Політика конфіденційності

1. Introduction

This Privacy Policy describes how "SvitSliv" (the mobile app and website operated under the project SvitSliv, hereinafter "we", "us", or "the Service") handles information when you use our application or website. It is intended to meet common requirements for app stores (including Google Play and Apple App Store) and to inform you transparently about our practices.

2. Controller

Ivan Kharchenko
c/o flexdienst – #20597
Kurt-Schumacher-Straße 76
67663 Kaiserslautern
Germany

Email: edelhirschx@gmail.com

3. Data we process

3.1 Data you provide

If you contact us (for example via email or a feedback form), we process the content of your message and your contact details as needed to respond.

3.2 Data collected automatically

When you use the website or the app (including the Capacitor-based mobile client that loads our web content), standard technical data may be processed, such as approximate information about the request (e.g. time, type of client), and—if applicable—analytics, hosting logs, or advertising data as described below.

3.3 Local storage on your device

The app stores preferences and learning-related data locally on your device (for example via browser or WebView storage). We do not operate a central server that stores your personal learning progress. This data stays on your device unless you send it to us explicitly (e.g. when reporting an issue).

3.4 Advertising-related data

When ads are shown (see Section 6), Google may process advertising and device-related data as an independent or joint controller, depending on the product and region. This is separate from your learning data in SvitSliv.

4. Purposes and legal bases (GDPR)

Where the GDPR applies, we rely on appropriate legal bases, including:

• Art. 6(1)(b) GDPR — performance of a contract or pre-contractual steps, when providing the Service you requested.
• Art. 6(1)(f) GDPR — legitimate interests, such as operating, securing, and improving the Service, and measuring aggregate usage, where not overridden by your rights.
• Art. 6(1)(a) GDPR — consent, where we or our partners ask for it (e.g. personalized advertising in the EEA/UK, or non-essential cookies on the website).

5. Analytics and hosting

Our website uses analytics provided by our hosting partner Vercel. Vercel Analytics does not use cookies; data is aggregated and not used to identify you directly. Hosting may process server log data (e.g. IP address, request time) as described in our German notice at /datenschutz.

6. Advertising

6.1 Mobile app — Google AdMob

The iOS and Android apps display banner ads through Google AdMob (Google Ireland Limited / Google LLC). AdMob may process data such as advertising IDs, IP address, ad interactions, and device/app information to deliver and measure ads and to fund the free app.

6.2 EU / UK consent form (Google UMP)

If you are in the European Economic Area, Switzerland, or the United Kingdom, you may see a consent dialog provided by Google (User Messaging Platform, "UMP") when the app starts. It asks whether you allow Google and its partners to use data for personalized advertising. The dialog is operated by Google; your choice is stored via Google's SDK and can be changed later in Google or device privacy settings. If you decline personalized ads, non-personalized ads may still be shown.

6.3 iOS — App Tracking Transparency (ATT)

On Apple devices, iOS may separately ask whether the app may track you across other companies' apps and websites (IDFA). This relates to advertising measurement, not to your vocabulary learning data in SvitSliv.

6.4 Website — Google AdSense

Our website svitsliv.com shows banner ads through Google AdSense (Google Ireland Limited / Google LLC) when you consent via the cookie banner. AdSense may use cookies or similar technologies to deliver and measure ads. The AdSense script loads only after you acceptadvertising cookies; if you choose "Essential only", we do not load AdSense.

6.5 Website — cookie consent banner

On the website you may see a banner asking whether you allow advertising cookies. Your choice is stored locally in your browser (localStorage key svitsliv_cookie_consent_v1). We use Google Consent Mode v2: advertising tags stay denied until you accept.

More information: Google Privacy Policy, How Google uses data in advertising.

8. Cookies and similar technologies (website)

8.1 Essential — interface language

We store your chosen interface language in a first-party cookie named jasno_ui_locale (and in localStorage for the same purpose). This is needed to remember Ukrainian or English in the menu. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in providing the Service in your language).

8.2 Advertising — Google AdSense (with consent)

If you accept advertising cookies in our banner, Google AdSense may set cookies such as __gads or __gpi for ad delivery and measurement. Legal basis: Art. 6(1)(a) GDPR (consent).

8.3 No advertising cookies without consent

Vercel Analytics does not use cookies (see Section 5). If you decline advertising cookies, we do not load the AdSense script on the website.

9. Children

The Service is not directed at children under 16. We do not knowingly collect personal data from children. If you believe we have collected such data, please contact us and we will take appropriate steps.

10. Retention

We retain personal data only as long as necessary for the purposes described, unless a longer period is required by law. Local data stored on your device is controlled by you (you can clear app or browser data). Advertising partners apply their own retention periods.

11. Your rights

Depending on applicable law (including the GDPR where it applies), you may have the right to access, rectify, erase, restrict processing, data portability, and to object. You may also lodge a complaint with a supervisory authority. For Google's ad processing, you may also use Google's privacy tools and withdraw consent in device settings.

12. International transfers

If data is processed outside the European Economic Area (e.g. by Vercel or Google in the USA), we rely on appropriate safeguards as required by applicable law (e.g. standard contractual clauses or the EU-U.S. Data Privacy Framework, where applicable).

13. Changes

We may update this Privacy Policy from time to time. The "Last updated" date at the top will change when we do. Continued use of the Service after changes constitutes your acknowledgment of the updated policy, to the extent permitted by law.

14. Contact

For privacy-related questions, contact us at edelhirschx@gmail.com.

A German-language privacy notice (Datenschutzerklärung) is also available at /datenschutz.