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Privacy policy

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In short

What Nalo knows about you: only what you type in and scan. It stays with you and your family.

  • No account, no ads, no analytics, no tracking
  • No sharing with third parties
  • Your words, tests and progress live on your device and, if you use it, in your family's iCloud
  • We never get to see photos of book pages. They live in the app and, if you use iCloud, in your family's iCloud

This is a translation for your convenience. The German version is the legally binding one.

  • If you report a problem with a page, you send only the words concerned and technical details, never a photo

Controller

Adrian Kühlewind
Hauptstraße 3/2
73271 Holzmaden
Germany
E-mail: [email protected]

Questions about privacy go to this address too.

Data on the device

Nalo stores on your device what you create yourself: words and meanings, tests and dates, your progress and your rounds, the name you give yourself (a nickname is enough), and photos of the scanned book pages. Text recognition and the check against the dictionary run on the device. None of it is transmitted to us, unless you report a problem with a page (see below).

iCloud and sharing in the family

If your device is connected to iCloud, Nalo syncs your data through iCloud (CloudKit) and, if you wish, shares it with your parents. The provider is Apple; the data lives in your family's iCloud accounts. We have no access to it. Apple's privacy policy applies.

The legal basis is the performance of the function you requested (Art. 6(1)(b) GDPR).

Camera and Apple Intelligence

The camera is used only to scan a book page, when you open it. Recognising the words runs on the device, even when Apple Intelligence helps. Photos stay in the app and in your iCloud. When Nalo checks whether your answer fits, Apple Intelligence helps on the device as well. Nothing goes to the internet.

Reporting a problem with a page

Only when you tap “Report a problem with this page” in the app and then “Send” does Nalo send us a report. It contains the words on that page that were orange, or that you corrected, removed or added yourself, each as Nalo read it and as you left it. It also contains technical details: where the lines sit on the page, image size, brightness, sharpness, device model, iOS and app version, the language pair, and your choice and any text you add. Never sent are the photo, any part of it, other text on the page, example sentences, the page's name, names, account or device identifiers, or your location. A report cannot be linked to any person or device. We use it only to improve how Nalo reads book pages. The report is stored by Cloudflare (storage in the EU) and deleted after 90 days. On your device Nalo keeps the details of a scanned page for 30 days so you can still report it later. They are not shared through iCloud.

Notifications

Nalo schedules practice reminders on the device; the hints for parents are created on the parents' device. There are no push notifications from a server.

Requests to naloapp.de

For legal texts Nalo asks the naloapp.de server. Dictionaries and pictures Nalo downloads from packs.naloapp.de when you need them. Both are delivered by Cloudflare, Inc. (Cloudflare Pages and Cloudflare R2). Cloudflare processes technically necessary connection data such as your device's IP address and the time of the request; we ourselves store no access logs. This data is linked with nothing. Cloudflare may also process data in the USA; Cloudflare is certified under the EU-US Data Privacy Framework. The legal basis is our legitimate interest in secure operation (Art. 6(1)(f) GDPR). Cloudflare's privacy policy applies.

If you write to us

If you write to [email protected], we use your e-mail address and your message only to answer you, and delete them once the matter is settled. The legal basis is our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR).

Sharing tests

When you share a test as a link or a file, the content is in the link itself or in the file. None of it is uploaded to a server: a link on link.naloapp.de carries the test after the #, and that part never reaches the web server. You decide whom you share the link or the file with. You are responsible for the content yourself, see the terms of use.

Children

Nalo is made for school children. We receive no data from you, so there is nothing you need to confirm. Your parents see your progress only if you connect Nalo with each other.

Beta through TestFlight

If you use Nalo as a beta through Apple's TestFlight, TestFlight's terms apply as well. TestFlight is provided by Apple. Through TestFlight we receive crash reports, feedback and screenshots you send yourself, and details about the use of the beta such as device, platform, app version and the number of sessions and crashes. If you joined through the public link, we see neither your name nor your email address; if we invite you by email, we see both. We use this information only to find bugs and improve Nalo. The legal basis is our legitimate interest in an app without errors (Art. 6(1)(f) GDPR). Apple's privacy policy applies.

Your rights

You have the right to access, rectification, erasure and restriction of processing as well as to data portability, and you may lodge a complaint with a data protection supervisory authority. Because your data lives only with you, you delete it by deleting the app or by removing the data in your device's iCloud settings.

Privacy on naloapp.de

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This website

naloapp.de is a static website without an account, without cookies, without analytics and without tracking. No fonts, scripts or images are loaded from other providers.

The website is delivered by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA (Cloudflare Pages). When you visit, Cloudflare processes technically necessary connection data such as your device's IP address, the time of the request and the page requested, in order to deliver the page and protect it from attacks. We ourselves store no access logs. The legal basis is our legitimate interest in secure operation (Art. 6(1)(f) GDPR). Cloudflare's privacy policy applies.

The same applies to link.naloapp.de: shared tests and invitations land there when Nalo is not installed on the device.

What applies to shared test links and to the app's requests is described above under “Sharing tests” and “Requests to naloapp.de”.

This is a translation for your convenience. The German version is the legally binding one.

Contact and rights

The controller is Adrian Kühlewind, Hauptstraße 3/2, 73271 Holzmaden, Germany, [email protected]. You have the right to access, rectification, erasure and restriction of processing, and the right to lodge a complaint with a data protection supervisory authority.