Privacy Policy

This Privacy Policy applies to the Meloji mobile application (the “Application”), developed and operated by Halina Puhach, acting as an individual (the “Service Provider”, “Data Controller”).
Country of residence: Germany, European Union.
The Application is provided as a Freemium service and is offered “AS IS”.

1. Data Controller

For the purposes of the General Data Protection Regulation (GDPR), the Data Controller is:

2. What personal data does the Application collect?

2.1 Information you provide directly

When you register and use the Application, we collect the following personal data:

• Email address
  • used for account-related communication
  • used for important service notifications (such as changes to this Privacy Policy or security-related notices)
  • not used as a unique user identifier within the Application
• User-generated content, including:
  • flashcards created by the user
  • images uploaded by the user into flashcards

No real name or additional identifying information is required.

2.2 Voice input during quizzes

Some quizzes require access to the device microphone. Microphone access requires your explicit consent via iOS system permissions and an in-app prompt before first use.

• Live audio input is used exclusively for speech recognition and pronunciation assessment
• Voice input is not stored, not recorded, and not retained by the Service Provider
• Live audio is temporarily transmitted to Microsoft Azure Cloud for real-time processing and is deleted immediately after processing

2.3 Automatically collected information (security purposes only)

For security, fraud prevention, and abuse protection, the Application automatically collects:

• internal user ID
• device ID
• IP address
• operating system information

This data is:

• not used for advertising
• not used for analytics or profiling
• not shared for marketing purposes

Legal basis: legitimate interest (Article 6(1)(f) GDPR).

2.4 Location data

The Application does not collect precise real-time location data.

3. Legal bases for processing personal data

a) Performance of a contract (Article 6(1)(b))

• account creation and management
• access to flashcards and learning features
• storage of user-generated content

b) Consent (Article 6(1)(a))

• microphone access
• speech recognition and pronunciation assessment
• AI-powered features such as pronunciation generation and intelligent flashcard import

Consent can be withdrawn at any time through device settings.

c) Legitimate interest (Article 6(1)(f))

• ensuring application security
• preventing fraud and misuse
• protecting user accounts and infrastructure

4. Hosting, Artificial Intelligence, and cloud services

4.1 Hosting

The hosting infrastructure used for the Application is located within the European Union.

4.2 Artificial Intelligence and translation services

The Application uses Microsoft Azure Cloud exclusively for AI-related functions, including:

• speech recognition and pronunciation assessment
• pronunciation generation
• intelligent AI-powered flashcard import
• translation services

Important safeguards:

• Azure services are used only as data processors
• No voice recordings or imported files are stored after processing
• Azure cloud resources used by the Application are located within the European Union

The Application does not use AI for profiling, advertising, or automated decision-making with legal or similarly significant effects.

5. Sharing data with third parties

Personal data is shared only when necessary and only with trusted data processors:

• Cloud hosting provider (data is processed within the European Union)
• AI and speech recognition provider: Microsoft Azure Cloud
• Payment processor: Apple (App Store)

All third parties:

• process data only on documented instructions
• are bound by GDPR-compliant data processing agreements
• do not use data for their own independent purposes

6. Payment data

Subscription payments are processed exclusively by Apple.

• The Service Provider does not collect or store payment card details
• Apple acts as an independent data controller for payment-related data
• Payment data is handled according to Apple’s own privacy policies

7. Data retention and deletion

7.1 Retention

• Account data (email, user-generated content): stored while the account remains active
• Security-related technical data: stored only as long as necessary for security purposes

7.2 Account deletion

You may delete your account at any time using the Account Deletion feature in the Application.

Upon deletion:

• your email address is deleted
• your flashcards and uploaded images are deleted
• no voice data is retained
• payment-related data remains under Apple’s control

8. Uninstalling the Application

Uninstalling the Application does not automatically delete your personal data. To fully erase your data, you must delete your account from within the Application.

9. Children’s privacy

The Application is not intended for children under 16 years of age, or under the minimum legal age required to consent to data processing in their country.

The Service Provider does not knowingly collect personal data from children below this age. If you believe a child has provided personal data, please contact us immediately.

10. Data security

Appropriate technical and organizational measures are used to protect personal data, including:

• access control
• secure hosting infrastructure
• contractual safeguards with service providers

Despite these measures, no system can guarantee absolute security.

11. Changes to this Privacy Policy

This Privacy Policy may be updated from time to time.

• Minor updates will be reflected by updating this page
• Material changes will be communicated via the Application or by email

Continued use of the Application means you acknowledge the updated Privacy Policy.

Effective date: 2026-02-02

12. Your rights under GDPR

You have the right to:

• access your personal data
• rectify inaccurate data
• request erasure of your data
• restrict or object to processing
• data portability
• lodge a complaint with an EU supervisory authority

You may exercise these rights by contacting the Service Provider.

13. Contact

For any privacy-related questions, please contact:
help.meloji.app@gmail.com