1. Controller
Company: SlowBud
Represented by: Alireza Taghizadeh
Email: [contact@lebenpass.com]
Website: https://lebenpass.com
This Privacy Policy applies to the Leben Pass mobile apps (Android & iOS) and the website lebenpass.com.
2. Data-Protection Contact
A data-protection officer has not yet been appointed.
For privacy inquiries, please contact: [privacy@lebenpass.com]
3. Data We Collect
We collect and process the following categories of personal data:
- Account data: email address, name (from Google or Apple sign-in), authentication tokens
- Study and usage data: learning progress, streaks, XP, hearts, FSRS status, preferences (language, translation, state, goals)
- Technical data: device model, operating system, IP address, app version, log files
- Payment metadata: transaction ID and plan details processed through Stripe (we do not store payment card information)
- Support communications: emails or messages you send to our team
4. Purpose and Legal Basis for Processing
| Purpose | Data Used | Legal Basis (GDPR Art. 6) |
|---|---|---|
| Account creation and login | Email, auth token | (b) Performance of contract |
| Learning progress and statistics | Usage data | (f) Legitimate interest |
| Premium payments | Stripe transaction data | (b) Performance of contract |
| Error tracking and app stability | Log data via Sentry | (f) Legitimate interest |
| Push notifications | Device token | (a) Consent |
| Marketing or promotions (if used) | Contact data | (a) Consent |
5. Third-Party Processors
5.1 Firebase (Google Ireland Ltd.)
- Purpose: hosting, authentication, database, analytics
- Data processed: user ID, email, IP address, usage statistics
- Location: EU and worldwide (Google cloud infrastructure)
- Privacy policy: https://firebase.google.com/support/privacy
5.2 Stripe Payments Europe Ltd.
- Purpose: payment processing for premium features
- Data processed: name, email, billing details, transaction ID
- Location: Ireland (EU) and global payment networks
- Privacy policy: https://stripe.com/privacy
5.3 Sentry GmbH
- Purpose: error and crash tracking
- Data processed: device information, stack traces, error logs
- Location: Germany (Frankfurt)
- Privacy policy: https://sentry.io/privacy
6. International Data Transfers
Some of our service providers may process data outside the EEA.
Such transfers are made only where adequate safeguards are in place, such as the EU Standard Contractual Clauses (SCCs).
7. Data Retention
- Account data is retained until you delete your account.
- Learning and usage data remain while your account is active.
- Payment records are kept as required by law (6 – 10 years).
- Analytics and log data are anonymized or deleted after months.
8. Your Rights Under the GDPR
You have the following rights:
- Access (Art. 15)
- Rectification (Art. 16)
- Erasure / Right to be forgotten (Art. 17)
- Restriction of processing (Art. 18)
- Data portability (Art. 20)
- Objection (Art. 21)
- Withdraw consent (Art. 7 para. 3)
To exercise any right, contact [privacy@lebenpass.com].
We may require proof of identity for security reasons.
9. Data Security
All transmissions use SSL/TLS encryption.
Data is stored on secure servers with restricted access.
Only authorized staff may access personal data as necessary for their duties.
10. Children’s Privacy
The app is not intended for children under 16 years of age.
If we become aware that we have collected data from a minor, we will delete it promptly.
11. Analytics and Advertising
If enabled, Firebase Analytics and advertising services may collect anonymous usage statistics.
We will ask for your consent before any such collection, and you can withdraw it at any time in the app settings.
12. App Permissions
The Leben Pass app may request access to:
- Internet (for content sync and updates)
- Push notifications
- Storage (for offline learning data)
- Audio (playback of lessons and pronunciations)
13. Data Processing Agreements
SlowBud has entered into Data Processing Agreements (DPAs) with Firebase (Google), Stripe, and Sentry in accordance with Article 28 GDPR.
14. Changes to This Privacy Policy
We may update this policy from time to time to reflect legal, technical, or business changes.
The current version will always be available in the app and on our website.
Material changes will be notified in-app or by email.
15. Supervisory Authority
If you believe your data protection rights have been violated, you may file a complaint with the competent supervisory authority in Germany, for example:
The State Commissioner for Data Protection and Freedom of Information of the federal state where SlowBud is registered.
16. Contact
SlowBud
Email: [privacy@lebenpass.com]
Website: https://lebenpass.com