Privacy

Last updated: 28 October 2026

1. Summary in plain words

• You can study without an account. Then your progress stays in your browser on your device.
• With an account, your learning progress is also stored with our cloud database provider so you can use it on several devices.
• AI features send the text you ask about to Google's AI service. Do not put personal data into AI requests.
• We do not sell your data and do not show advertising.
• Optional usage statistics are only collected if you agree, and you can say no.
• You can export your learning data at any time and ask us to delete your account.

2. Who is responsible (controller)

Viafacta – Wortwabe, Youssef Ibrahim, postal address on request via [email protected], Egypt. Email: [email protected]

3. What data we process, why, and on what legal basis

3.1 Visiting the website (all visitors)

• Technical connection data: IP address, time, requested page, browser type, operating system, referrer. Processed by our hosting and network provider Cloudflare to deliver the website, protect it from attacks and keep it stable. Purpose: delivery and security. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
• Security and abuse limits: to prevent abuse of AI and login features, we compute short-lived, daily hashed values from account ID, IP address, a session value and the browser's user agent, together with counters. They do not contain your raw IP address. Legal basis: legitimate interest in security and fair use.

3.2 Studying as a guest

• Your learning progress (cards, review history, XP, streak, reading progress, your own words, texts you write, drafts, generated texts, settings) is stored only in your browser (IndexedDB and localStorage) on your device.
• We do not receive guest progress unless you use a feature that sends data (for example AI feedback or an issue report).
• Legal basis: performance of the service you request (Art. 6(1)(b) GDPR) and, where storage on your device needs consent, § 25(2) of the German TTDSG/TDDDG exemption for technically necessary storage.

3.3 Account

• Account data: email address, password (sent to our authentication provider, never stored by us in readable form), account ID, optional display name, second-factor (TOTP) enrolment status. With Google sign-in: your Google account identifier, name and email as provided by Google.
• Session data: a login session stored in your browser; with Google sign-in also a secure, HttpOnly cookie.
• Synchronised learning progress: a copy of your learning profile (as in 3.2, including texts you wrote) is stored in our cloud database so it can be used on several devices.
• Roles and badges (only if relevant): a hashed email value, a masked email hint, role and badges, and an audit log of role changes.
• Purpose: providing the account and synchronisation. Legal basis: contract (Art. 6(1)(b) GDPR); security of accounts: legitimate interest (Art. 6(1)(f)).

3.4 AI features

• When you use AI features (generated texts, example sentences, writing feedback), we send the task instructions and the relevant input (for example your text, target words, level) through our server to Google Gemini.
• If you use an advanced mode with your own AI key, your browser may send requests directly to Google under your key.
• Do not include personal data, secrets or confidential information in AI requests.
• Purpose: providing the AI feature you request. Legal basis: contract (Art. 6(1)(b)).
• Google may process this data under its own terms; retention by Google is.

3.5 Audio and speech

• Word audio prepared by us is a static file loaded from our website; no personal data is sent beyond normal connection data.
• Cloud speech for your own words: when you play audio for a word you added yourself, the German text is sent through our server to a Google text-to-speech endpoint.
• Speech exercises use your browser's speech recognition. Your browser or operating system vendor (for example Google, Apple, Microsoft) may process your voice on its servers under its own terms. We do not receive or store your recordings. The microphone is only used after you allow it in the browser.

3.6 Issue reports

• If you send an issue report, we store the text, category, language, app version, time and, if signed in, your account ID. Reports are stored in a private storage at Cloudflare and reviewed by authorised team members. Optional email alerts to the owner contain only a reference, not your report text.
• Do not put personal data or passwords into reports.
• Legal basis: legitimate interest in fixing errors (Art. 6(1)(f)); for rewards (badges, bonus freezes): contract.

3.7 Update emails (optional)

• If you subscribe to release emails, we process your email address and the confirmation status. Subscription uses double opt-in (you confirm through a link). Emails are sent by Resend (sending region EU/Ireland). You can unsubscribe at any time through the link in each email.
• Legal basis: consent (Art. 6(1)(a)).

3.8 Optional usage statistics and error reports

• We ask for your consent first. Without consent, the app sends no usage or error events.
• With consent, the app sends screen views, lesson start/finish, streak and celebration events, drop-off events and sanitised error reports together with screen, language, device class (mobile/desktop), browser family and app version. A daily pseudonymous ID is formed from your account ID or a random cookie (`ww_analytics`, up to 30 days).
• Recipients: Cloudflare (aggregated counts); where activated, PostHog (usage events, IP explicitly not sent) and Sentry (error reports, IP explicitly not sent).
• Legal basis: consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). You can withdraw consent at any time in the app settings; this does not affect processing before withdrawal.

The host necessarily receives your IP address; the diagnostics service hashes it. Identifiers are pseudonymous, not anonymous. Disabling stops future events without deleting earlier records. Actual onward-provider activation and exact retention are not yet confirmed.

3.9 Support emails

When you write to [email protected] we process your email address and message to answer you. Legal basis: legitimate interest / pre-contractual and contractual communication.

3.10 External video

YouTube connects only when you press the load-video button. Google receives network information including your IP address and may use cookies or other storage. This is separate from optional diagnostics consent. See https://policies.google.com/privacy. Diagnostics withdrawal does not withdraw a video load you separately request.

4. Providers (processors and recipients)

We have or will conclude data processing agreements where required. Some providers are in the USA; transfers rely on the EU–US Data Privacy Framework and/or Standard Contractual Clauses where applicable.

5. Storage on your device

Wortwabe stores data in your browser so it works offline and remembers your progress:

• IndexedDB database `wortschatz-werkstatt` (learning profile, backups, conflict copies, your own audio files);
• localStorage keys such as `ww-session`, `ww-deployment`, `ww-telemetry-consent`, `ww_guest`, `ww_first_entry`, theme and language choice;
• sessionStorage for temporary values (for example navigation state, an advanced-mode AI key you enter for one session);
• a service worker and caches (`ww-offline-*`) so the app works offline.

These are technically necessary for the features you use, except the statistics consent choice and the statistics cookie described in 3.8. The cookie page lists details: wortwabe.com/en/storage/.

6. How long we keep data

• Guest data: in your browser until you delete it.
• Issue reports, security records, diagnostics and support emails: exact retention periods and provider backup expiry are not yet confirmed. There is no general automatic expiry for diagnostics records. Contact [email protected] for information or a deletion request.
• Update subscription: until you unsubscribe.
• The pseudonymous diagnostics cookie can last up to 30 days; cookie expiry does not delete earlier server records.

7. Your rights

Under the GDPR (and similar rights under Egyptian law) you have the right to:

• access the data we hold about you (Art. 15);
• correct wrong data (Art. 16);
• have data deleted (Art. 17);
• restrict processing (Art. 18);
• receive your data in a portable format (Art. 20) — the export in Settings gives you your learning data as JSON;
• object to processing based on legitimate interest (Art. 21);
• withdraw consent at any time (Art. 7(3));
• complain to a data protection supervisory authority, for example the authority in your EU country of residence.

To use your rights, write to [email protected] from the email address of your account. We may need to verify your identity. We answer within the legal deadlines (generally one month).

Account deletion: In Settings → Account, choose Delete account where available. You can export first and choose to keep a local learning copy. If unavailable, contact [email protected] from your account email. Clearing browser data alone does not delete your account. Separate diagnostic, security and provider records may remain under their retention rules; this does not promise deletion of every record.

8. Children

Wortwabe is not directed at children under 16. Children under 16 may only use it with the consent of a parent or guardian. If you believe a child gave us personal data without consent, contact us and we will delete it.

9. Security

We use encryption in transit (HTTPS), row-level access rules in the database so each account only reaches its own progress, second-factor authentication for accounts, rate limits, sanitised error reports and restricted owner access. No system is completely secure; we cannot guarantee absolute security. If a data breach affects you, we inform you as required by law.

10. No automated decisions, no selling, no advertising

We do not make decisions with legal or similarly significant effects about you based solely on automated processing. The learning scheduler (FSRS) only decides when a card is shown again. We do not sell personal data and do not use it for advertising or ad profiling.

11. Changes

We update this policy when the service or the law changes. The date at the top shows the current version. For important changes we inform account holders in the app or by email where possible.

12. Contact

Viafacta – Wortwabe · Youssef Ibrahim · Egypt · [email protected]