FonoPrivacy Policy
This policy explains which personal data we process when you use the Fono app and the website tryfono.app, why we need it, and which rights you have. The German version is the legally binding one.
1. Controller
[FILL IN: full name]
[FILL IN: street and number, postcode city, country]
Email: [email protected]
2. Overview
- Voice recordings go straight from your device to Google Gemini so Zümi can answer you. Fono's own servers do not receive or store the recording.
- Your learning progress (for example reviews, completed scenarios, results) is stored in your account so you can continue where you left off.
- Analytics and ad measurement run only with your consent. Crash reports are on by default and contain neither your voice nor conversation content; you can switch them off in the app.
- The website tryfono.app sets no cookies and uses no analytics or tracking services.
3. Website tryfono.app
The website is delivered by Cloudflare. When you visit, Cloudflare processes technically necessary connection data (for example IP address, time, page requested) to serve the page and protect it against abuse. Legal basis: our legitimate interest in secure and stable operation (Art. 6(1)(f) GDPR). Fonts are hosted locally; no data is sent to font providers. If you email us, we process your message and address to reply (Art. 6(1)(b) or (f) GDPR).
4. Account and sign-in
You can use Fono as a guest (anonymous account), with Sign in with Apple, with Continue with Google, or with email and password or an email code. Depending on the route we process a random account ID, your email address, with Apple possibly a private relay address and the name Apple releases, with Google the name, email address and profile picture Google releases, and technical sign-in data (session token). Legal basis: performance of the contract (Art. 6(1)(b) GDPR). Providers: Supabase, plus Google when you sign in with Google (see below).
5. Voice conversations with Zümi
For spoken conversations Fono uses the AI service Google Gemini (Google). When you speak, your voice is sent as audio from your device directly to Google; Google generates Zümi's reply and rates pronunciation and grammar. Our server only issues a short-lived access token for this and does not see the recording. For translations, pronunciation scoring, scenarios and exam tasks (for example grading your texts), our server sends text to Google Gemini.
The legal basis is your explicit consent (Art. 6(1)(a) GDPR), which you give before first using voice and can withdraw at any time under Profile → Privacy. Without it, voice conversations are not possible. Google processes the data under the terms that apply to the Gemini API; retention and use by Google are governed by those terms. We do not promise any specific retention period at Google.
We may store the transcript of conversations and results derived from it (for example notes on sentences, vocabulary, scores) in your account so you can see progress and corrections. Zümi can also remember a limited number of facts from your conversations (for example hobbies or goals) to respond more personally. You can remove these "memories" by deleting your account.
6. Learning progress, reviews, exam preparation
We store progress data in your account (learning path, scenario progress, review schedule for words and sentences, streak, practice and exam results, appointments for Zümi's calls) and your consent choices with a timestamp so we can prove them. Legal basis: performance of the contract (Art. 6(1)(b) GDPR); for consent records Art. 6(1)(c) and (f) GDPR.
7. Calls and notifications
If you enable calls or reminders from Zümi, we process push tokens (Apple/Google, plus a VoIP token for calls) and your appointment preferences to notify you at the agreed time. We use OneSignal for push messages. Legal basis: performance of the contract or your consent via the system notification prompt. You can withdraw it at any time in your device settings.
8. Purchases and subscriptions
Purchases go through the App Store or Google Play. To manage subscriptions and minute packs we use RevenueCat. RevenueCat receives your account ID and purchase information (product, period, status) but no payment data; Apple or Google alone process that. Legal basis: performance of the contract (Art. 6(1)(b) GDPR) and statutory retention duties (Art. 6(1)(c)).
9. Crash reports
If the app crashes or reports an error, we send technical information (device type, operating system, app version, error trail and your account ID) to Sentry (servers in the EU). It contains no voice recordings and no conversation content. These reports are on by default so we can fix errors quickly (legitimate interest, Art. 6(1)(f) GDPR). You can switch them off at any time under Settings → Crash Reports.
10. Analytics (consent only)
If you agree, we use Mixpanel (EU data residency) to measure how the app is used (for example screens opened, features used) so we can improve it. Legal basis: consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG). Without consent there is no analytics. You can withdraw consent at any time in the app.
11. Ad measurement (consent only)
To measure which ad led to an install, Fono may use AppsFlyer and the Facebook SDK (Meta). On iOS this happens only if you agree in the App Tracking prompt. Advertising ID, device information and install or purchase events may be transmitted. Legal basis: consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw it at any time in iOS settings under "Tracking".
12. Recipients and processors
| Service | Purpose | Data |
|---|---|---|
| Google (Gemini) | AI replies, pronunciation rating | Voice recording, text |
| Supabase | Accounts, database | Account, progress, consents |
| Google (Google sign-in only) | Sign-in | Name, email, profile picture |
| Cloudflare | Server (API), website, scheduling | Connection data, requests |
| RevenueCat | Subscriptions and purchases | Account ID, purchase status |
| Sentry | Crash reports | Technical error data, account ID |
| OneSignal | Push notifications | Push token, device information |
| Apple / Google | Sign-in, payments, push delivery | Under their own terms |
| Mixpanel (consent only) | Analytics | Usage events |
| AppsFlyer, Meta (consent only) | Ad measurement | Advertising ID, install and purchase events |
Providers process data on our behalf or as independent controllers under their own terms. The Supabase database location is eu-west-1 (Ireland, EU).
13. Transfers to third countries
Some providers (for example Google, Cloudflare, RevenueCat, OneSignal, Meta, AppsFlyer) may process data in the US or other third countries. Where there is no adequacy decision (for example the EU-US Data Privacy Framework), we rely on the European Commission's standard contractual clauses (Art. 46 GDPR).
14. Retention
- Account data and learning progress: as long as your account exists. On account deletion they are deleted (see Delete account).
- Anonymous guest accounts with no conversation that are unused for 60 days are deleted automatically.
- Open call-queue entries are deleted after 30 days. Short-lived practice data expires automatically.
- Purchase receipts and tax-relevant data are kept by Apple, Google and us according to statutory retention periods.
- Server logs at Cloudflare are kept only briefly.
15. Your rights
You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and objection (Art. 21 GDPR). You can withdraw any consent at any time with effect for the future; processing before withdrawal stays lawful. Write to [email protected]. You may also complain to a data protection authority, for example where you live or where the controller is based.
16. Children
Fono is intended for people aged 16 and over. We do not knowingly collect data from children under 16.
17. Automated decisions
Zümi and the ratings in Fono are AI-assisted and serve only as learning aids. There is no automated decision with legal effect on you. Exam ratings in Fono are practice feedback and not an official result.
18. Changes
We update this policy when the app or the law changes. The current version is always at tryfono.app/en/privacy.