Privacy policy

Wortspur does not send Your personal information anywhere. Your progress, Your settings and the first name You may choose to enter all stay on Your Device. There is no account, no analytics, no advertising and no tracking of any kind. The Application makes one automatic network request, described below, and it carries nothing about You.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service, and tells You about Your privacy rights and how the law protects You. By using the Service, You agree to this Privacy Policy. Wortspur does not collect personal data; what it stores, and where, is described below.

1. Interpretation and Definitions

Interpretation. The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions. For the purposes of this Privacy Policy:

• Application refers to Wortspur, the software program provided by the Company.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Samson Clement, an independent developer publishing under the name Dusk Enterprise. Dusk Enterprise is a name Wortspur is published under, not a registered company; the data controller is Samson Clement personally.
• Country refers to: Kuwait.
• Device means any device that can access the Service, such as a phone or a tablet.
• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual. We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.
• Service refers to the Application.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

2. Collecting and Using Your Personal Data

Personal Data. The Application has no account to create and does not ask You to identify Yourself. It offers one optional field: a first name, which You may enter so that the daily reminder can greet You by it. That name is stored on Your Device, is used only inside the Application, and is never transmitted to Us. You may clear it at any time by emptying the field, or remove it with everything else as described in section 9.

Information stored on Your Device. To remember Your progress and preferences, the Application stores the following on Your Device:

• the level You are working at, and which packs You have finished, including the words You have found, Your best and most recent times, and the board each pack is showing;
• Your settings: colour theme, light or dark mode, text size, haptics, whether the screen stays awake, and whether a word is spoken aloud when You find it;
• the answers You gave during onboarding — why You are learning, and how many minutes a day You said You could give — and the optional first name described above;
• whether the daily reminder is on and the time You chose for it;
• a small amount of housekeeping: when the Application was first opened, how many times it has been opened, the last version You ran, how far along the review prompt is, and counters that stop the Application asking twice about a better German voice;
• whether a subscription is active and the date it began, so the Application can show You how long is left of the free month.

This information stays on Your Device. It is not transmitted to Us, it is not stored on any server of Ours, and We cannot access it. The Application does not collect Usage Data, contains no analytics or advertising software, and uses no third-party tracking of any kind.

The one request the Application makes on its own. When the Application opens, it asks the App Store whether a newer version of Wortspur has been published, so that it can offer You the update. That request sends the Application's own identifier (com.dusk.wortspur) and nothing else — no name, no identifier belonging to You or Your Device, and nothing about how You use the Application. On Android the equivalent check is made for Us by Google Play services. Apart from this, and apart from the purchase checks described next, the Application does not connect to the internet at all.

Use of Your Personal Data. The Company may use Personal Data for the following purposes:

• To provide and maintain Our Service.
• For the performance of a contract: the undertaking of the purchase contract for the subscription You have taken out.
• To manage Your requests: to attend and manage Your requests to Us.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Our assets.

We may share personal information in the following situations: with Your consent, for any purpose You agree to; and for business transfers, as described above. We do not share Your information with advertisers, data brokers or analytics providers, because We do not hold any to share.

3. Purchases

Purchases in the Application are processed entirely by Apple or by Google. We never receive Your payment card details, Your billing address, or Your Apple ID or Google account. To know whether You have an active subscription, the Application checks the purchase record Apple or Google keeps for Your account, and that check happens on Your Device.

The first month is free. It is an introductory offer on the subscription itself, so it is Apple or Google — not Us — that records when it started and when it ends. We could not extend it, restart it or look it up even if You asked Us to; it is managed entirely from Your App Store or Google Play account, where You can also cancel.

Apple and Google provide Us with aggregated sales reports, which count purchases by country and by day and do not identify anyone. How Apple handles Your information is described in the Apple Privacy Policy, and Google in the Google Privacy Policy.

4. The daily reminder

If You turn the daily reminder on, the Application schedules it on Your Device using the operating system's own notification service. The reminder is written and delivered locally. There is no push service, no device token, and nothing about You or the reminder leaves Your Device. Turning it off in the Application, or refusing the notification permission, stops it entirely.

5. Spoken German

The Application reads German words and example sentences aloud using the speech engine built into Your Device. On iPhone and iPad this happens on the Device. On Android, the system speech engine You have selected may use one of its own online voices, in which case the German text being read is sent by that engine to its provider — this is Your Device's speech setting rather than something the Application chooses, and the text sent is the German vocabulary itself, never anything about You.

6. Crash reports

We do not include any crash-reporting or diagnostic software in the Application. If You have chosen in Your Device settings to share analytics and crash reports with app developers, Apple or Google may pass Us crash reports. They arrive already stripped of information that identifies You, and We use them only to fix faults. You can turn this off at any time — on iPhone and iPad in Settings → Privacy & Security → Analytics & Improvements, and on Android in Settings → Google → Usage & diagnostics.

7. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations, resolve disputes, and enforce Our legal agreements and policies.

The only information We hold is correspondence You send Us. We keep it for as long as is needed to answer You and to handle any follow-up, and no longer than 12 months, after which it is deleted. Everything else the Application knows about You is on Your Device, for as long as You keep it there.

We may retain Personal Data beyond the period stated above where We have a legal obligation to do so, where it is needed to establish or defend a legal claim, where You have asked Us to, or where a copy persists briefly in a routine backup.

8. Transfer of Your Personal Data

Our contact address is a Gmail account, so Google LLC handles that correspondence as Our email provider and stores it on servers in the United States. We read it in Kuwait, which has no adequacy decision from the European Commission, so correspondence You send Us from the European Economic Area or the United Kingdom reaches a country outside it. Nothing else We hold is transferred anywhere, because there is nothing else We hold.

9. Delete Your Personal Data

You have the right to delete, or to request that We assist in deleting, the Personal Data that We have collected about You.

• Reset all data in Settings → Developer clears everything listed in section 2 — Your progress, Your settings, Your name and the onboarding answers — and returns the Application to how it was on the day You installed it.
• Deleting the Application from Your Device removes that information with it.
• Your subscription is not affected by either. It belongs to Your Apple or Google account, not to the Application, and is cancelled from Your App Store or Google Play subscription settings.
• To have correspondence You have sent Us deleted, write to duskenterprise.team@gmail.com.

Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

10. Disclosure of Your Personal Data

Business Transactions. If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement. Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (for example, a court or a government agency).

Other legal requirements. The Company may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation; protect and defend the rights or property of the Company; prevent or investigate possible wrongdoing in connection with the Service; protect the personal safety of users of the Service or the public; or protect against legal liability.

11. Security of Your Personal Data

Because the information described in section 2 never leaves Your Device, the security of it is the security of Your Device itself: it is protected by Your device passcode and by the Application's sandbox, which prevents other applications from reading it. We hold no copy of it, so there is no database of Ours that could be breached. Where We do hold information — correspondence You send Us by email — We use commercially acceptable means to protect it, but no method of electronic storage is 100% secure, and We cannot guarantee its absolute security.

12. Your rights under the GDPR

Samson Clement is the data controller for the information described in this Privacy Policy — an individual rather than a company, which is why no registration number appears anywhere in it. Where We process personal data, We rely on these legal bases: performance of a contract, where processing is needed to provide the Service You asked for; Our legitimate interests, where We answer Your correspondence or fix faults; Your consent, where You have given it, which You may withdraw at any time; and compliance with a legal obligation.

Because the Application keeps everything on Your Device, there is in practice nothing of Yours for Us to look up, correct, export or delete. If You have written to Us, these rights apply to that correspondence: You have the right to access it, to have it corrected, to have it erased, to restrict or object to Our processing of it, and to receive it in a portable form. To exercise any of these, write to duskenterprise.team@gmail.com — We will respond within 30 days, and We do not charge for it.

You also have the right to complain to Your national data protection authority.

13. Your rights under the CCPA/CPRA

In the past twelve months We have not collected any categories of personal information from users of the Application. We do not sell Your personal information and We do not share it for cross-context behavioural advertising, and We have never done so. We do not use or disclose sensitive personal information for purposes beyond those permitted.

California residents may request to know what personal information We hold, to have it deleted, and to have it corrected. Write to duskenterprise.team@gmail.com. We will not discriminate against You for exercising these rights.

14. Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information.

Because the Application sends no personal information to Us from anyone, it sends none from children. The optional first name it can store stays on the Device.

15. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us — Your App Store or Google Play subscription settings, the store listing, and Our own site. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

16. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via a prominent notice on Our Service, prior to the change becoming effective, and update the "In effect from" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

17. Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: duskenterprise.team@gmail.com

Samson Clement, an independent developer publishing as Dusk Enterprise — Kuwait.