App Privacy Policy

1. General Information

The abblino app (hereinafter also referred to as “the App”) serves as a language learning platform, enabling users to learn a new language through conversations with AI-supported language partners. The App offers a range of features and content for language practice. In addition to the conversation function, other services, such as a vocabulary and grammar trainer, are offered. There is also a premium version with extended features and content, which is subject to a fee.

Website: abblino.com

Marketing Activities: For marketing purposes, abblino is promoted through company accounts on common social media channels. Paid advertising is also placed on these channels. Additionally, abblino operates its own website for overview and information about the App. These channels are not part of this privacy policy but have individual privacy policy documents.

Data Controller

abblino UG (haftungsbeschränkt)

Roonstraße 23a

76137 Karlsruhe, Germany

Contact Email for Data Protection Inquiries: support@abblino.com

This privacy policy was last revised on April 21, 2025.

2. Collected Data

abblino’s mission is to optimally support users in learning a new language. To achieve this, abblino processes a range of personal data. The following personal data may be collected:

  • Registration and Account Data:
    • Email address, username, optional first and last name, as well as age, and in some countries, the phone number.
    • abblino also allows registration through third-party providers such as Google or Apple. If you register with one of these third-party providers, abblino may gain access to data from your third-party account. You can manage your data used by abblino in the App’s settings.
  • Usage and Device Data: Data resulting from App usage, device information, and general location data.
    • Profile Page: In particular, the creation of a profile using the user data mentioned above. Other users may be allowed to view your profile to interact with you through the App. No sensitive data is shared with other users; only your username and information about your achieved milestones and statistics within the App, such as experience points (XP) or the number of written messages, are shared. At abblino, the protection of your data is a top priority, so you can set your profile to private at any time through the profile view page. This means you can no longer be found by other users and are only visible to users on your friend list. By default, your profile is public.
    • User-Generated Content: When using our App, further user-related data is generated, which abblino requires to provide our services correctly. This includes the collection of voice and text messages, which form the basis of various functions. For voice and text recognition, these messages may be send to a third-party provider such as Google or Vercel.
    • IP Addresses: abblino may collect activity and location-related data. These are stored for no longer than thirty (30) days unless there are legal provisions that expressly require us to store the data.
  • Server and Log Data: Automatically collected information about App usage, including IP addresses, time and duration of use.
  • Cookies and Similar Technologies: Cookies and similar tracking technologies are used to collect and track usage, including integrations with third-party providers such as Google Analytics.
  • Sensitive Data: In principle, we do not collect special categories of personal data (e.g., health data, biometric data). However, when using certain functions, especially the conversation features, personal data could be shared by the user themselves. This information may be processed by third parties such as Vercel and Google as part of our platform and stored on our servers. To protect your privacy, we recommend not sharing sensitive data through the conversation functions.

3. Purposes and Legal Bases of Data Processing

The collection and processing of personal data primarily serve to provide and improve the functions of our App and to ensure a smooth user experience. The specific purposes of use include:

  • Creation and Management of User Accounts: To enable the use of personalized App functions.
  • Communication: abblino can use your data, such as your email address, to contact you on relevant topics.
  • Analyses and Optimizations: To improve the App and its functions by analyzing usage data.
  • Technical Provision and Functionality: Ensuring stable, secure, and efficient operation of the App and the functionalities of the offered language partners and AI-based interactions.

Data processing is based on the following legal bases according to the General Data Protection Regulation (GDPR):

  • Contractual Necessity (Art. 6 para. 1. b GDPR): The provision of some functions of the App is not possible without this data.
  • Consent (Art. 6 para. 1. a GDPR): Consent to the processing of certain data is obtained during registration.
  • Legitimate Interest (Art. 6 para. 1. f GDPR): For the purpose of improving and ensuring the security and functionality of our App.

4. Data Sharing

In the context of using our App, personal data is shared with third parties to ensure the App’s functionality and to provide services that are important to our users. The following third parties receive access to the collected data, with the specific purposes of data sharing listed below:

  • AdMob (Google): Data is shared to display personalized advertisements within the App, which allows us to offer the App to users free of charge.
  • Gemini and possible other third-party AI-providers: Data is transmitted to Gemini to enable text and voice generation based on user input. This is an essential part of the functions we provide. This data is generally only passed on in anonymized form. However, as mentioned above, the user has the option to include personal data in the text messages. We expressly advise against this, as it is not necessary for the operation of the App and its functions.
  • Vercel: Parts of our servers are operated through the Vercel service, which stores server-side log files to analyze and understand user activities, especially to detect and prevent attacks on our infrastructure in a timely manner. In particular, functionalities related to the conversation features require the provided services through Vercel. These servers may be located in the USA, which requires the data generated in the app to be facilitated and process to and in the USA. The reason for this traffic is backed by the reasons in 3.
  • Firebase Products (Google): These services are used for the processing, storage, and collection of data. This includes authentication services as well as security and integrity measures of our App.
  • AppCheck (Google): abblino uses Firebase App Check to help ensure that only authorized devices and apps can access our backend services. This helps protect your data and prevent abuse. App Check may collect device information to verify that interactions with our services come from the intended application.
  • Google Analytics: Data is shared with Google Analytics for analysis purposes to evaluate user data and continuously improve offers and user experience.
  • Google Play Store: Data sharing with the Google Play Store serves to list the App and process transactions in connection with the premium subscription.
  • Apple App Store: Similar to the Google Play Store, data is transmitted to the Apple App Store to support the publication of the App and process transactions.
  • Google Cloud Platform (GCP): Services of the Google Cloud Platform ecosystem might be used to ensure a high functionality and scalability of our services. The servers are located within the EU, if available by GCP.

The sharing of personal data with third parties takes place exclusively in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).  

5. Storage Location and Duration

The storage of personal data takes place at various locations, depending on the respective data processing services:

  • abblino’s Server Locations: All user’s personal data is stored on servers within the European Union (EU). This ensures that the data is processed in accordance with the requirements of the General Data Protection Regulation (GDPR).
  • Gemini & Vercel: Data transmitted to Gemini for processing might be stored on servers in the United States of America (USA). The transmission of this data is lawful according to Art. 6 1. GDPR and necessary for the use of abblino.
  • Other Third-Party Providers: To provide our functionalities, it is possible that data from other third-party providers, such as Google Analytics, is stored. This data is stored exclusively in the EU, if possible. Third-party providers whose servers are located in other regions, such as the USA, are only used if this is possible through the justifications in Art. 6 of the GDPR.

6. Data Transfer Outside the EU

In the context of using our services, it may be necessary for personal data to be transmitted to countries outside the European Union (EU). This particularly concerns the transmission of data to Gemini, whose servers are located in the USA.

We aim to minimize the transmission of sensitive data. Nevertheless, it is necessary to transmit certain data to ensure the functionality of our App.

To ensure GDPR-compliant data processing, we have concluded Data Processing Agreements (“DPA”) if available. These agreements set the framework for the processing of personal data and ensures that the data is handled in accordance with the data protection standards of the GDPR.

We follow recognized standards for data protection and ensure that all transmissions are carried out in a GDPR-compliant manner.

By using our services, users agree to the transmission of their data under the conditions mentioned above.

7. User Rights

According to § 13 GDPR, users have the right to receive information about the data stored about them at any time. In addition, they have the right to assert their rights according to Articles 12 to 21 GDPR. This includes:

  • Right to Information: Users can request to receive information about which personal data is processed.
  • Right to Rectification: Users have the right to have incorrect data corrected.
  • Right to Erasure
  • Right to Restriction of Processing: Users can request the restriction of the processing of their data under certain conditions.
  • Right to Data Portability: Users have the right to receive their personal data in a structured, common, and machine-readable format and to transmit it to another controller.
  • Right to Object: Users can object to the processing of their personal data under certain circumstances.  

If the exercise of the above rights is not possible via the App, a request can be made via email to the following address: support@abblino.com

8. Data Retention Period

The retention period of personal data is regulated as follows:

  • User Data: The personal data of users is stored on our servers until the user account is deleted.
  • Exceptions: If there are legal retention periods, the corresponding data will be retained for the duration of these periods to comply with legal requirements.

9. Data Protection Officer

Currently, abblino UG (haftungsbeschränkt) has not appointed a Data Protection Officer. For questions or concerns about data protection, you can contact us directly by sending an email to support@abblino.com.

10. Integration of Third-Party Services and Cookies

In the context of providing our App, various third-party services and technologies are used to analyze and optimize the use of our services. This includes Google Analytics, a web analytics service of Google LLC. Google Analytics uses cookies to collect information about the use of our App. This information is usually transmitted to a Google server in the USA and stored there. Google uses this information to evaluate the use of the App, create reports on App activities, and provide other services related to App and internet usage.  

The use of cookies is based on Art. 6 para. 1 f GDPR, as we have a legitimate interest in improving the quality and user-friendliness of our App. Users can prevent the installation of cookies by setting their browser software accordingly. In addition, users have the option to control the processing of their personal data by selecting appropriate settings on their devices.

We also use cookies and similar tracking technologies to conduct user analyses and optimize our offerings. These technologies allow us to better understand user interactions with our App and adapt our services to the needs of our users.

Users have the right to object to the processing of their personal data. For information on how to exercise your data protection rights, please refer to the section on the rights of data subjects.

11. Changes to the Privacy Policy

We reserve the right to change or amend this privacy policy at any time. Changes will be communicated to users in an appropriate manner. Users will be informed of significant changes by email or directly in the App.

We recommend that users regularly review the privacy policy to stay informed about the applicable conditions and the processing of their personal data.