Privacy Policy for Mera

1. Who We Are

Responsible Party (Data Controller)

Bianca Scholze
Petalbe Technologies
Roßmarktstraße 37
04177 Leipzig
Germany

E-Mail: [email protected]
Website: tech.petalbe.com

The responsible party is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

About Mera: Mera is a Hindi vocabulary learning app for iOS that helps you build conversational Hindi skills through personalized exercises and spaced repetition.

2. Data We Collect

2.1 Vocabulary Data

When you use Mera, the following data is stored locally on your device:

• Vocabulary Items: Hindi words, English translations, parts of speech, categories, example sentences, and notes that you add or upload
• Learning Progress: Your mastery level, correct/incorrect answer counts, review dates, and spaced repetition schedules for each vocabulary item
• Exercise Statistics: Exercise completion data, scores, accuracy rates, and time spent practicing
• User Preferences: Daily goals, notification settings, and app configuration choices
• Learning Analytics: Your daily study streaks, time spent per session, words learned per day/week, and goal completion rates are stored locally and used to display your progress statistics

Storage Location: All this data is stored locally using Apple's Core Data framework on your device. If you enable iCloud sync, this data is automatically synchronized across your Apple devices via CloudKit.

2.2 Apple ID Information

Mera uses your Apple ID for iCloud sync functionality. We do not collect or store your Apple ID credentials. Apple handles all authentication securely.

2.3 What We Don't Collect

We explicitly do not collect:

• Personal identification information (name, email, phone number) beyond your Apple ID for sync
• Location data or GPS coordinates
• Device identifiers for advertising purposes
• Browsing history or activity outside the app
• Contacts, photos, or other sensitive device data
• Payment information (handled entirely by Apple)

3. How We Use Your Data

3.1 Purpose of Data Processing

Your vocabulary and learning data is used exclusively to:

• Personalize Your Learning: Track which words you've mastered, which need review, and optimize spaced repetition schedules
• Generate Exercises: Create personalized flashcards, quizzes, and practice sessions based on your learning history
• Display Progress: Show your learning statistics, streaks, mastery levels, and achievements
• Sync Across Devices: Keep your vocabulary and progress synchronized across all your Apple devices via iCloud

3.2 Local Processing

All vocabulary processing, exercise generation, and progress calculations happen entirely on your device. When you upload CSV files with vocabulary, they are parsed locally without sending data to external servers.

4. Data Storage and Security

4.1 Core Data and CloudKit

Mera uses Apple's Core Data framework for local storage and CloudKit for optional iCloud synchronization. Both are industry-standard technologies with built-in encryption and security measures.

• Local Storage: Data is stored in an encrypted SQLite database managed by Core Data
• iCloud Sync: When enabled, data syncs via CloudKit using end-to-end encryption
• Access Control: Only you can access your data through your Apple ID. We (Petalbe Technologies) cannot access your iCloud data

4.2 Data Retention

Your data remains on your device and in your iCloud account until you choose to delete it. We do not have access to delete your data on our behalf.

5. Third-Party Services

5.1 Apple Services

Mera relies on Apple's infrastructure:

• Apple ID: For user authentication and iCloud sync (Apple's Privacy Policy applies)
• CloudKit: For cross-device data synchronization (covered by Apple's iCloud Terms)
• TestFlight: For beta testing, which collects anonymized crash reports and usage analytics handled by Apple
• App Store: For app distribution and in-app purchases (Apple's standard terms apply)

Apple's Privacy Policy: https://www.apple.com/legal/privacy/

5.2 Limited Analytics Usage

Mera uses anonymized analytics only for improving app functionality. We do not use:

• Advertising networks or user tracking for marketing purposes
• Social media integration that shares your data
• Analytics data for advertising or selling to third parties

For information about our analytics usage, see Section 6 below.

6. Analytics and Usage Data

6.1 TelemetryDeck

To understand how users interact with Mera and improve the app experience, we use TelemetryDeck, a privacy-friendly analytics service provided by TelemetryDeck GmbH, Von-der-Tann-Str. 54, 86159 Augsburg, Germany.

6.2 Purpose of Analytics

We use TelemetryDeck to understand general app usage patterns and app stability. This helps us prioritize improvements and fix issues that affect the user experience.

6.3 Data Collected

TelemetryDeck processes the following data:

• An anonymized, untraceable user identifier (per app installation — cannot be tied to your identity)
• A rounded timestamp (to the nearest hour)
• Device metadata: iOS version, app version, and device type

The TelemetryDeck SDK is fully open source: github.com/TelemetryDeck. Further details on data processing: telemetrydeck.com/privacy.

6.4 Legal Basis

The use of TelemetryDeck is based on our legitimate interest in understanding how Mera is used in order to improve the app (Art. 6(1)(f) GDPR). The data collected is fully anonymized and cannot be linked to any individual.

6.5 No Opt-Out Required

Because TelemetryDeck collects only anonymized, non-personal data, no consent or opt-out mechanism is legally required under GDPR. Nevertheless, if you prefer not to share any usage data, you can disable analytics in Mera's Settings under Privacy.

6.6 No Advertising Use

We do not use analytics data for advertising purposes and do not share it with advertising networks. The data is used solely to understand app usage and improve features.

7. Your Privacy Rights

7.1 Access and Control

You have complete control over your data:

• View Your Data: All your vocabulary and progress is visible within the app's Library and Statistics sections
• Edit Your Data: You can edit or delete individual vocabulary items at any time
• Export Your Data: You can export your vocabulary data in standard formats (future feature)
• Delete All Data: Delete the app to remove all local data. For iCloud data, manage it through your Apple ID settings
• Control Analytics: Toggle "Share Anonymous Analytics" in app Settings to opt out of Firebase Analytics

7.2 iCloud Data Management

To manage your iCloud data:

• Go to iPhone Settings → [Your Name] → iCloud → Manage Storage → Mera
• You can disable iCloud sync or delete iCloud data from here
• Deleting iCloud data will not affect local data stored on your device

7.3 Right to Be Forgotten

Since we do not collect personal data on our servers, simply deleting the app removes all local data. For iCloud data, use Apple's iCloud management tools as described above. Firebase Analytics data is anonymized and automatically deleted after 14 months.

8. Children's Privacy

Mera is suitable for users of all ages, including children under 13. However, we do not knowingly collect personal information from children. Since all data is stored locally and synced via Apple's infrastructure, parents should review Apple's Family Sharing and parental controls for managing children's app usage.

If a parent or guardian believes their child has provided data to Mera in a manner inconsistent with this policy, please contact us at [email protected].

9. International Data Transfers

Mera processes all data locally on your device. If you enable iCloud sync, your data is stored in Apple's iCloud infrastructure, which may involve international data transfers according to Apple's policies. Apple complies with applicable data protection laws including GDPR for European users.

Analytics data processed via TelemetryDeck is handled by TelemetryDeck GmbH, based in Augsburg, Germany. Data is stored and processed within the EU and is not transferred to third countries.

For more information:

• Apple's privacy practices: https://www.apple.com/legal/privacy/

10. Data Breach Notification

Since we do not collect or store your data on our servers, the risk of a data breach affecting your Mera data is minimal. Your data security depends on:

• Your device's security (passcode, Face ID, Touch ID)
• Your Apple ID security (two-factor authentication recommended)
• Apple's iCloud security infrastructure

If Apple or Google notifies us of any security incident affecting Mera users, we will promptly inform affected users according to applicable legal requirements.

11. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process your data based on:

• Contractual Necessity (Art. 6(1)(b) GDPR): Processing vocabulary and progress data is essential to provide the app's core learning functionality
• Legitimate Interest (Art. 6(1)(f) GDPR): Storing user preferences and settings to improve user experience, and processing anonymized analytics data via TelemetryDeck to improve app functionality, stability, and user experience
• Consent (Art. 6(1)(a) GDPR): Where applicable, such as enabling optional iCloud sync features or sharing analytics data (which you can opt out of at any time)

12. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make significant changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you through the app (for material changes)
• Request your consent if required by applicable law

We encourage you to review this policy periodically. Continued use of Mera after changes constitutes acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this privacy policy or your data, please contact us:

Email: [email protected]
Company: Petalbe Technologies
Website: https://tech.petalbe.com

We will respond to your inquiry within 30 days.

14. Supervisory Authority

If you are located in the EEA, UK, or Switzerland and believe we have not addressed your privacy concerns adequately, you have the right to lodge a complaint with your local data protection authority:

• Germany: Contact your state's data protection authority (Landesdatenschutzbehörde) or the Federal Commissioner for Data Protection and Freedom of Information (BfDI)
• EU/EEA: Find your national authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en
• UK: Information Commissioner's Office (ICO) at https://ico.org.uk