Who we are (data controller)
Mustafa Baykal (Individual Developer), jurisdiction: Republic of Türkiye.
For all privacy-related questions: mustafabaykal91@gmail.com
What we collect
- Nothing personal. Fluexo Swipe does not require an account or collect identifying information about you.
Third-party services we use
- RevenueCat (subscription receipt validation — keyed to an anonymous app-user id, no personal data)
- Apple StoreKit (in-app purchase processing)
Data processors and international transfers
We use the following processors. All have signed Data Processing Agreements (DPAs); transfers to the United States are additionally protected by Standard Contractual Clauses (SCCs) per GDPR Articles 44–49 (post-Schrems II).
| Processor | Purpose | Location | DPA | SCC |
|---|---|---|---|---|
| RevenueCat, Inc. | Validates your App Store subscription receipt and manages your premium entitlement. Keyed to an anonymous, randomly-generated app-user id — never your name, email, or Apple ID | USA | ✓ | ✓ |
| Apple, Inc. | App Store distribution and in-app purchase processing (StoreKit). Apple handles all payment data; we never see your card, billing details, or Apple ID | Global | ✓ | N/A |
Data retention
We keep data only as long as necessary for the purpose collected, or as required by law (GDPR Art. 5(1)(e); KVKK Art. 7).
| Data type | Retention period | Reason |
|---|---|---|
| Local learning progress (words seen/known, weak words, mastery, streak, hearts, XP, favorites, settings, chosen course & app language) | until-you-uninstall | Stored only on your device (local storage). Deleting the app erases it completely. It never leaves your phone and we never receive it |
| Anonymous subscription entitlement (via Apple + RevenueCat) | 7-years | Subscription receipts are retained for tax/accounting records required by Turkish tax law (Vergi Usul Kanunu), keyed to an anonymous id |
No account, no sign-up, nothing personal
Fluexo Swipe has no login. You do not create an account, and you never give us an email, a name, a phone number, or any personal information to learn. Everything you do — the words you swipe, your quiz answers, your weak words, your streak, hearts, XP, favorites, your settings and your chosen languages — is saved only on your own device. It never leaves your phone and we never see it.
What we do NOT collect
We do not collect or use: your name, email, precise or coarse location, contacts, photos, microphone, camera, health/fitness data, calendar, browsing history, the advertising identifier (IDFA), or any biometric data. Fluexo Swipe contains zero advertising SDKs and zero analytics or tracking SDKs. We do not sell, rent, or share your data with anyone. Our App Store privacy manifest declares NSPrivacyTracking: false — we do not track you across other companies' apps or websites.
Audio / pronunciation
Word and sentence audio is produced by your device's built-in text-to-speech (on-device speech synthesis). Nothing you tap, hear, or answer is sent to any server for audio. The microphone is never used.
How the lessons were made (AI)
The word lists, example sentences, quizzes and mini-dialogues inside Fluexo Swipe were prepared with the help of AI writing tools during development and then reviewed by a human, before the app ships. The app itself does NOT send any of your data, answers, or activity to any AI service while you use it — there is no live AI in the app.
Children (rated 4+)
Fluexo Swipe is rated 4+ and is suitable for all ages. It collects no personal information from anyone, including children. There is no chat, no social feature, no user-generated content, no links out to third-party content, and no way for a child to share anything publicly or contact another person. The only purchasable items are clearly-labeled subscriptions gated behind the App Store's standard purchase confirmation (which can be additionally protected with Screen Time / Ask to Buy). If you have any concern, email us at mustafabaykal91@gmail.com.
International data transfer
Fluexo Swipe keeps all of your learning data on your device. The only data that leaves your phone is the anonymous subscription receipt check, which passes through RevenueCat's USA infrastructure under Standard Contractual Clauses (post-Schrems II), and Apple's global StoreKit pipeline. We have a Data Processing Agreement in place with RevenueCat.
Your rights & choices (GDPR / KVKK / CCPA)
Because we store nothing about you on any server, there is nothing for us to export, correct, or erase on our side — you already hold all of it on your device. To remove all local data, simply delete the app. To manage or cancel your subscription, use iOS Settings → Apple ID → Subscriptions, or the Manage Subscription link inside the app. You have the right to access, rectify, erase, restrict, and port your data, and to object to processing and lodge a complaint with your local authority; for any such request, or to have your anonymous RevenueCat subscription record anonymized further, email mustafabaykal91@gmail.com and we will respond within 30 days. We do not 'sell' or 'share' personal information as defined by the CCPA.
Your rights
- Access — request a copy of any data we hold about you.
- Rectification — request correction of inaccurate data.
- Erasure — request deletion (see Delete account).
- Portability — receive your data in a machine-readable format.
- Restriction — restrict processing in certain circumstances.
- Objection — object to processing based on legitimate interests.
- Object to automated decisions — the app does not make consequential automated decisions; you may still email us per GDPR Art. 22.
- Withdraw consent — for any processing based on consent.
- Lodge a complaint — with your local supervisory authority (in Türkiye: KVKK; in EU: your national DPA).
Legal bases for processing (GDPR Art. 6)
- Performance of a contract — processing payment receipts via Apple/RevenueCat to provide your subscription.
- Legitimate interests — anonymized analytics + crash reporting to improve the app.
- Consent — health permissions, push notifications, ATT tracking (you can withdraw at any time in iOS Settings).
- Legal obligation — retaining payment records per applicable tax law.
Children
Fluexo Swipe is not directed at children under 4. We do not knowingly collect data from children under that age. If you believe a child has provided us data, contact mustafabaykal91@gmail.com and we will delete it within 30 days.
Security
We implement industry-standard security measures: TLS 1.3 for all network traffic, encrypted at rest where stored on third-party services, no plaintext credentials, principle of least privilege for data access. No system is 100% secure; if a breach impacts you, we will notify per GDPR Art. 33–34 (within 72 hours of discovery).
California / CCPA
California residents have the right to: (i) know what personal info we collect; (ii) delete personal info; (iii) opt out of sale (we do not sell); (iv) non-discrimination. To exercise: email mustafabaykal91@gmail.com with subject "CCPA request".
Changes
If this policy changes materially, the "Last updated" date will be revised. Significant changes will be flagged in-app and we will provide a 30-day notice period for objection where required by law.
Contact
Privacy questions: mustafabaykal91@gmail.com · Data subject requests: same email, subject "Data subject request".