Back to product

Privacy policy content

1. Controller

The controller responsible for data processing relating to the mobile app MuyVerbs - Spanish Verb Master is:

2DAY Communications GmbH, Dornacherstrasse 172, 4053 Basel, Switzerland. Email: [email protected]

2. Scope of this Privacy Policy

This Privacy Policy applies to the mobile application MuyVerbs - Spanish Verb Master ("the App") for iOS and Android.

It explains which personal data we process when you use the App, for what purpose, how long we store it, to whom it is disclosed, and what rights you have under applicable Swiss data protection law, in particular the revised Swiss Federal Act on Data Protection (FADP / revDSG) of 1 September 2023.

Separate privacy terms of app stores or platform providers, such as the Apple App Store or Google Play, and third-party service providers, such as Google, Apple and RevenueCat, apply when you download, purchase, update or sign in to the App through those services.

3. Categories of Personal Data We Process

Depending on how you use the App, we process the following categories of personal data:

3.1 Account and Authentication Data

When you create an account or sign in, we process:

  • your email address
  • your display name, if provided
  • a unique user identifier issued by the authentication provider
  • the sign-in method used: Google, Apple, email, or Guest
  • authentication tokens provided by Firebase Authentication

Guest and Apple Sign-In

If you use Sign in with Apple with email relay, we only receive the relay address provided by Apple.

If you use Guest mode, we process only an anonymous, randomly generated user identifier; no email or name is collected.

3.2 Learning and Progress Data

To provide the core functionality of the App, including learning path, quizzes, and progress tracking, we process:

  • level and round completion
  • correct answer counts, accuracy and streak-style learning statistics
  • favorite verbs you save
  • quiz settings and study preferences
  • learning path position

Progress Storage

This data is stored locally on your device and, where you are signed in, synchronised with Cloud Firestore under your user identifier.

3.3 App Settings

We store your settings on your device, and where applicable in Cloud Firestore, including:

  • text size
  • light or dark layout preference
  • daily notification preference
  • "Ignore Accents" preference
  • "Skip Correct Review" preference
  • Learn by Tense verb pool preference: 500 most important verbs or all 3,000 verbs
  • analytics opt-out preference

3.4 Subscription and Purchase Data

If you purchase a Pro subscription, Monthly or Annual, the purchase itself is processed by the respective app store, Apple App Store or Google Play, and by our subscription management provider RevenueCat. In this context, the following data may be processed:

  • an anonymous app user ID provided to RevenueCat
  • the subscription product identifier, for example monthly_membership_4_99 or annual_membership_29_00
  • purchase, renewal, restore and cancellation status
  • entitlement status, for example pro_access
  • the platform used, iOS or Android

Payment Details

We do not receive your full payment details, such as credit card numbers. Payment is handled by Apple or Google.

3.5 Support and Feedback Data

If you use the "Report a bug", "Give Feedback" or "Contact" functions, or if you contact us by email, we process:

  • your email address
  • any name or identifier you provide
  • the content of your request
  • technical information you voluntarily include, for example device model or app version

3.6 Technical and Diagnostic Data

If you have not disabled analytics in Settings, we may process limited technical data through Firebase, such as:

  • app version and build
  • device type and operating system version
  • language and region settings
  • crash reports and error diagnostics
  • basic usage events needed to improve App stability

Analytics Controls

You can disable analytics at any time in Settings > Your Data > Disable Analytics.

4. Purposes of Processing

We process your personal data for the following purposes:

  • to provide the core learning features of the App: learning path, quizzes, grammar guide, verb library, favorites, and progress tracking
  • to create and manage your user account
  • to synchronise your progress across devices
  • to provide and manage Pro subscriptions, including restore of purchases
  • to enforce free-tier limits, for example the daily 10-question limit for free users
  • to provide support and respond to your requests
  • to diagnose and fix bugs, crashes and technical problems
  • to improve the quality and stability of the App
  • to comply with our legal obligations under Swiss law

5. Legal Basis for Processing

Under Swiss data protection law, we rely on the following justifications for our processing:

  • Performance of a contract, our terms of use, for account creation, learning progress, subscription management and support.
  • Your consent, for example for optional analytics or daily notifications, which you can withdraw at any time in Settings.
  • Our legitimate interests, for example in diagnosing crashes, preventing abuse, enforcing free-tier limits and improving the App.
  • Compliance with a legal obligation, for example accounting or responding to lawful requests from Swiss authorities.

6. Recipients and Data Sharing

We only share personal data with third parties where necessary to provide the App and only with service providers that are bound by appropriate contractual and data protection obligations. The main recipients are:

  • Google LLC / Google Ireland Ltd. - Firebase Authentication, Cloud Firestore, Firebase services and Google Sign-In: authentication, storage of user profile and progress data, and optional diagnostics.
  • Apple Inc. - Sign in with Apple: authentication for users who choose Apple sign-in.
  • RevenueCat, Inc. - management of subscriptions, entitlements, purchase validation and restore functionality.
  • Apple App Store / Google Play - processing of payments and subscription transactions for Pro plans.
  • Hosting and email providers used to receive and respond to your support requests.

No Sale or Advertising Networks

We do not sell your personal data. We do not use your personal data for advertising purposes and we do not share it with advertising networks.

7. Cross-Border Data Transfers

Some of our service providers, in particular Google/Firebase, Apple and RevenueCat, are based in the United States or process data in countries outside Switzerland and the European Economic Area.

Where personal data is transferred to a country that does not provide an adequate level of data protection in the view of the Swiss Federal Data Protection and Information Commissioner (FDPIC), the transfer is safeguarded by appropriate measures, such as Standard Contractual Clauses recognised by the FDPIC or equivalent safeguards provided by the relevant provider.

You can request a copy of these safeguards by contacting us at [email protected].

8. Storage Period

We retain personal data only as long as necessary for the purposes for which it was collected, or as required by law:

  • Account data: until you delete your account via Settings or request deletion by email.
  • Progress and favorites data: until you use "Reset progress" in Settings, delete your account, or uninstall the App for local data.
  • Subscription data: for as long as your subscription is active and afterwards for the period required by the app stores, RevenueCat and applicable accounting and tax law.
  • Support correspondence: typically for up to 24 months after the last contact, unless a longer retention period is required by law.
  • Diagnostic and crash data: for as long as necessary to diagnose and fix issues, typically no longer than 14 months.
  • Local data on your device: until you delete it in the App, reset it, or uninstall the App.

Account Deletion

When you use Delete Account in Settings, we delete your stored user data and request deletion of your Firebase authentication user where Firebase permits it. Backups or log files may still contain data for a limited residual period before they are overwritten.

9. Children

The App is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16 without the consent of a parent or legal guardian. If you believe that a child has provided us with personal data without such consent, please contact us at [email protected] and we will take appropriate steps to delete the data.

10. Automated Decision-Making

We do not use your personal data for automated individual decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

11. Data Security

We apply appropriate technical and organisational measures to protect your personal data against loss, misuse and unauthorised access, alteration or disclosure, in line with the principles of privacy by design and privacy by default required under Swiss data protection law.

Measures include encrypted transport, HTTPS/TLS, for communication with our backend services, access restrictions on Firestore data, authentication via trusted identity providers, and data minimisation in the design of the App.

No electronic transmission or storage system is completely secure; you are responsible for keeping your device and your app store or sign-in credentials secure.

12. Your Rights under Swiss Data Protection Law

Under applicable Swiss data protection law, you have in particular the following rights:

  • the right to request information about the personal data we process about you
  • the right to request correction of inaccurate personal data
  • the right to request deletion of your personal data where legally applicable
  • the right to request restriction of processing where legally applicable
  • the right to object to processing where legally applicable
  • the right to receive certain personal data in a common electronic format, data portability, where legally applicable
  • the right to withdraw a consent you have given, with effect for the future
  • the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner, FDPIC, Feldeggweg 1, CH-3003 Berne, Switzerland

Rights Requests

To exercise your rights, please contact us at [email protected].

You can also exercise some rights directly in the App, for example by resetting your progress or deleting your account in Settings > Your Data.

We may ask you for reasonable information to verify your identity before we act on your request.

13. Contact by Email

If you contact us by email, for example for support or privacy requests, we process the personal data you provide in your message, such as your email address, your name if provided, the content of your request and any information you voluntarily send us. We use this information only to process and answer your request and to document the communication where necessary.

14. Data Breaches

In the event of a data security breach involving personal data processed by us, we will handle the incident in accordance with applicable Swiss law. Where a breach is likely to result in a high risk to the rights of affected persons, we will notify the FDPIC as soon as possible and, where required, inform the affected persons.

15. Changes to this Privacy Policy

We may update this Privacy Policy if the App's features, our service providers, or the legal requirements change. The version published for MuyVerbs will always reflect the App's actual data processing. Where changes are material, we will notify you through the App or by other appropriate means before the changes take effect.

Controller: 2DAY Communications GmbH, Dornacherstrasse 172, 4053 Basel, Switzerland. Email: [email protected]