Privacy Policy

Last updated: [[DATE of publication]] (draft of 19 Oct 2026). Translation of the German original.

1. Controller

The controller responsible for data processing in connection with the app “Mimhar” and this website is:

[[COMPANY NAME]] [[LEGAL FORM]]
[[ADDRESS]]
Email: [[EMAIL]]
Phone: [[PHONE]]

Further details can be found in the imprint. Data protection officer: [[if appointed: name and contact – otherwise delete this sentence]]

2. In short

• Mimhar does not require a user account.
• Learning content, images and audio are included in the app.
• The app does not transmit your progress or usage data to us.
• The app uses no advertising, analytics or tracking services.
• This website uses no cookies, no analytics or tracking services, and no external fonts or content.

3. The Mimhar app

3.1 Data stored locally

Your learning progress, review cards, learning statistics, language, display options and audio ratings are stored only locally on your device. We do not receive this data and have no access to it.

3.2 Widgets (iOS)

For the widgets, your language, streak, recent learning days and learning words are shared locally between the app and the widget extension on your device. This data does not leave your device in the process.

3.3 Copy function

If you trigger the copy function for audio ratings yourself, the ratings are copied to your device’s clipboard. They only reach other people or services once you pass them on yourself.

3.4 Resetting and backups

In the “Profile” tab you can reset your learning progress. Your language, transliteration setting, introduction status and audio ratings are kept. Device backups and their restoration depend on your device settings and the terms of the device manufacturer.

3.5 Permissions

The app does not use the microphone and does not need any special permissions. Audio is only played back.

3.6 App stores

If you download the app through the Apple App Store or Google Play, the respective operator processes data under its own responsibility and according to its own privacy terms. We have no influence on this.

4. This website

4.1 Hosting and server log files

The website is hosted on Cloudflare Pages; domain name resolution (DNS) is also handled by Cloudflare. The provider is Cloudflare, Inc., USA ([[address of the contracting entity according to the Cloudflare data processing agreement]]). Cloudflare delivers the pages through a worldwide network, so processing may also take place on servers outside the EU. When you open a page, Cloudflare processes technically necessary connection data on our behalf, usually: IP address, date and time of the request, the page/file requested, amount of data transferred, status code, and browser type and version (user agent), possibly the previously visited page (referrer).

The purpose is to deliver the website and to keep it secure and stable. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in secure and trouble-free operation). Storage time depends on Cloudflare: [[retention period of log files according to Cloudflare documentation]].

A data processing agreement under Art. 28 GDPR is in place with Cloudflare. For transfers to the USA, Cloudflare states that it relies on the EU-US Data Privacy Framework (adequacy decision of the European Commission under Art. 45 GDPR) and, in addition, on standard contractual clauses. [[confirm before publication: data processing agreement concluded in the Cloudflare account; certification checked on dataprivacyframework.gov]]

4.2 No cookies, no third-party content

This website sets no cookies and stores no information in your browser. It embeds no analytics, advertising or social media services and loads no fonts, scripts or images from third-party servers. A consent prompt (“cookie banner”) is therefore not needed.

4.3 Contact by email

If you write to us, we process your sender address and the content of your message in order to reply. The legal basis is Art. 6(1)(f) GDPR (handling enquiries) or, if the enquiry concerns a contract, point (b). We delete the data once the enquiry is settled and no statutory retention obligations apply: [[set deletion period]].

5. Recipients

We do not receive data from the app. For the website, Cloudflare as hosting provider (section 4.1) receives the connection data described there. Beyond that, we do not pass personal data on to third parties unless we are legally obliged to do so.

6. Your rights

As far as we process personal data about you (for example log files at the host or your email to us), you have the following rights under the GDPR:

• Access to the stored data (Art. 15 GDPR)
• Rectification of inaccurate data (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Notification of recipients about rectification, erasure or restriction (Art. 19 GDPR)
• Data portability (Art. 20 GDPR)
• Objection to processing based on legitimate interests (Art. 21 GDPR)

To exercise them, contact the email address given above. Data stored locally in the app exists only on your device; you can reset it in the profile or remove it by uninstalling the app from your device.

7. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. The supervisory authority responsible for us is: [[RESPONSIBLE SUPERVISORY AUTHORITY according to the company’s seat, with address]]

8. Changes

If the app or the website changes – for example through new features or services – we will update this policy. You can always find the current version at mimhar.app/en/privacy.