest, Art. 6(1)(f) GDPR.
- Unlock and manage Pro access: contract, Art. 6(1)(b) GDPR.
- Optional App analytics: consent, Art. 6(1)(a) GDPR. Withdrawal does not affect earlier lawful processing.
We do not use App analytics for advertising, sell the data, or use it for automated decisions with legal or similarly significant effects.
4. Retention
- On-device data: until you clear browser data, delete the App, or restore the device.
- PostHog analytics events and session replays: up to 30 days.
- Apple transaction records: governed by Apple and applicable tax/accounting rules.
5. Third-party services and transfers
- Apple Inc. — App Store distribution, in-app purchase processing, iCloud Backup (if enabled). apple.com/legal/privacy.
- PostHog Inc. — optional App analytics and session replay, hosted in the EU. posthog.com/privacy.
- Cloudflare, Inc. — website hosting, CDN, and technical protection. cloudflare.com/privacypolicy.
PostHog hosts App analytics in the EU. Where PostHog, Apple, or Cloudflare transfers personal data outside the EEA, it uses applicable safeguards such as adequacy decisions or Standard Contractual Clauses.
6. Your rights
Subject to applicable law, you can ask for access, rectification, erasure, restriction, portability, objection to legitimate-interest processing, and withdrawal of consent. You can also lodge a complaint with the Italian Garante (garanteprivacy.it) or your local supervisory authority.
For device-only data, clearing browser data or deleting the App is usually the fastest way to erase it. For analytics deletion, use the link in the App’s Privacy screen or email [email protected] with your Analytics ID. We respond within one month where GDPR applies.
7. Children and security
Congiugno is not directed to children under 16. We do not knowingly collect personal data from children. The Service uses standard transport security, iOS sandboxing, and origin-limited browser storage.
8. Changes and contact
We post changes to this policy at this URL with an updated date.
Data controller: Anton Platonov
Established in: Bologna, Italy
Italian VAT number: IT04308291204
Email: [email protected]
PEC: [email protected]
Full registered-seat address: congiugno.com/note-legali.