🇧🇬 Privacy Policy

Learn Bulgarian: Speak BG — Last updated: June 26, 2026

🔒 Privacy at a Glance

Table of Contents

  1. Introduction
  2. Information We Collect
  3. Sensitive Data (Microphone / Audio)
  4. How We Use Your Data
  5. Legal Bases for Processing (GDPR)
  6. Speech Processing Details
  7. Data Storage & Security
  8. Data Sharing
  9. Data Retention
  10. Your Privacy Rights
  11. Data Deletion
  12. Third-Party Services
  13. Tracking Technologies
  14. Do-Not-Track
  15. US State Privacy Rights
  16. International Data Transfers
  17. Children's Privacy
  18. Changes to This Policy
  19. Contact Us

1. Introduction

Welcome to Learn Bulgarian: Speak BG ("the App," "we," "us," or "our"). We are committed to protecting your privacy. This Privacy Policy explains what information is collected, how it is used, and your rights with respect to that information.

By using the App, you agree to the practices described in this Policy. If you do not agree, please discontinue use of the App.

The App is designed with privacy by default: all learning progress lives entirely on your device, we do not require account creation, and we do not build server-side profiles of our users.

2. Information We Collect

2.1 Data Stored Locally on Your Device

All learning progress is stored on your device using AsyncStorage under the key sofia_progress_v2. This data never leaves your device except as described below. It includes:

This data is entirely local. Deleting the app or clearing app data from your device settings removes it completely.

2.2 Audio Data (Speaking Exercises)

When you complete a speaking exercise, the App records a short audio clip through your device microphone. This audio is:

The service returns only a similarity score and transcript. We do not keep the audio file. OpenAI processes the audio as our sub-processor under their API terms; per OpenAI's policy, API audio is not used to train their models and is retained by OpenAI only transiently for abuse monitoring. See OpenAI's Privacy Policy.

2.3 Subscription and Purchase Data (RevenueCat)

When you purchase a premium subscription, the transaction is handled by Apple App Store or Google Play and managed by RevenueCat. RevenueCat may collect:

We do not receive or store your payment card details. See RevenueCat's Privacy Policy for details.

2.4 Advertising Data (Google AdMob — Free Users)

If you use the free tier, the App displays ads served by Google AdMob. AdMob may collect:

Premium subscribers do not see ads and AdMob data collection is minimized. See Google's Privacy Policy for details.

2.5 Data We Do NOT Collect

2.6 CCPA Categories of Personal Information

CategoryCollectedSource
Identifiers (device ID, ad ID)Yes (AdMob/RevenueCat)Device / Third parties
Internet / network activityMinimal (ad interactions)AdMob
Inferences (interests)No
Sensitive personal info (audio)Transient only (not stored)Microphone, in-app
Name, email, financial infoNo
Geolocation (precise)No

3. Sensitive Data (Microphone / Audio)

The App requests microphone permission solely for speaking exercises. We treat audio data with the highest level of care:

4. How We Use Your Data

PurposeData UsedLegal Basis (GDPR)
Deliver learning content & track progressLocal AsyncStorage dataContract / Legitimate Interest
Pronunciation feedbackAudio (transient), target phraseContract / Consent
Manage premium subscriptionsRevenueCat identifiersContract
Display relevant ads (free users)AdMob advertising IDConsent (ATT) / Legitimate Interest
Maintain streak & gamificationLocal progress dataContract / Legitimate Interest
Push notifications (opt-in)Device token (local)Consent
App analytics & error trackingAggregated, non-identifiableLegitimate Interest

We do not use your data for automated profiling that produces legal or similarly significant effects.

If you are located in the European Economic Area (EEA) or UK, we process personal data under the following legal bases:

6. Speech Processing Details

Speaking exercises are powered by a speech-recognition service hosted on Supabase Edge Functions, which uses OpenAI's audio transcription API to convert your recorded speech to text.

What is sent:

What is returned:

What is retained by us: Nothing. The Edge Function processes the request in memory and returns only the analysis result. No audio data is written to any database or storage bucket on our side. The only record we keep is an anonymous per-client request counter used to rate-limit the service against abuse (no audio, transcript, or personal identifier is stored in it).

OpenAI's role: The audio clip is transmitted to OpenAI solely to generate the transcript. Under OpenAI's API terms, this audio is not used to train their models and is retained by OpenAI only transiently for abuse monitoring before deletion.

All communication with the speech service and OpenAI uses HTTPS with TLS encryption.

7. Data Storage & Security

Local data (AsyncStorage): Stored on your device's sandboxed storage. Protected by your device's OS-level security (encryption at rest on modern iOS and Android). Cleared when you delete the app or clear app data.

Speech processing (Supabase): Audio is transmitted over TLS. Supabase infrastructure is hosted on AWS and complies with SOC 2. Audio is not persisted. See Supabase's Privacy Policy.

Subscriptions (RevenueCat): Purchase data is stored on RevenueCat's servers with industry-standard encryption. See RevenueCat's Privacy Policy.

Ads (AdMob): Ad data is handled on Google's infrastructure. See Google's Privacy Policy.

We take reasonable technical measures to protect your data. No system is completely secure; if you become aware of a security issue, please contact us immediately.

8. Data Sharing

We do not sell, rent, or trade your personal information. We share data only as follows:

We do not sell or share personal information for cross-context behavioral advertising.

9. Data Retention

10. Your Privacy Rights

Universal Rights

GDPR Rights (EEA / UK)

CCPA Rights (California)

To exercise any rights, email us at bora.nikolai.mindwise@gmail.com with subject "Privacy Rights Request." We respond within 30 days (45 days for complex requests).

11. Data Deletion

Deleting Local Progress Data

Because all learning data is stored on your device, you have direct control over it:

  1. iOS: Delete the app from your device. All data is immediately removed.
  2. Android: Go to Settings → Apps → Learn Bulgarian: Speak BG → Storage → Clear Data.
  3. Or: Reinstall the app — this clears all local data and resets progress.

Deleting RevenueCat Subscription Data

If you want your RevenueCat purchase history deleted, email us at bora.nikolai.mindwise@gmail.com with subject "Data Deletion Request" and we will submit a deletion request to RevenueCat on your behalf.

Opting Out of Advertising

For any data deletion request, we respond within 30 days. See our Data Deletion Guide for step-by-step instructions.

12. Third-Party Services

ServicePurposeData SharedPrivacy Policy
RevenueCat Subscription & in-app purchase management Anonymous user ID, purchase transactions revenuecat.com/privacy
Google AdMob Ad serving (free users) Advertising ID, device info, ad interactions policies.google.com/privacy
Supabase Hosts speech recognition Edge Function Audio (transient, not stored), phrase text supabase.com/privacy
OpenAI Audio-to-text transcription for pronunciation scoring Audio (transient; not used for training), phrase text openai.com/policies/privacy-policy
Apple App Store App distribution & IAP Apple user ID (for IAP validation only) apple.com/legal/privacy
Google Play App distribution & IAP Google account ID (for IAP validation only) policies.google.com/privacy

13. Tracking Technologies

The App does not use cookies or browser-based tracking. On-device storage uses React Native AsyncStorage, which is sandboxed to the App and never accessible by other apps or websites.

Google AdMob uses the device advertising identifier (IDFA on iOS, GAID on Android) to serve relevant ads. This identifier is not linked to your name or email. You can reset or disable it via your device privacy settings at any time.

We do not use cross-app or cross-site behavioral tracking beyond what AdMob applies under Google's policies.

14. Do-Not-Track

The App does not respond to browser-level Do-Not-Track signals (as it is a native mobile app, not a website). To limit advertising tracking, use your device's built-in privacy controls described in Section 11.

15. US State Privacy Rights

California (CCPA / CPRA)

California residents have the rights described in Section 10. We do not sell personal information. To exercise California rights, email bora.nikolai.mindwise@gmail.com with "California Privacy Request" in the subject line.

Virginia (VCDPA)

Virginia residents have rights to access, correct, delete, and obtain a copy of personal data. Contact us to exercise these rights. You may appeal a denial by emailing us with "Privacy Rights Appeal" in the subject.

Colorado (CPA)

Colorado residents have similar rights including the right to opt out of targeted advertising. Contact us to exercise these rights.

Connecticut (CTDPA)

Connecticut residents have rights to access, correction, deletion, portability, and opt-out rights. Contact us to exercise these rights.

Utah (UCPA)

Utah residents have rights to access, deletion, and portability of personal data. Contact us to exercise these rights.

For all US state requests, email bora.nikolai.mindwise@gmail.com with your state and specific request. We respond within 45 days.

If your appeal is denied, you may contact your state's attorney general. California Department of Justice — Consumer Complaint.

16. International Data Transfers

The App is operated from Bulgaria. Data processed by our third-party services (RevenueCat, AdMob, Supabase, OpenAI) may be transferred to and processed in the United States and other countries.

Where required by GDPR, these transfers are made under Standard Contractual Clauses (SCCs) or other approved transfer mechanisms. For EEA users, you may contact us for details about applicable transfer safeguards.

17. Children's Privacy

The App is not directed at children under 13 (or under 16 in the EEA). We do not knowingly collect personal information from children under these ages. If you believe a child has used the App and provided information, please contact us at bora.nikolai.mindwise@gmail.com and we will take immediate steps to address it.

18. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. For material changes, we will provide notice through the App or via a prominent notice on this page. Continued use of the App after changes are posted constitutes your acceptance of the updated Policy.

19. Contact Us

Email: bora.nikolai.mindwise@gmail.com

Location: Bulgaria

For privacy inquiries, data access requests, or deletion requests, please email us with subject line "Privacy Request" and include any relevant details (e.g., the specific right you wish to exercise). We respond within 30 days.

You may also contact your local data protection authority:

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