Data controller
Kestrel, at kestrelwords.com, is the data controller. You can email us at support@kestrelwords.com. We store personal data in the EU, under the GDPR. If you sign in or pay, Apple processes that, and that processing is not limited to the EU.
Account
If you sign in, we use Sign in with Apple and store the unique identifier Apple assigns to your account, so a later sign-in finds the same account. We do not receive your name or email address. We check that sign-in proof, then delete it.
Progress
Until you sign in, your progress stays on your device. If you sign in, we store it with your account, so signing in on another phone restores it. Progress is the information the app needs to run the course. A typed answer stays on your device. The account stores whether it was right.
Dictation
Dictation needs the microphone and speech recognition. We do not receive the audio. If the iPhone cannot recognize the speech on the device, iOS may send it to Apple.
Purchases
If you subscribe, the full course is an App Store subscription, and we keep the transaction identifiers we need to know whether that course is unlocked. Payment and refunds are handled by Apple.
Usage statistics
You can share counts of what you do in the app, such as opening it, finishing a visit, and reaching the subscription screen. It stays off until you turn it on, and you can turn it off again in the app.
Saying yes or no is counted either way, including when you turn it off later. We keep each count for 90 days. The counts are not attached to your account, so they remain if you delete it. What you type is not included. Turning the setting off stops the other counts. The security logs below are kept either way.
Logs
We keep limited technical data to run the service and to prevent misuse. The legal basis for that is legitimate interest. The logs record each request and whether it succeeded. An IP address is kept only for as long as the hosting provider keeps it for security.
Retention
Progress on your device is deleted when you delete the app. If you have an account, that account and the progress stored with it are kept while the account exists, and deleting the account deletes them.
Your rights
You can ask for a copy of your personal data, including a copy in a portable form, and you can ask us to correct it or to restrict how it is used. You can object to the security logs. Deleting the app erases progress kept on your device. Deleting the account erases the data kept for the course. You can also complain to your supervisory authority.