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Політика конфіденційності

Оновлено: 2026-10-04

1. Introduction

This Privacy Policy describes how "SvitSliv" (the mobile app and website operated under the project SvitSliv, hereinafter "we", "us", or "the Service") handles information when you use our application or website. It is intended to meet common requirements for app stores (including Google Play and Apple App Store) and to inform you transparently about our practices.

2. Controller

Ivan Kharchenko
c/o flexdienst – #20597
Kurt-Schumacher-Straße 76
67663 Kaiserslautern
Germany

Email: edelhirschx@gmail.com

3. Data we process

3.1 Data you provide

If you contact us (for example via email or a feedback form), we process the content of your message and your contact details as needed to respond.

3.2 Data collected automatically

When you use the website or the app (including the Capacitor-based mobile client that loads our web content), standard technical data may be processed, such as the time of a request, browser or device type, app version, operating system, IP address, and diagnostic information. When advertising is enabled, Google Mobile Ads may also process the categories listed in Section 3.4. The precise data available to Google depends on your device, region, consent choices, and advertising settings.

3.3 Local storage on your device

The app stores preferences and learning-related data locally on your device (for example via browser or WebView storage). We do not operate a central server that stores your personal learning progress. This data stays on your device unless you send it to us explicitly (e.g. when reporting an issue).

3.4 Advertising-related data

When the mobile app requests or displays ads, Google Mobile Ads may collect or receive an IP address (which can be used to estimate coarse location), device or account identifiers (including an advertising ID where permitted), app and device information, advertising data, product interactions such as app launches, taps and video views, crash logs, and performance information such as launch time, hang rate, or energy usage. Google uses this information for ad delivery and measurement, analytics, security, and fraud prevention. Data transmitted by the Google Mobile Ads SDK is encrypted in transit. This advertising-related processing is separate from your locally stored SvitSliv learning progress.

4. Purposes and legal bases (GDPR)

Where the GDPR applies, we rely on appropriate legal bases, including:

  • Art. 6(1)(b) GDPR — performance of a contract or pre-contractual steps, when providing the Service you requested.
  • Art. 6(1)(f) GDPR — legitimate interests, such as operating, securing, and improving the Service, and measuring aggregate usage, where not overridden by your rights.
  • Art. 6(1)(a) GDPR — consent, where we or our partners ask for it (e.g. personalized advertising in the EEA/UK, or non-essential cookies on the website).

5. Analytics and hosting

Our website uses analytics provided by our hosting partner Vercel. Vercel Analytics does not use cookies; data is aggregated and not used to identify you directly. Hosting may process server log data (e.g. IP address, request time) as described in our German notice at /datenschutz.

We also use PostHog (PostHog, Inc.) on the EU cloud (stored in Frankfurt) to see how the website and the iOS and Android apps are used: time on a word (word id, not the word text), time in a trainer or the daily lesson, words added to favorites, the chosen companion (cat, dog, sun, or off), the platform, and a temporary recording of the screen so we can review the interface. There is no account, name, or email. PostHog stores a random id in localStorage.

On the website, PostHog loads only after you accept the analytics banner (Art. 6(1)(a) GDPR). In the iOS and Android apps the same events and recordings are sent while you use the app, without that banner (Art. 6(1)(f) GDPR, legitimate interest in improving the product). You can object by emailing us. Details are in the German notice.

We use Sentry to diagnose technical errors in the website and on the server. An error report may contain the error message, stack trace, page URL, browser or operating system information, and connection data. Browser session replay and performance tracing are disabled. We use these reports to keep the service reliable (Art. 6(1)(f) GDPR). See the German notice for details.

6. Website performance

Our website uses Vercel Speed Insights (Vercel Inc.) to measure page loading speed and Core Web Vitals (e.g. LCP, CLS, INP). Speed Insights does not use cookies, does not store IP addresses, and does not create user identifiers or profiles; the collected metrics are anonymous and aggregated. We use them solely to find and fix slow pages. This applies to the website only — the iOS and Android apps do not use Speed Insights. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a fast and reliable website).

7. Advertising

7.1 Mobile app — Google AdMob

The iOS and Android apps use Google AdMob (Google Ireland Limited / Google LLC). The app may display persistent banner ads, interstitial ads between learning activities, and rewarded video ads. Rewarded ads are shown after you explicitly choose to watch one and can grant bonus XP inside the app; this XP has no cash value. AdMob processes advertising-related data as described in Section 3.4 to deliver and measure ads, keep advertising secure, and help fund the free app.

7.2 EU / UK consent form (Google UMP)

If you are in the European Economic Area, Switzerland, or the United Kingdom, you may see a consent dialog provided by Google (User Messaging Platform, "UMP") when the app starts. It asks whether you allow Google and its partners to use data for personalized advertising. The dialog is operated by Google, and your choice is stored via Google's User Messaging Platform SDK. If you decline personalized advertising, non-personalized or limited ads may still be shown where legally permitted. These ads can still use data necessary for ad delivery, frequency capping, aggregated measurement, security, and fraud prevention.

7.3 iOS — App Tracking Transparency (ATT)

On Apple devices, iOS may separately ask whether the app may track you across other companies' apps and websites (IDFA). This relates to advertising measurement, not to your vocabulary learning data in SvitSliv. If you deny permission, the app does not receive access to the IDFA. You can change this choice in iOS Settings under Privacy & Security > Tracking.

7.4 Advertising partners and purposes

Google and participating advertising technology providers may process advertising-related data to select and deliver ads, measure ad performance, prevent invalid traffic and abuse, and—only where permitted by your choices and applicable law—personalize advertising. Their processing is governed by their own privacy terms. We do not sell your locally stored learning progress to advertisers.

7.5 Website advertising

The website svitsliv.com currently does not display advertising or load the Google AdSense script. Advertising in the mobile apps is described above.

7.6 Website — analytics choice

On the website, a banner asks whether you allow optional PostHog analytics and session recordings. Your choice is stored in your browser (localStorage key svitsliv_analytics_consent_v2). Declining does not affect the website's learning features.

More information: Google Privacy Policy, How Google uses data in advertising.

8. Your advertising and privacy choices

  • Consent dialog: where required, use the options shown in the Google consent dialog to accept, reject, or manage advertising purposes and providers. You can reopen these choices from Settings under Privacy and advertising in the iOS and Android apps.
  • iOS tracking:manage ATT permission in iOS Settings under Privacy & Security > Tracking.
  • Android advertising ID: reset or delete the advertising ID using the privacy or ads controls in Android Settings.
  • Google advertising:manage ad personalization and related choices through Google's privacy and advertising controls.
  • Website analytics: decline optional analytics in the banner or reopen Privacy Settings from the website footer.

9. Cookies and similar technologies (website)

9.1 Essential — interface language

We store your chosen interface language in a first-party cookie named jasno_ui_locale (and in localStorage for the same purpose). This is needed to remember Ukrainian, English, or Romanian in the menu. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in providing the Service in your language).

9.2 Optional analytics — PostHog (with consent)

If you allow analytics, PostHog stores a random identifier in localStorage and may record your website session as described in Section 5. Legal basis: Art. 6(1)(a) GDPR (consent).

9.3 Other website measurement

Vercel Analytics and Vercel Speed Insights do not use cookies (see Sections 5 and 6). If you decline optional analytics, we do not start PostHog or send PostHog events from the website. Sentry browser session replay is disabled.

10. Children

The Service is not directed at children under 16. We do not knowingly collect personal data from children. If you believe we have collected such data, please contact us and we will take appropriate steps.

11. Retention

We retain personal data only as long as necessary for the purposes described, unless a longer period is required by law. Local data stored on your device is controlled by you (you can clear app or browser data). Advertising partners apply their own retention periods.

12. Your rights

Depending on applicable law (including the GDPR where it applies), you may have the right to access, rectify, erase, restrict processing, data portability, and to object. You may also lodge a complaint with a supervisory authority. Where processing is based on consent, you can withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. The controls described in Section 8 can be used for advertising and tracking choices.

13. International transfers

If data is processed outside the European Economic Area (e.g. by Vercel or Google in the USA), we rely on appropriate safeguards as required by applicable law (e.g. standard contractual clauses or the EU-U.S. Data Privacy Framework, where applicable). PostHog product data for this service is stored in the EU cloud (Frankfurt).

14. Changes

We may update this Privacy Policy from time to time. The "Last updated" date at the top will change when we do. Continued use of the Service after changes constitutes your acknowledgment of the updated policy, to the extent permitted by law.

15. Contact

For privacy-related questions, contact us at edelhirschx@gmail.com.

A German-language privacy notice (Datenschutzerklärung) is also available at /datenschutz.