Tounsi App Privacy Policy

Legal

This is a translation for convenience. In case of discrepancies, the German version prevails to the extent permitted by law.

This privacy policy applies to the app „Tounsi: Tunesisch lernen“ for iOS and Android. It explains what personal data is processed when you use the app, for what purposes and on what legal basis. The website tounsi.app has its own privacy policy.

1. Controller

Email: info@tounsi.app
Legal notice: tounsi.app/en/legal-notice

No data protection officer has been appointed, as there is no legal obligation to do so. For any privacy question, an email to info@tounsi.app is enough.

2. Overview

• The app works without an account. All lessons and audio files are included in the app and can be used offline.
• An account is optional. It lets you back up your progress, use it on several devices and send feedback.
• Usage statistics are only collected if you agree. The app asks you once; until you answer, they are off.
• Crash reports are only sent if you agree. The app asks you once – together with usage statistics, but as a separate choice; until you answer, they are off.
• Ads (free version only) follow your choice in the ad consent dialog.
• The app does not access your microphone, camera, location, contacts or photos. There are no server push notifications.
• We do not sell your data.

3. Data stored on your device

Your learning progress, learning time, settings, app language, daily goal, reminder times, favorites, placement test result, lessons unlocked through reward videos and your choices on ads, usage statistics and crash reports are stored locally on your device. Without an account, this data is not transferred to us. It may, however, be included in backups you have set up on your device (iCloud or device backup on iOS, Google device backup on Android); Apple’s or Google’s terms apply to those. The data is deleted when you uninstall the app.

Storing this data on your device is permitted under § 25(2) no. 2 TDDDG because it is strictly necessary for the function you requested. Where personal data is processed, the legal basis is Art. 6(1)(b) GDPR.

4. Technically necessary connections

When it starts, the app reads a general configuration from Google Firebase (Cloud Firestore, see section 5): whether a new version is available and which app languages are enabled. This configuration contains no data about you. Your IP address and connection data are technically transmitted to Google.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is pointing users to current and secure versions and keeping the app working.

5. User account and sync (optional)

You can create an account with an email address and password, with „Sign in with Google“ or – on iPhone and iPad – with „Sign in with Apple“. We then process:

• email address, display name and a user ID
• for Google or Apple sign-in, the data provided by Google or Apple (email address, name; with Apple, optionally an anonymous relay address)
• learning progress, including daily learning activity, review status per word and the lesson you last worked on
• favorites and your own favorite lists (including the names you give them)
• subscription status (whether PRO is active, product, expiry date, renewal) and the ID under which RevenueCat manages your subscription (the same as your user ID)
• the selected app language

The purposes are providing the account, backing up and syncing your progress, and linking a PRO subscription to it. Legal basis: Art. 6(1)(b) GDPR (contract of use).

Sign-in and storage use Firebase Authentication and Cloud Firestore by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland („Google“), acting as our processor (Art. 28 GDPR). The Firestore database is located in a data center in the EU (Berlin region). Access by Google LLC (USA) cannot be ruled out. Google LLC is certified under the EU-US Data Privacy Framework (European Commission adequacy decision, Art. 45 GDPR); standard contractual clauses also apply.

Signing out: When you sign out, the data on your device stays there; the link to RevenueCat is removed.

Deletion: You can delete your account in the app at any time (Account & profile → „Delete account permanently“). This deletes your account, the progress stored in the cloud, your favorites and favorite lists, and the feedback and word reports you submitted (section 8). On your device, progress, the account’s favorites and unlocked lessons are deleted.

The following is not deleted:

• your purchase history with Apple or Google and with RevenueCat (section 6). The app tells you this before deletion. An active subscription does not end when you delete your account; cancel it in your store settings.
• feedback emails already forwarded to our mailbox (section 8). We delete them on request by email.
• pseudonymous statistics data (section 7.2), because it is not linked to your account.
• the permission you granted the app in your Google account; you can remove it in your Google account settings.

Otherwise, account data is kept for as long as the account exists.

6. Purchases and PRO subscription

PRO is purchased as a subscription through the Apple App Store or Google Play. Apple or Google process the payment under their own responsibility. We do not receive any payment details. Apple’s or Google’s privacy policies apply.

To manage subscriptions we use RevenueCat (RevenueCat, Inc., 1032 E Brandon Blvd #3003, Brandon, FL 33511, USA). The app connects to RevenueCat every time it starts to check your subscription status – even without an account or purchase. Without an account this happens under a random RevenueCat ID; with an account, under your user ID. RevenueCat processes this ID, store purchase receipts, product, time of purchase, subscription status and expiry date, as well as technical data such as device type, operating system, app version and IP address; exactly which technical data depends on the SDK. The app does not send your name or email address to RevenueCat.

The purposes are verifying purchases, unlocking PRO, showing subscription offers and restoring purchases on other devices. Legal basis: Art. 6(1)(b) GDPR (contract or pre-contractual steps); where the check happens at app start without any intention to buy, Art. 6(1)(f) GDPR, our legitimate interest being to correctly unlock subscriptions already purchased.

RevenueCat acts as our processor. Data is processed in the USA. Transfers are based on the European Commission’s standard contractual clauses (Art. 46(2)(c) GDPR). Purchase data is kept as long as needed to manage your subscription and then for the statutory retention periods. If you delete your account, we also delete your customer record at RevenueCat. Beyond that, RevenueCat’s own privacy policy applies.

7. Ads, usage statistics and crash reports

These three areas are independent of each other. Each choice applies only to its own area.

Area	Default	Change it in the app
Ads (free version only)	according to your choice in the ad consent dialog	More → Privacy & offline → „Open privacy settings“; on iPhone/iPad also iOS Settings → Privacy & Security → Tracking
Usage statistics	off until you agree	More → Settings → Data & progress → „Usage statistics“
Crash reports	off until you agree	More → Settings → Data & progress → „Crash reports“

Withdrawal applies to the future.

7.1 Ads (Google AdMob) and consent dialog

The free version shows ads: banners, full-screen ads and optional rewarded ads that unlock a lesson for 24 hours. PRO is ad-free.

Consent dialog: On first launch, where required by law, the app shows Google’s consent dialog (User Messaging Platform). On iPhone and iPad, the app then uses Apple’s „App Tracking Transparency“ prompt to ask whether it may use your device identifier for ads. Both choices apply only to ads – not to usage statistics and not to crash reports. Your choice is stored on your device. If no dialog is required in your region, the app shows a notice when you open the privacy settings.

The provider is Google AdMob by Google Ireland Limited (address above). The following may be processed: IP address, the device’s advertising ID (Android advertising ID; on iPhone/iPad the IDFA only if you allow tracking), device type, operating system, language setting, app information, an approximate location derived from the IP address and interactions with ads (impressions, clicks). The app does not pass any information about your learning content to Google.

Depending on your choice, there are three states:

• Personalized ads – with your consent. Google may build usage profiles for this.
• Non-personalized ads – ads without a profile; with your consent, Google accesses device identifiers or storage for this (e.g. frequency capping, fraud prevention, measurement).
• Limited ads – without that consent. Google then processes data only to a limited extent, without personalization and without access to device identifiers.

Which state applies to you depends on your choice, your region and Google’s requirements.

Legal basis: for personalized and non-personalized ads, Art. 6(1)(a) GDPR and § 25(1) TDDDG (consent). For limited ads without consent, Art. 6(1)(f) GDPR, our legitimate interest being to fund the free version.

Google processes some advertising data under its own responsibility. Transfers to the USA are based on the EU-US Data Privacy Framework. More information: https://policies.google.com/technologies/ads

7.2 Usage statistics (our own statistics and Google Analytics for Firebase)

Only with your consent. After setup, the app asks you once: „Send usage statistics?“. „Yes“ and „No“ are equal options. Until you answer, statistics are off. Your choice in the ad consent dialog does not count for this. You can give or withdraw consent at any time under More → Settings → Data & progress → „Usage statistics“.

With your consent, the app records how it is used:

• sessions (start, length), screens viewed and automatic events of the analytics service (e.g. first open, session start)
• lesson start and completion, choosing and changing the app language
• views of the PRO page and start, cancellation, errors (with error code), success (with product, price, currency) and restoring of purchases
• app version, platform, device and system information, selected app language
• a randomly generated pseudonymous ID per installation

This ID is not linked to your account. The analytics service does not collect your device’s advertising ID (iOS: version without advertising ID; Android: advertising ID collection turned off). The purpose is to understand which content is used and where users get stuck, and to improve the app.

The data is processed via Google Analytics for Firebase (Google Ireland Limited) and in our own statistics database in Cloud Firestore at Google (see section 5). Google Analytics for Firebase is linked to Google AdMob so that usage and ad revenue can be evaluated together.

Withdrawal: If you turn statistics off, the app stops sending statistics data. The pseudonymous ID and analytics data on your device are deleted. Statistics data already sent stays stored in pseudonymous form until the retention period ends.

Note for users of earlier versions: If you agreed to ad consent in an earlier version of the app, usage statistics were linked to it at the time. On the first launch after updating to version 2.0.0, Google Analytics may still send automatic start events (e.g. app update, session start) before the app turns collection off. After that, your new answer applies.

Legal basis: Art. 6(1)(a) GDPR and § 25(1) TDDDG (consent). For the start events in the note above, Art. 6(1)(f) GDPR applies; our legitimate interest is a smooth transition to the new version.

Retention: Statistics data is kept only as long as needed for the purpose.

Transfers to the USA are based on the EU-US Data Privacy Framework.

7.3 Crash reports (Firebase Crashlytics)

Crash reports are only sent if you agree. The app asks you once – together with usage statistics, but as a separate choice; until you answer, crash reports are off. If you agreed and the app crashes or hits certain errors, it sends a report to Firebase Crashlytics (Google Ireland Limited). The report contains the error trace, device model, operating system, app version, time and an installation ID. It contains neither your user ID nor the statistics ID. The purpose is finding and fixing crashes and errors.

You can withdraw your consent at any time under More → Settings → Data & progress → „Crash reports“. Reports not yet sent are then discarded.

Note for users of earlier versions: Before version 2.0.0, crash reports were linked to ad consent. If you agreed to it, a crash report already stored on your device may still be sent on the first launch after the update, before the app turns collection off. After that, your new answer applies.

Legal basis: Art. 6(1)(a) GDPR and § 25(1) TDDDG (consent). For a stored report in the note above, Art. 6(1)(f) GDPR applies; our legitimate interest is a smooth transition to the new version.

Retention: According to Google, crash reports are kept for 90 days and then deleted. Transfers to the USA are based on the EU-US Data Privacy Framework.

8. Feedback and word reports

If you are signed in, you can send feedback or report a problem with a word.

Feedback – we process:

• your message and the selected category
• your name (required) and, optionally, a contact email address
• account ID, account email and display name
• app version, platform, general device type (e.g. „iPhone or iPad“), device language, app language and time

Word reports – we process the word concerned, the selected category, an optional comment, app version, platform, device language, app language, time, and account ID, account email and display name.

Both are stored in Cloud Firestore (see section 5). Feedback is also forwarded by email to info@tounsi.app, with your contact or account email as the reply address. It is sent via an email service of Google (Gmail); the mailbox is hosted by IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany (processor).

The purpose is handling your message and improving the content. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest being to answer feedback and fix errors; where your message concerns your account or subscription, Art. 6(1)(b) GDPR.

Reports in the app database are deleted with your account (section 5); forwarded emails on request. Beyond that, we delete feedback once it has been handled and we no longer need it.

9. Reminders

Learning reminders are scheduled locally on your device. To do this, the app reads the device’s time zone. There are no server push notifications. The app only asks for notification permission when you turn reminders on, and you can revoke it in your system settings at any time.

10. Sharing and ratings

When you share the app, your operating system’s share sheet opens. The app does not learn who you share with. For ratings, the app uses Apple’s or Google’s rating feature, and your rating goes directly to Apple or Google.

11. External links

The app contains links to the app stores, to this website and to Tounsi’s pages on Facebook, Instagram and TikTok. These are ordinary links; no services from these providers are embedded. You only leave the app when you tap a link. The linked services‘ own privacy policies apply.

12. Downloading the app

When you download the app from the Apple App Store or Google Play, Apple or Google process data such as account data, device ID and time under their own responsibility. We have no influence on this.

13. Minors

Under Art. 8 GDPR, people under 16 can only give consent (e.g. to personalized ads or usage statistics) with the approval of a parent or guardian.

14. Your rights

Under the GDPR you have the following rights:

• access (Art. 15)
• rectification (Art. 16)
• erasure (Art. 17)
• restriction of processing (Art. 18)
• data portability (Art. 20)
• objection to processing based on Art. 6(1)(f) GDPR, on grounds relating to your particular situation (Art. 21)
• withdrawal of consent at any time with effect for the future (Art. 7(3)), in the app as described in section 7

The pseudonymous statistics ID is stored only on your device and is deleted when you withdraw consent. Without it, we cannot link statistics data to any person (Art. 11 GDPR).

An email to info@tounsi.app is enough. The app itself does not offer a data export; you can request a copy of your account data.

15. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for the controller’s location is:

16. Changes

We update this privacy policy when the app or the services it uses change. The version published on this page applies.

Last updated: October 2026 (app version 2.0.0)