Privacy Policy for DE Words

This Privacy Policy applies solely to the mobile application DE Words (referred to herein as "the App", "our application", or "DE Words"), having the Android package identifier com.nexso.de.wordtrainer.app, published and maintained by Nexso Labs ("we", "our", or "us").

DE Words is designed as an interactive German vocabulary learning and training tool. We believe in data minimization and transparency. We do not require users to create an account, register an email address, or provide personal identity details to access learning features. This document outlines the types of non-personally identifiable diagnostic, analytics, and advertising information that may be gathered automatically when using the App.

We categorize data into on-device user content and automatically collected technical information:

A. Information Stored Locally on Your Device

• Learning & Training Progress: Dictionary records, review schedules, sprint results, and study preferences are stored locally on your device utilizing an embedded SQLite database. This information is confidential to your device.
• Local App Preferences: Audio speed, selected UI themes, and learning goal settings.

B. Automatically Collected Technical Data

When you use the App, integrated industry-standard SDKs automatically collect certain technical diagnostic and telemetry data:

• Device Telemetry: Device manufacturer, model, operating system version (e.g., Android 14/15), system language, and screen resolution.
• Usage Analytics: Screen views, session duration, interaction with training modules, and feature engagement metrics (collected via Google Firebase Analytics).
• Crash Diagnostics: Stack traces, application crash logs, memory state, and CPU architecture at the time of an unexpected termination (collected via Firebase Crashlytics).
• Advertising Identifiers: Google Advertising ID (GAID), coarse IP-derived geographic location (country/city level), and ad interaction telemetry (collected via Google AdMob).

To maintain high operational stability, diagnose technical failures, and support development through advertisements, DE Words incorporates third-party Software Development Kits (SDKs) provided by Google LLC. Each third party operates under its own privacy terms:

In accordance with Google Play Store's Data Safety declaration requirements, the table below provides an exact breakdown of data types handled by the App:

Any information processed through the App is used strictly for the following purposes:

1. Ensuring Application Reliability: Identifying software defects, unhandled exceptions, and ANR (Application Not Responding) events across distinct Android OS builds.
2. Improving Educational Value: Understanding which training modes (such as Sprint, Anagram, Speaking, or Word Flashcards) are most beneficial to learners.
3. Serving Advertisements: Presenting non-intrusive ad placements to keep DE Words free of mandatory subscription fees.
4. Complying with Legal Obligations: Enforcing applicable legal guidelines, store policies, and protecting our legal rights.

We adhere strictly to Google Play policy regarding data retention and user deletion requests:

Retention Periods

• Crash Diagnostics (Firebase Crashlytics): Automatically retained by Google Firebase for up to 90 days, after which it is permanently purged.
• Analytics Data (Google Analytics): Aggregated pseudonymous event retention is configured in accordance with standard Firebase retention thresholds (up to 14 months).
• Local On-Device Data: Retained locally on your smartphone or tablet until you choose to uninstall the application or manually clear its app storage.

How to Delete Your Data

Because DE Words does not maintain user account registries on cloud servers, you maintain direct, total sovereignty over your data:

1. Clearing Local Data: You can instantly wipe all vocabulary training progress, history, and cached assets by navigating on your Android device to:
   Settings > Apps > DE Words > Storage & cache > Clear storage (or Clear data).
2. Uninstalling the App: Removing the app permanently erases the local SQLite database and all associated application files.
3. Diagnostic & Analytics Deletion Request: If you wish to request manual deletion of any pseudonymous analytics associated with your device instance ID, please email our privacy team at nexsolabs@ukr.net with the subject line "Data Deletion Request - DE Words". We will process your request in accordance with applicable legal requirements within 30 days.

The App is intended for general audiences aged 13 and older (or 16 and older where required by local regulations, such as in the European Union).

We do not knowingly collect, request, or solicit personally identifiable information from children under 13 years of age. If you are a parent or legal guardian and discover that your child under 13 has provided personal information or that diagnostic data has been unintentionally collected, please notify us immediately at nexsolabs@ukr.net. We will promptly delete such records from our systems and partner consoles.

Depending on your location, you may have specific rights regarding personal information under data protection laws:

For European Union & United Kingdom Residents (GDPR / UK GDPR)

• Right of Access: You may request information regarding the categories of personal data collected and processed.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of telemetry associated with your instance identifier.
• Right to Restrict or Object: You can object to processing or withdraw consent for personalized advertising at any time.
• Right to Lodge a Complaint: You have the right to contact your local Data Protection Authority if you believe our data processing violates statutory regulations.

For California Residents (CCPA / CPRA)

Under the California Consumer Privacy Act:

• We do not sell personal information for monetary consideration.
• We do not share sensitive personal information.
• You have the right to request disclosure or deletion of any collected commercial telemetry.
• You are entitled to non-discriminatory treatment when exercising your privacy rights.

Google Android allows you to control how advertising networks use your Advertising ID:

• Reset Your Advertising ID: On Android 12 or newer, open Settings > Google > Ads > Reset advertising ID. This disconnects past ad interactions from your new identifier.
• Delete Your Advertising ID: On Android 12 or newer, open Settings > Google > Ads > Delete advertising ID. Subsequent ads served will be generic and non-personalized.
• Web & App Activity Controls: Manage your global Google advertising settings at Google My Ad Center.

The security of diagnostic data and user safety is paramount. All network communications originating from third-party SDKs (Google Firebase, Google AdMob) utilize modern cryptographic Transport Layer Security (TLS 1.2 / TLS 1.3 / HTTPS). Local storage on your Android device is sandboxed within the application’s isolated directory structure, prevented by operating system controls from unauthorized inspection by other non-privileged third-party apps.

We reserve the right to revise or update this Privacy Policy periodically to reflect changes in legal statutes, store regulations, or updates to application architecture. When modifications occur, the updated policy will be posted on this URL with an updated "Effective Date". We encourage you to review this page periodically. Continued usage of DE Words after modifications implies acceptance of the revised policy.

If you have questions, inquiries, feedback, or requests regarding this Privacy Policy or your data, please contact our engineering and compliance team: