The short version

• RomaTalk works offline. You don't create an account, and we don't know who you are.
• Your profiles, cards, photos, videos, recordings, schedules, practice results and diary stay on your device. We cannot see them.
• There are no ads, no analytics, no trackers and no crash reporting to third parties.
• The app does not send anything to our servers. The Android version does not even ask for internet access.
• Purchases are handled by Google Play or the App Store. We never see your payment details.
• If you write to us through our website or by email, we receive what you choose to send, and use it to review and respond to your request.
• Our website uses Google Analytics only if you agree to it in the cookie banner. The app itself has no analytics.

The details are below.

1. Who we are

RomaTalk is made by Serhii Lypii, a sole trader (eenmanszaak) registered in the Netherlands. He is the controller of the personal data described in this policy.

• Address: Juliana van Stolbergstraat 28, 4532 AZ Terneuzen, the Netherlands
• Chamber of Commerce (KvK): 99817039
• Email: serhii@lypii.nl
• Website: https://apps.lypii.nl/romatalk

2. What this policy covers

This policy covers:

• the RomaTalk app for Android, iPhone and iPad;
• the RomaTalk pages on apps.lypii.nl, including the support and feedback forms.

It does not cover Google Play, the App Store, your device's operating system or any other service you choose to use with RomaTalk, such as a cloud drive. Those have their own privacy policies.

3. How RomaTalk is built

• On your device. Everything you create in the app is stored in the app's private storage on your device.
• No account. We never create a profile of you.
• Only what is needed. The app asks for a permission only when you use the feature that needs it.
• No tracking. We don't track what you do in the app, where you are, or which other apps you use.

4. Data stored on your device

You enter this data yourself, and it never leaves your device unless you send it somewhere yourself (see section 5).

• Profiles: name, photo, colour, gender and age group (child, teen or adult). Gender and age group are used to choose fitting pictures and wording.
• Cards and categories: card words, photos, short videos and voice recordings, plus their order, favourites and hidden cards.
• Schedules, stories, choice sets and lesson plans that you make.
• Practice results: which cards were chosen and when, used for the statistics.
• Diary: the moments you or your child mark, and the notes you add. Feelings, tokens and "Hard moment" entries are stored in the same way.
• Usage counts: how often a card is used, for the "Recent" tab.
• Settings: language, voice, speech rate, theme, grid size and similar.
• Parent PIN: stored only as a salted SHA-256 hash in your device's secure storage (Keychain on iOS, Keystore on Android). Face ID or fingerprint unlocking is handled entirely by your operating system, and we never receive biometric data.

Home screen widgets. If you add a RomaTalk widget, the app copies what the widget shows (the current and next schedule step, or the cards of a visual choice) to storage that the widget can read on the same device. Anyone who can see your home screen can see the widget.

Deleting the app, or using "reset all data" in the app, removes all of this from your device.

5. When data leaves your device, and only because you choose it

• Backups. A backup is a file with your profiles, cards, photos and recordings. You can encrypt it with a password, and you choose where to save it. If you save it to a cloud service, that service's privacy policy applies.
• Sharing and PDFs. Shared card sets, printed cards and PDF reports (diary, practice, "Communication passport", "Summary for a specialist") go only where you send them, using your device's share or print menu.
• Links that open in your browser. Some buttons open a web page: support, feedback, the store page, or an email to us. The link may include the app version, the app language and the platform, so the page opens in the right language.
• The technical report. When you tap "Write to us" in Parents › About, the support page opens with a technical report attached in the part of the link after the "#" sign. Your browser does not send that part in the page request. The page fills the report field and removes the fragment from the address. If you switch languages, the report is passed to the new page within the same tab. You can review or clear it under Add technical report. It reaches us when you send the form, even if the section is closed. The report contains:
  • app and system versions, languages and theme;
  • how many profiles, cards and media files there are, and whether files are missing;
  • which voice language is selected;
  • a short log of app events. It does not contain names, card texts, photos, recordings or diary entries. You can read the full report in Parents › About › Technical report before you send anything.
• Store reviews. Now and then the app may ask Google Play or the App Store to show their own rating window. What you write there goes to the store, not to us.

6. What we do not collect

• your location;
• your contacts, calendar or list of apps;
• advertising identifiers (Advertising ID or IDFA);
• analytics or behaviour data;
• crash reports;
• the content of your cards, your photos, videos or recordings, or your child's name.

The RomaTalk app contains no ads and no third-party advertising, analytics or tracking code. For the website, see section 10a.

7. Purchases and donations

RomaTalk Pro is a one-time purchase, and donations are optional. Both are processed entirely by Google Play or the Apple App Store. They act as independent controllers for your payment data, and we never receive your card details. See the Google Privacy Policy and the Apple Privacy Policy.

The store confirms the purchase on your device. The app currently does not send your receipt to us.

The app contains an optional server check for purchases. It is switched off. If we ever switch it on, it will send only the platform, the product ID and the store receipt, never anything about you or your child, and we will update this policy and tell you in the app first.

8. Permissions

On Android the app does not request internet access.

9. Voice output

Card words are spoken by the text-to-speech engine on your device, or by your own recording if a card has one. Card texts are never sent to a cloud speech service by RomaTalk.

If a voice is missing, the app can open your system settings so you can install one. Your operating system downloads it, not RomaTalk. If you install a third-party speech engine, that engine's own privacy policy applies.

10. Our website and contacting us

When you use the support or feedback form on apps.lypii.nl, or email us, we receive what you choose to send:

• your message;
• your email address, which is required for Support and specialist Feedback and optional for other Feedback;
• any technical report included in the Support form;
• any additional information or attachments you choose to email us.

Why: we use it to review your request and respond. The legal basis is our legitimate interest in replying to you and fixing problems (Art. 6(1)(f) GDPR).

How it reaches us: forms are delivered to us by email through our hosting provider, Hostinger, which processes this data on our behalf. Like any web server, it may keep technical logs (such as IP addresses) for a short time for security.

How long we keep it: Support correspondence, including diagnostics and attachments, is deleted within six months of receipt. Contact messages and feedback are deleted within 30 days of receipt. To request earlier deletion, email serhii@lypii.nl. See the Website Privacy Policy.

10a. Cookies and analytics on our website

The app uses no cookies and no analytics. On the website, the selected page language is part of the address and the cookie choice is saved in browser storage. Google Analytics runs on public information pages only after you accept analytics. Analytics cookies can last up to 180 days. You can withdraw consent through Cookie settings. See the Website Privacy Policy for the current website policy.

11. Children

RomaTalk is meant to be set up and managed by a parent, guardian, teacher or specialist. We do not collect children's personal data. A child's name and photo are entered by an adult and stay on the device.

Settings and purchases sit behind the parent area, so a child cannot change them or buy anything by accident. There are no ads and no behavioural tracking.

We aim to meet the GDPR rules for children's data, the US Children's Online Privacy Protection Act (COPPA) and the Google Play Families Policy.

If you think we have received a child's personal data by mistake, for example in a support email, write to serhii@lypii.nl and we will delete it.

12. Sharing with others

We do not sell, rent or share your data. The only exceptions are:

• our hosting provider, which processes website messages on our behalf;
• Google, for website analytics, only if you consent (section 10a);
• cases where the law requires it.

Your cards, photos, recordings and your child's name never reach us, so we could not share them even if asked.

13. International transfers

Website messages are processed by Hostinger. If any of that processing happens outside the European Economic Area, it is covered by the EU Standard Contractual Clauses. Google Analytics data may be processed in the United States. Google is certified under the EU-US Data Privacy Framework, and the Standard Contractual Clauses apply as well. Data that stays on your device is never transferred.

14. How long data is kept

• On your device: until you delete it, reset the app or uninstall it.
• Messages you send us: support correspondence is deleted within six months of receipt; contact messages and feedback within 30 days (section 10).
• Website analytics: see section 10a and the Website Privacy Policy.

15. Your rights

Depending on where you live (for example, under the GDPR in the EU or the CCPA/CPRA in California), you have the right to:

• access your data and get a copy;
• correct it;
• delete it;
• restrict or object to processing;
• data portability;
• withdraw consent;
• complain to a data protection authority. In the Netherlands, that is the Autoriteit Persoonsgegevens.

Almost everything is on your device, so you can view, change, export (backup) and delete it yourself in the app. For messages you sent us, write to serhii@lypii.nl to make a request.

California residents: we do not sell or share personal information as defined by the CCPA/CPRA.

16. Legal bases (GDPR)

• Contract (Art. 6(1)(b)): providing the app and the features you bought.
• Legitimate interest (Art. 6(1)(f)): answering your messages, keeping the website secure and improving RomaTalk.
• Consent (Art. 6(1)(a)): camera, microphone, photos and Personal Voice access in the app, which you grant through your device's permission prompts and can withdraw in system settings; and Google Analytics cookies on the website, which you accept or refuse in the cookie banner.

17. Security

The app keeps data in its private storage on your device, stores the PIN only as a salted hash in secure system storage, and can encrypt backups with a password. The website uses HTTPS.

No system is perfectly secure. Please protect your device with a passcode, because its security is in your hands.

18. Changes

We may update this policy. The current version is always at https://apps.lypii.nl/romatalk/privacy with its date. If something important changes, we will tell you in the app.

19. Contact

Email serhii@lypii.nl, or use RomaTalk Support.

This policy is written in English.