Privacy Policy

1.1 Account Data

When you create an account, we collect the information needed to authenticate you and operate your account, including:

• Email address
• One-time sign-in codes sent to that email address (the App uses no passwords)
• If you sign in with Google or Apple: the name and email address that provider shares with us
• Any profile details you choose to add (e.g. display name)

Account authentication is handled by Amazon Cognito, an identity service of Amazon Web Services (AWS) hosted in the AWS Frankfurt region (Germany). AWS's handling of your sign-in data is governed by the AWS Privacy Notice.

1.2 Content You Submit for AI-Generated Feedback

The App's writing-practice feature lets you submit text you write (e.g. practice essays or letters) to receive feedback on your German. To generate that feedback, the text you submit is sent to a third-party AI provider, OpenAI, for processing.

• We send only the submitted text (and any minimal context needed to score it, such as the exercise prompt) — not your account credentials.
• OpenAI processes this text through its API under the OpenAI Privacy Policy and its API data-handling terms. OpenAI does not use text sent through its API to train its models. It may retain the text for up to 30 days to monitor for abuse, after which it is deleted.
• We retain your submitted texts and the feedback received in order to show you your practice history within the App. You can request deletion at any time (see Section 6).

Scanning a handwritten answer (iPhone and iPad). The writing exercise's Scan button opens your device's camera so you can photograph an answer you wrote on paper. The photo is converted to text on your device only: it is never uploaded, and it is deleted as soon as the text has been read from it. The recognised text lands in the answer field, where you can edit it, and is treated like text you typed once you submit it. The App asks for camera access the first time you scan and uses the camera for nothing else.

1.3 Crash Reporting and Performance

To find and fix defects, and to see where the App is slow, the App uses Sentry, a crash-, error-, and performance-reporting service operated by Functional Software, Inc. When the App crashes, hits an unexpected error, or a request to our servers fails, a report is sent to Sentry; the App also sends timing measurements for a share of the screens you open and actions you take. A report may contain:

• Technical details of the failure: the error type and message, a stack trace, and the names of the screens and actions leading up to it
• Device and app information: device model, operating system and version, app version and build, language, screen size, free memory and storage, battery and connectivity state
• Network diagnostics for requests to our servers: the request path, method, status code, duration, and payload sizes — never the request or response contents, and never your sign-in token
• A random installation identifier, so that we can tell how many devices a problem affects, and which releases; this identifier is not derived from your account or your device's hardware identifiers
• Whether the App was in use, for session and stability statistics
• Performance measurements: how long the App took to start, how long a screen took to appear, and how long the requests made while it loaded took — the name of the screen or the control you used, and durations, never what you entered or read there. On iPhone and iPad these measurements may also record which parts of the App's own program code were running at the time

We have configured Sentry to collect as little as possible: reports carry no email address, display name, or IP address beyond what any internet connection transmits transiently, and they do not include the texts you write in the App. The installation identifier still singles out one installation over time, so we treat reports as pseudonymous personal data rather than as anonymous. Sentry processes reports on our behalf under Sentry's privacy policy and data processing terms. Reports are stored in the European Union and deleted automatically at the end of Sentry's retention period, which is no longer than 90 days.

Analytics. As of this writing, the App collects no product-usage analytics (e.g. which features are used). If we add analytics in the future, we will update this policy before that collection begins and name the service used here.

1.4 Purchase and Access Data

Full access to the App (“Doch! PRO”) is sold as one-time access packages, described in Section 6 of our Terms of Service.

The payment itself does not go through us. It is taken by the Apple App Store or Google Play, under that store's own terms and privacy policy. We never receive, see or store your card, bank or other payment details, and we do not receive your name or address from the store.

When a purchase completes, the App sends our backend only:

• Which store the purchase came from (Apple or Google)
• Which package was bought (its product identifier, e.g. the 90-day package)
• The store's proof of purchase: on Android, the Google Play purchase token for that order; on iPhone and iPad, the signed transaction Apple issues. Our backend checks it against that store to confirm the purchase is genuine and has not already been used

From that we store, against your account:

• The package bought and the start and end dates of your access period
• The store's transaction identifier, so the same purchase can never unlock access twice, and so we can find your purchase if you contact support

Apple and Google process your purchase as independent controllers under their own policies: Apple, Google.

1.5 Automatically Collected Technical Data

Standard technical data your device sends as part of normal app operation (e.g. IP address for network requests, device/OS type for compatibility) may be logged transiently by our backend infrastructure for security and debugging purposes, and is not linked to marketing or advertising profiles.

1.6 Contact Form on dochapp.com

The Impressum page on dochapp.com has a contact form. What you enter there — your name, your email address and your message — is turned into one email to our support mailbox, the same one support@dochapp.com reaches, and is not stored anywhere else. We use it only to answer you, and keep that email for as long as the conversation needs it. The email is delivered through Cloudflare, Inc., which processes it on our behalf under Cloudflare's Data Processing Addendum, incorporating the EU Standard Contractual Clauses.

We use the information described above to:

• Create and maintain your account
• Provide the core App functionality, including generating AI feedback on submitted writing
• Maintain your practice history within the App
• Unlock and keep track of paid access, and answer questions about a purchase
• Keep purchase records after an account is deleted, so that a purchase cannot unlock access twice and a later refund still reaches you
• Secure the App and investigate misuse
• Communicate with you about your account (e.g. sign-in codes)
• Answer messages you send through the contact form on dochapp.com

We do not sell your personal information, and we do not use your submitted writing content for advertising purposes.

We share data only with the service providers necessary to operate the App:

Cognito, OpenAI, Sentry and Cloudflare act as processors on our behalf and are contractually permitted to use this data only to provide services to us. Apple and Google act as independent controllers for the payment itself, under their own terms.

We retain your account data and submitted writing/feedback history for as long as your account is active.

If you delete your account, we delete this data from our live systems immediately. Copies held in routine backups are overwritten as those backups expire, within 30 days. We keep a record that the deletion happened, holding an internal account identifier and the date, but not your name or email address.

Purchase records, meaning which store the purchase came from, its transaction identifier, the package bought and the access period it granted, are kept after you delete your account. We keep them so that a purchase can never unlock access twice and so that a refund the store issues later is still applied. Once your account is deleted they are not linked to your name or email address, and they are never used to profile you.

Both the purchase records and the deletion record are kept for three years from the end of the year in which the access period ended — or, for the deletion record, in which the account was deleted. That window is chosen so that it runs past the general limitation period for claims about the purchase under German law (§§ 195, 199 BGB), which starts at the end of the year a claim arises rather than the year of the purchase. We delete the records once it ends.

Where the GDPR applies, we rely on:

• Performance of a contract (Art. 6 (1)(b)) for your account, authentication, practice history, AI feedback on the writing you submit, and unlocking and tracking paid access
• Legitimate interests (Art. 6 (1)(f)) for crash, error and performance reporting, and for security and abuse investigation — our interest being to keep the App working, fast and secure, weighed against the limited, pseudonymous data those reports contain — no name, email or content, and an installation identifier we cannot tie to your account (Section 1.3)
• Legitimate interests (Art. 6 (1)(f)) for keeping purchase records after an account is deleted — our interest being fraud prevention and the handling of refunds and disputes, weighed against records that no longer carry your name or email address (Section 4)
• Legitimate interests (Art. 6 (1)(f)) for answering a message you send through the contact form — our interest being to reply to you, weighed against data you chose to send us for exactly that purpose (Section 1.6)

Depending on where you live, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your account and associated data
• Export a copy of your data
• Restrict or object to processing based on our legitimate interests

To exercise any of these rights, contact us at support@dochapp.com. To delete your account, you can also do it yourself in the App, under Profile; Deleting Your Doch! Account sets out both routes and what deletion does and does not remove.

If you are in the EU/EEA, you also have the right to lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work.

The App is not directed at children under 16, and we do not knowingly collect personal information from children under that age. If you believe a child has provided us with personal information, contact us at support@dochapp.com and we will delete it.

We use reasonable technical and organizational measures to protect your information, including encryption of data in transit. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

Your account data, practice history, and the servers that operate the App are hosted in the European Union: authentication (Amazon Cognito) and our application backend run in the Amazon Web Services Frankfurt region (eu-central-1, Germany), and crash reports are stored in Sentry's EU region. Text you submit for AI feedback is processed by OpenAI, which may process it outside the EU/EEA, including in the United States. That transfer is covered by OpenAI's Data Processing Addendum, which incorporates the EU Standard Contractual Clauses. A message sent through the contact form on dochapp.com passes through Cloudflare's network, which may handle it outside the EU/EEA; that transfer is covered by Cloudflare's Data Processing Addendum, which likewise incorporates the Standard Contractual Clauses (Section 1.6). Information processed outside the EU/EEA may be subject to different data protection laws than your country of residence.

Verifying a purchase means contacting the store that took the payment. Apple and Google are independent controllers there, contracting with buyers in the EU through Apple Distribution International Ltd. and Google Commerce Limited, both established in Ireland. Where they process anything outside the EU/EEA, they do so under their own privacy policies, linked in Section 1.4, rather than under an arrangement we make on your behalf. We send them nothing beyond the proof of purchase described in that section.

We may update this Privacy Policy from time to time. If we make material changes, we will notify you in the App or by other reasonable means before the changes take effect. The “Last updated” date above reflects the most recent revision.

Questions about this Privacy Policy? Contact us at:

support@dochapp.com
Liudmila Kapustina, Bettinastrasse 50, 60325 Frankfurt am Main, Germany