Privacy Policy

Last updated: March 15, 2026

Pronouncy (“we,” “our,” or “the app”) is committed to protecting your privacy. This Privacy Policy explains how the Pronouncy iOS application handles your data. The short version: we don’t collect any of it.

1. Data We DON’T Collect

Pronouncy is designed with a strict no-collection architecture. We do NOT collect:

• Personal information -no names, email addresses, phone numbers, or physical addresses
• Voice recordings -no audio is recorded, stored, or uploaded. Speech is processed in real-time and discarded immediately.
• Location data -no GPS coordinates, IP-based location, or geofencing
• Browsing history -no web activity, search queries, or referral data
• Device identifiers -no UDID, serial number, or hardware fingerprinting
• Third-party analytics -no Google Analytics, Firebase, Mixpanel, or any analytics SDK
• Personally identifiable data -no data that could identify you as an individual
• Advertising identifiers (IDFA) -we do not use or request the Identifier for Advertisers

2. Local-Only Data Storage

All data you create in Pronouncy stays on your device. The app uses Apple’s SwiftData framework for persistent local storage. The following data types are stored exclusively on your device:

• Session transcripts -text transcriptions of your practice sessions
• Pace data -words-per-minute measurements and pace trends over time
• Filler word counts -detected filler words and their frequency per session
• Flashcard decks -custom decks you create for spoken practice
• Analytics -session scores, streaks, and performance history
• Settings -pace targets, filler word preferences, and display options

This data is never transmitted to any server, API, or third-party service.

3. Microphone Access

Pronouncy requires microphone access to provide real-time speech coaching:

• The microphone is used exclusively for on-device speech recognition via Apple’s Speech framework
• Audio is processed in real-time and NOT recorded or stored
• No audio files are created, cached, or uploaded at any time
• The microphone is only active during practice sessions -never in the background
• iOS displays a microphone indicator (orange dot) whenever the microphone is in use
• You can revoke microphone access at any time in iOS Settings > Pronouncy

Your voice is processed entirely on your device and never leaves it.

4. iCloud Sync (Optional)

Pronouncy offers optional iCloud synchronization for all users. If you enable iCloud sync:

• Your data is stored in your personal iCloud account, not on our servers
• Data is encrypted by Apple both in transit and at rest
• Access is controlled exclusively by your Apple ID
• You can disable iCloud sync at any time in the app or iOS Settings
• Synced data allows you to access your information across multiple Apple devices
• iCloud data is subject to Apple’s Privacy Policy

We have no access to your iCloud data. Apple manages all cloud infrastructure.

5. App Permissions

Pronouncy may request the following permissions. All can be revoked at any time in iOS Settings:

• Microphone -required for on-device speech recognition. Audio is processed in real-time and never recorded or stored. The microphone is only active during practice sessions.
• iCloud -optional, used for cross-device sync. Data goes to your personal iCloud account only.
• Notifications -optional, used for practice reminders and streak alerts. All notifications are scheduled locally.

You can review and revoke any permission at any time in iOS Settings > Pronouncy.

6. On-Device Speech Recognition

Pronouncy uses Apple’s Speech framework for speech recognition, which runs entirely on your device:

• All speech-to-text processing happens locally using Apple’s on-device speech recognition engine
• Audio never leaves your device -it is processed in real-time and immediately discarded
• No transcripts, audio snippets, or voice data are sent to any server (including Apple’s)
• Pace calculations (words per minute) are computed locally from the recognized text
• Filler word detection is performed locally by matching recognized words against a local dictionary

Apple’s on-device speech recognition requires no internet connection and processes all audio locally on the device’s neural engine.

7. Purchase & Payment Processing

Pronouncy offers an optional one-time Pro upgrade (€9.99) that unlocks AI-generated practice prompts and the Smart Prompter:

• One-time Pro upgrade via the App Store

All payment processing is handled exclusively through Apple’s StoreKit 2 framework:

• Apple processes all billing, payments, and refunds
• We never see or store your payment information, credit card details, or Apple ID
• Purchase status is verified locally via StoreKit 2 -no server-side receipt validation
• Payment data is subject to Apple’s Privacy Policy

8. No Network Transmission

Pronouncy does not include any of the following:

• No backend servers or APIs
• No analytics SDKs (Google Analytics, Firebase Analytics, Mixpanel, etc.)
• No advertising networks or ad SDKs
• No tracking pixels or web beacons
• No crash reporting services (Crashlytics, Sentry, etc.)
• No A/B testing frameworks
• No social media SDKs

The only network activity that may occur is optional iCloud synchronization (handled entirely by Apple’s CloudKit framework).

9. Third-Party Services

Pronouncy does not integrate any third-party services that collect user data. The only Apple frameworks used are:

• Speech -for on-device speech recognition (processed locally, no network activity)
• CloudKit -for optional iCloud sync (data stored in your iCloud account)
• StoreKit 2 -for in-app purchase management (handled by Apple)

Apple acts as a data processor for CloudKit data under the Apple Developer Program License Agreement (DPLA), which includes data processing provisions compliant with GDPR Article 28.

10. Data Security

Your data is protected by multiple layers of Apple’s security architecture:

• iOS Sandboxing -the app’s data container is isolated from all other apps
• Device Encryption -all data at rest is protected by your device’s hardware encryption
• SwiftData Secure Storage -data is stored in Apple’s modern persistence framework with built-in security
• No Network Exposure -since data never leaves your device (except via optional iCloud), there is no attack surface for network-based threats

11. Your Rights (GDPR)

Under the General Data Protection Regulation (GDPR), you have the following rights regarding your personal data:

• Right to Access -you can view all your data directly within the app at any time
• Right to Rectification -you can edit any data directly within the app
• Right to Erasure -you can delete individual sessions, flashcard decks, or all data via the app’s settings. Uninstalling the app permanently removes all local data.
• Right to Data Portability -your data is stored locally and accessible on your device
• Right to Object -since we do not process your data, there is nothing to object to
• Right to Restrict Processing -all processing occurs locally on your device and can be stopped by closing or uninstalling the app
• Right to Withdraw Consent -you can revoke any granted permissions (microphone, notifications, iCloud) at any time in iOS Settings

Because Pronouncy does not collect or transmit personal data, most GDPR provisions are satisfied by design.

Right to Lodge a Complaint -You have the right to lodge a complaint with a data protection supervisory authority. The competent authority is:

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Str 22, 7. OG
20459 Hamburg
Email: mailbox@datenschutz.hamburg.de
Website: https://datenschutz.hamburg.de

12. Data Retention

• Data remains on your device for as long as the app is installed
• Uninstalling Pronouncy permanently deletes all locally stored data
• If iCloud sync is enabled, data persists in your iCloud account until you manually delete it via iCloud Settings

13. Children’s Privacy (COPPA)

Pronouncy complies with the Children’s Online Privacy Protection Act (COPPA):

• We do not collect data from any user, including children under the age of 13
• The app has no online interactions, user accounts, or registration
• There is no advertising of any kind within the app

Because Pronouncy does not collect any personal information from anyone, it is inherently compliant with COPPA requirements.

14. International Data Transfers

• Pronouncy does not transfer any data internationally, as all data is stored locally on your device
• If iCloud sync is enabled, Apple may store your data in data centers located in various countries. These transfers are governed by Apple’s Standard Contractual Clauses (SCCs) and the Apple Developer Program License Agreement

15. California Privacy Rights (CCPA)

Under the California Consumer Privacy Act (CCPA), California residents have additional rights. Pronouncy’s position:

• We do not sell personal information to any third party
• We do not share personal information for cross-context behavioral advertising
• We do not collect personal information as defined by the CCPA

Because Pronouncy does not collect, store, or transmit personal information to any server, CCPA requirements are satisfied by design.

16. Changes to Privacy Policy

• Any updates to this Privacy Policy will be posted within the app and on this page
• Significant changes will be highlighted in App Store release notes
• Previous versions of this policy are available upon request by emailing info@jgeider.com

17. Contact Information

If you have any questions about this Privacy Policy, please contact us:

• Email: info@jgeider.com
• Response time: within 48 hours

18. Verification

You can independently verify our privacy claims using the following methods:

• iOS Network Usage -check Settings > Cellular to confirm Pronouncy uses no cellular data (unless iCloud sync is enabled)
• Privacy Indicators -iOS displays an orange microphone indicator when the microphone is in use; Pronouncy only triggers this during active practice sessions
• Network Monitoring Tools -use any network proxy or monitoring tool to verify that Pronouncy makes no outbound connections (except optional iCloud)
• App Privacy Report -check Settings > Privacy & Security > App Privacy Report to review Pronouncy’s data and sensor access

19. Legal Basis for Processing (GDPR)

Where applicable under GDPR, our legal bases for processing data are:

• Consent -you provide explicit consent when granting app permissions (microphone, notifications, iCloud)
• Contract -processing is necessary to provide the app’s functionality that you have requested (speech recognition, pace tracking, filler word detection, session analytics)
• Legitimate Interest -on-device processing to improve app performance and personalize your experience, with no impact on your privacy

20. Automated Decision-Making

Pronouncy does not perform automated decision-making or profiling as defined by GDPR Article 22. Pace calculations and filler word detection are deterministic computations based on recognized speech and do not constitute profiling. All calculations occur entirely on your device and do not produce legal or similarly significant effects.

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Summary: Your voice is processed on your device and never stored. We don’t collect, transmit, or sell your data. Period.