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 or expiry date, transaction identifier, and verified subscription 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 and does not offer an email waitlist form. The App sends analytics only if you choose Enable analytics. These events help us understand aggregate product usage: screens viewed, drill counts, tenses reached, session completion or abandonment, paywall events, purchase plan, restore events, and Pro lapse status.
Analytics events do not contain typed answers, keystrokes, screen contents, name, email, Apple ID, payment details, or billing details. Events are sent through TelemetryDeck GmbH in Germany and include a salted SHA-256 hashed installation identifier, app version, iOS version, device model, and language setting. We treat this identifier as pseudonymous personal data. You can withdraw consent any time in the App’s Privacy screen. TelemetryDeck’s privacy policy is at telemetrydeck.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 run advertising, sell data, share data for behavioural advertising, train AI models on your data, or make 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.
- TelemetryDeck events: up to 24 months.
- 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.
- TelemetryDeck GmbH — App analytics, opt-in only. telemetrydeck.com/privacy.
- Cloudflare, Inc. — website hosting, CDN, and technical protection. cloudflare.com/privacypolicy.
TelemetryDeck operates from Germany. Cloudflare and Apple may transfer data outside the EU under their own transfer safeguards, including the EU-US Data Privacy Framework or Standard Contractual Clauses where applicable.
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. To exercise rights for data we can access, email [email protected]. 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.