Privacy Policy
Last updated: July 25, 2026
1. Who we are
Smisli is a language-learning app run by an individual, not a company. The controller of your personal data is Artem Nurmatov.
For any privacy question or to exercise the rights described in section 8, contact kernel.systems.ab@gmail.com. We answer within one month.
2. What we collect
Account data — your email address, a user ID, and which sign-in method you used (Google, Apple, or email and password). Provided when you create an account.
Learning content — the words and phrases you save, your notes, word lists, and any text you paste into the reader.
Learning progress — review history, scheduling data, streaks, daily goals, and your language and level settings.
Collection data — coins, shards, and the items you have unlocked. Coins are earned in-app only and cannot be purchased.
Subscription status — whether you have an active premium entitlement. Payments are handled by Apple or Google; we never see your card details.
Usage and crash data — only if you turn it on. See section 5.
Technical logs — when our servers handle a request, they may record an IP address and a timestamp for security purposes.
3. Why we use it, and on what legal basis
To provide the app — storing your cards, scheduling reviews, syncing across your devices, translating and pronouncing words, and running the collection feature. Legal basis: performance of our contract with you.
To keep the service secure and prevent abuse — rate limits, server logs, and administrative audit records. Legal basis: our legitimate interest in a working, non-abused service.
To improve the app — anonymous usage statistics and crash reports. Legal basis: your consent, which you can withdraw at any time in Settings.
To send daily reminders — only if you enable notifications. Legal basis: your consent.
4. Who processes data on our behalf
We do not sell your personal information and we do not share it for advertising. We do not use advertising SDKs. The following providers process data so the app can work:
• Google Firebase (United States) — accounts, sign-in, and cloud storage of your cards and progress.
• Google Firebase Analytics and Crashlytics (United States) — usage statistics and crash reports. Only active with your consent.
• RevenueCat (United States) — subscription status. Receives your user ID and store receipt, not your email.
• DeepL (Germany) — translations. Receives the text you ask to have translated: single words, definitions, example sentences, and the sentence around a word you tap while reading. During the beta we use DeepL’s free API tier, under which DeepL may use submitted text to improve its own translation service. Please do not paste sensitive or personal text into the reader.
• Microsoft Azure Speech (Ireland) — pronunciation audio. Receives the word to be spoken.
• OpenAI (United States) — generation of example sentences. Receives the word being studied. Not used to train their models.
• Our own API server, which serves the dictionary, the reading catalogue and the collection feature.
Apple and Google also act as independent controllers for purchases made through their stores, under their own privacy policies.
We may disclose data where required by law.
5. Usage statistics and crash reports
These are off until you switch them on, and you are asked before anything is collected. If you agree, we collect which screens you open, which features you use, your device type and operating system version, and technical details of any crash.
They never include the words you save, your notes, or the texts you read. They are never used for advertising and are never sold. You can turn this off at any time in Settings, and the identifiers held on your device are cleared when you do.
The app works identically whether this is on or off.
6. International transfers
Some of our providers are based in the United States. Where data leaves the European Economic Area, the transfer relies on the European Commission’s Standard Contractual Clauses, or on the provider’s certification under the EU-US Data Privacy Framework.
7. How long we keep it
Account and learning data — for as long as your account exists. When you delete your account we erase it within 30 days.
Usage and crash data — retained by our analytics provider for up to 14 months, and deleted sooner on request.
Server security logs — up to 12 months.
Records we must keep by law, such as tax records relating to a purchase, are retained for the period the law requires.
8. Your rights
Depending on where you live, you may have the right to access your data, correct it, delete it, receive a copy in a portable format, object to or restrict certain processing, and withdraw consent at any time.
Two of these work directly in the app: Settings › Export Data gives you a machine-readable copy, and Settings › Delete Account erases your account and its data. For anything else, write to us and we will act within one month.
If you are in the EEA or the UK you also have the right to complain to your national data protection authority.
9. California residents
We do not sell or share personal information as those terms are defined by the California Consumer Privacy Act, and we do not use it for cross-context behavioural advertising. You may request access to or deletion of your information using the contact address above, and we will not discriminate against you for doing so.
10. Children
Smisli is not intended for children under 13, or under 16 in countries where that is the applicable age for consent to online services. We do not knowingly collect data from children below those ages. If you believe a child has given us personal data, contact kernel.systems.ab@gmail.com and we will delete it.
11. Security
Data is transmitted over encrypted connections and stored on infrastructure with access controls that limit each account to its own data. No system is perfectly secure, but if a breach affects your personal data we will notify you and the relevant authority as required by law.
12. Changes
If we change this policy materially we will tell you in the app before the change takes effect, and ask you to review it.