Privacy Policy

1. Controller

The data controller for the Lingrrotly mobile application is:

Tomasz Kisiel Software
NIP: 7941843728
REGON: 543020166
Country of establishment: Poland
Contact: hello@wigwik.tech

2. Scope

This Privacy Policy applies to the Lingrrotly mobile application ("App") available on the Apple App Store. It describes what data we collect, why we collect it, how we process it, and your rights under applicable law, including the General Data Protection Regulation (GDPR).

3. Age Requirements

The App is rated 12+ on the App Store. In certain countries, the minimum age may be 13+ or 14+ in accordance with local law. We do not knowingly collect data from children below the applicable minimum age in their country. In the United States, we comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided personal data through the App, please contact us at hello@wigwik.tech and we will delete it promptly.

4. Data We Collect and Why

4.1 Usage and Performance Data

We automatically collect anonymised usage data and performance metrics to understand how the App is used, diagnose technical issues, and improve the user experience. This includes:

• App interactions and feature usage patterns
• Crash reports and error logs
• Device type, operating system version, and app version
• IP address (used for geolocation at country level and then discarded)
• Device identifiers (e.g. installation ID assigned by the analytics SDK)

We process this data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) in maintaining and improving the App.

4.2 Optional Feedback

If you choose to submit feedback through the in-app feedback form, you may optionally provide your name and email address. This data is used solely to respond to your feedback. Providing this information is entirely voluntary.

We process this data on the basis of your consent (Art. 6(1)(a) GDPR). You may withdraw consent at any time by contacting us at hello@wigwik.tech. Upon withdrawal, your name and email address will be deleted.

5. Data We Do Not Collect

• We do not require you to create an account.
• We do not collect or store passwords or authentication credentials.
• We do not sell your personal data to third parties.
• We do not use automated decision-making or profiling.

6. Subprocessors

We use the following third-party service providers (subprocessors) to deliver the App. Each operates under a Data Processing Agreement (DPA) and processes data only as instructed by us.

7. International Data Transfers

Sentry and PostHog are incorporated in the United States. Although your data is stored in EU data centres, US-based staff of these companies may access it in the course of providing their services, which constitutes an international transfer under GDPR. We ensure appropriate safeguards are in place for such transfers, including Standard Contractual Clauses (SCCs) approved by the European Commission.

8. App Content Sources

The App uses linguistic data from Tatoeba and visual assets from Pexels to display content within the App. These services are used solely as content sources. No user data is shared with Tatoeba or Pexels at runtime.

9. Apple App Store

The App is distributed through the Apple App Store. Apple Inc. operates the App Store as a separate and independent data controller. Data collected by Apple in connection with your use of the App Store is governed by Apple's Privacy Policy, available at https://www.apple.com/legal/privacy.

10. Third-Party Links

The App may contain links to external websites or resources (such as regulatory authority websites). We are not responsible for the privacy practices or content of those external sites. We encourage you to review the privacy policies of any third-party sites you visit.

11. Advertising

We do not currently display advertisements in the App. We may introduce advertising in future versions. If and when we do, this Privacy Policy will be updated before any advertising-related data processing begins, and you will be informed through the App or App Store release notes.

12. Data Retention

13. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of access — You may request a copy of the personal data we hold about you.
• Right to rectification — You may request correction of inaccurate or incomplete data.
• Right to erasure — You may request deletion of your personal data where there is no legitimate reason for us to continue processing it.
• Right to restriction — You may request that we restrict the processing of your personal data in certain circumstances.
• Right to data portability — Where processing is based on your consent, you may request to receive that data in a structured, machine-readable format.
• Right to object — You may object to processing based on legitimate interest, including the collection of usage and performance data described in Section 4.1.
• Right to withdraw consent — Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at hello@wigwik.tech. We will respond within 30 days.

14. Complaints

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with a supervisory authority. As we are established in Poland, our lead supervisory authority is:

Urząd Ochrony Danych Osobowych (UODO)
ul. Stawki 2, 00-193 Warsaw
https://uodo.gov.pl

You may also contact the data protection authority in your country of residence or habitual place of work.

15. Security

We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. Our subprocessors are selected with security and data protection in mind. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

16. Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such change and ensure that your data continues to be protected in accordance with this Privacy Policy.

17. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. The updated version will be published at this address. For significant changes we will notify you through the App or App Store release notes, and where required by law we will seek your renewed consent before the changes take effect.

18. Contact

For any questions or requests related to this Privacy Policy, contact us at:

hello@wigwik.tech