Privacy Policy
What we collect in the Promi app and on this website, why we collect it, and what your rights are. We wrote it to be short and readable.
Last updated: 21 October 2026
This policy applies to the Promi: Business English iPhone app (“Promi”, “the app”) and to the website promienglish.com (“the website”). If anything is unclear, write to us at hello@promienglish.com.
1. Who is responsible for your data
The data controller is:
Digitly Media Kft.
1131 Budapest, Béke utca 73. 5. em. 13., Hungary
Company registration no.: 01-09-399063
Tax no.: 27818147-2-41
Privacy contact: hello@promienglish.com
“We”, “us” and “our” in this policy mean Digitly Media Kft.
2. The short version
- We collect only what the app needs to work: your account, your learning profile and progress, your roleplay conversations and your subscription status.
- We do not show ads in the app, and we do not sell your data.
- To learn which of our own ad campaigns bring new learners, the app uses an install attribution service (Tenjin). If you allow tracking in the iOS prompt, this includes your device’s advertising identifier. If you don’t, it doesn’t.
- Your roleplay messages are sent to an AI provider to generate replies and feedback.
- You can delete your account and all its data in the app at any time.
- This website uses no cookies and no analytics.
3. What data we collect in the app
Account data (Sign in with Apple)
- A unique user identifier that Apple gives us for your account.
- Your name, but only if you choose to share it with Sign in with Apple.
- We do not ask Apple for your email address.
Signing in is optional for lessons, but it is needed for AI roleplay and for syncing across devices.
Learner profile
- The first name you type in the app, your explanation language, your English level, your goals and focus situations, your daily goal, your reminder time and, if you answer it, how you heard about us.
Learning progress
- Lessons and exercises you complete, scores, time spent, reviews, streaks and achievements.
Roleplay conversations
- The messages you write in AI roleplay, the AI’s replies and the feedback you receive.
- Usage counters (for example how many sessions you started this month) and the cost of the AI calls, so we can apply fair-use limits.
- If you use dictation, it is provided by iOS. We receive only the text you send, never audio.
Subscription data
- Your subscription status and purchase history (product, dates, renewal state, whether you used an introductory offer). Apple processes the payment; we never see your card or payment details.
Attribution data
- Device identifiers (the identifier for vendor and an install ID), your IP address, app version, which ad campaign or network led to your install, and a few funnel events (onboarding completed, paywall viewed, trial started, subscribed).
- Your device’s advertising identifier (IDFA) only if you tap “Allow” in the iOS tracking prompt. We show that prompt only after you subscribe, never before.
Technical data
- When the app talks to our server, our hosting provider processes technical data such as your IP address, the time of the request and basic device and app information. We use it to deliver the service and keep it secure.
What stays on your device
- Reminders are scheduled locally on your iPhone. We do not use push notification tokens.
What we do not collect: location, contacts, photos, health data, audio or browsing history.
4. The website
This website is a static site hosted by Cloudflare. It sets no cookies, uses no analytics or tracking tools, and loads its fonts from our own server rather than from third parties.
When you visit, Cloudflare processes your IP address and basic request data (for example the page requested, the time and your browser type) to deliver the page and protect it from attacks. This is based on our legitimate interest in running a secure website (Art. 6(1)(f) GDPR). These logs are kept only for a short time.
If you email us, we use your email address and message to answer you.
5. Why we use your data and our legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Creating and running your account, saving and syncing your plan and progress | Account data, learner profile, progress | Performance of a contract (Art. 6(1)(b)) |
| Personalising lessons (level, language, goals) | Learner profile, progress | Performance of a contract (Art. 6(1)(b)) |
| AI roleplay: generating replies and feedback, showing your history | Roleplay conversations | Performance of a contract (Art. 6(1)(b)) |
| Checking your subscription and unlocking Pro features; showing the one-time offer only once | Subscription data, user ID | Performance of a contract (Art. 6(1)(b)) |
| Fair-use limits, preventing abuse and keeping the service secure | Usage counters, technical data, roleplay conversations | Legitimate interest (Art. 6(1)(f)): protecting the service and its costs, and keeping it safe for everyone |
| Measuring which of our ad campaigns lead to installs and subscriptions | Attribution data without IDFA | Legitimate interest (Art. 6(1)(f)): spending our marketing budget responsibly |
| The same measurement using your advertising identifier (IDFA) | IDFA | Consent (Art. 6(1)(a)), given in the iOS tracking prompt; you can withdraw it in iOS Settings → Privacy & Security → Tracking |
| Improving the course using aggregated statistics | Progress, learner profile | Legitimate interest (Art. 6(1)(f)): understanding which lessons work |
| Daily reminders | Reminder time | Consent (Art. 6(1)(a)), given through the iOS notification permission |
| Answering your emails and support requests | Your email address and message | Legitimate interest (Art. 6(1)(f)) or contract, depending on the request |
| Meeting legal obligations | As needed | Legal obligation (Art. 6(1)(c)) |
Where we rely on legitimate interest, you can object (see section 10).
We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. The AI feedback in roleplay is a learning aid only.
6. AI processing
When you use AI roleplay, our server sends your messages, the scenario and the conversation so far to OpenRouter, which routes the request to Anthropic (Claude models). The AI’s reply and feedback come back to our server and then to you. The app never sends your data to the AI provider directly.
We send only what is needed for the conversation: no name from Sign in with Apple, no Apple ID and no payment data. Please don’t write sensitive personal information (for example health details or other people’s personal data) into roleplay. The scenarios are fictional and don’t need it.
7. Who processes your data for us
We use these service providers. They process data on our behalf and under our instructions:
| Provider | What they do | Data involved |
|---|---|---|
| Cloudflare, Inc. | Hosting of our server, database, file storage and this website | Server-side data listed above, website request data |
| OpenRouter, Inc. | Routing AI requests to the AI model | Roleplay conversations |
| Anthropic, PBC | AI model that generates roleplay replies and feedback | Roleplay conversations |
| RevenueCat, Inc. | Managing subscription status | User ID, purchase history, device identifiers, attribution install ID |
| Tenjin, Inc. | Install attribution for our ad campaigns | Attribution data (see section 3) |
| Apple Inc. | App Store payments and subscriptions; Sign in with Apple | Purchase data, Apple user identifier, optional name |
Apple is responsible for its own processing of payment and App Store account data as an independent controller, under Apple’s own privacy policy.
We don’t sell your personal data. We may disclose data if the law requires it, or to protect our rights in a legal dispute.
8. International transfers
Some of our providers are based in the United States or may process data outside the European Economic Area. When personal data leaves the EEA, we make sure it is protected by an appropriate safeguard, such as the EU–U.S. Data Privacy Framework, where the recipient is certified under it, or the European Commission’s Standard Contractual Clauses, together with additional measures where needed.
You can ask us for more information about the safeguard used for a particular provider at hello@promienglish.com.
9. How long we keep your data
| Data | How long |
|---|---|
| Account data, learner profile, progress | Until you delete your account |
| Roleplay conversations | Until you delete your account, so you can see your history and we can apply monthly limits |
| Usage counters and AI cost records | Until you delete your account; short-term rate-limit records are deleted automatically |
| Subscription data in RevenueCat | Until you delete your account; we then ask RevenueCat to delete the subscriber record |
| Attribution data at Tenjin | As set in Tenjin’s data retention settings, and no longer than needed for campaign measurement |
| Technical server and website logs | For a short period, as set by our hosting provider, for security and troubleshooting |
| Emails | As long as needed to handle your request, then up to 2 years in case of follow-up questions |
When you delete your account, we delete your data from our active systems straight away, and from all systems, including backups, within 30 days. We also revoke our Sign in with Apple access. We may keep data longer only where the law requires it. Apple keeps its own records of your purchases under its own policy.
10. Your rights
Under the GDPR you have the right to:
- Access your data and get a copy of it.
- Rectification: correct inaccurate data. You can change most of your profile in the app.
- Erasure: delete your data. Use Profile → Settings → Delete account, or write to us.
- Restriction: ask us to limit how we use your data in certain cases.
- Data portability: receive the data you gave us in a structured, machine-readable format.
- Objection: object to processing based on our legitimate interest.
- Withdraw consent at any time, for example by turning off tracking or reminders in iOS Settings. This does not affect processing that happened before.
To use any of these rights, email hello@promienglish.com. We will answer within one month. We may need to confirm that the request comes from the account holder.
Complaints. You can complain to a data protection authority, in particular in the EU country where you live or work. Our lead authority is:
Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH, Hungarian National Authority for Data Protection and Freedom of Information)
1055 Budapest, Falk Miksa utca 9–11, Hungary
Postal address: 1363 Budapest, Pf. 9.
Phone: +36 1 391 1400
Email: ugyfelszolgalat@naih.hu · Website: naih.hu
You can also go to court. We would appreciate the chance to resolve your concern first, so please contact us.
11. Children
Promi is made for working professionals and is not directed at children. If you believe a child has given us personal data, contact us and we will delete it.
12. Security
We protect your data with technical and organisational measures that fit the risk. All connections between the app and our server are encrypted (HTTPS), access to our systems is limited to those who need it, and AI provider keys are kept only on our server. No system is perfectly secure. If a data breach is likely to put your rights at risk, we will inform you and the authority as the law requires.
13. Changes to this policy
We may update this policy when the app, the website or the law changes. We will post the new version on this page and change the date at the top. If the changes are significant, we will also tell you in the app before they take effect.
14. Contact
Digitly Media Kft., 1131 Budapest, Béke utca 73. 5. em. 13., Hungary
Privacy questions: hello@promienglish.com
App support: support@promienglish.hu