# Privacy

Last updated 20 August 2026.

This policy covers two things: the Koinori app for iOS, and this website (the waitlist). Koinori is
built to keep your data yours: your learning data stays on your device, and the few things that do
leave it are named below. The website only handles what you choose to share to join the waitlist.

## The Koinori app (iOS)

Applies to Koinori for iPhone and iPad.

### In short

The app runs on your device. The cards you make, your review history, and your settings live on your
iPhone or iPad, and if you turn on iCloud sync they also live in your own private iCloud account.
Your learning data never reaches our servers. Two narrow things do leave your device: your purchase
information, which goes to Apple and to RevenueCat, and, only if you switch it on, the messages you
write to the AI tutor, which go to Anthropic through a server of ours. Both are set out below. We use
no advertising, we do not track you across other apps or websites, and we do not sell or share your
information. There is no account system and no sign-up.

### What the app holds

Everything the app stores is generated by your own use: the flashcards you create or mine, your
review history (an append-only log of each review, its time, rating, duration, and the scheduling
values derived from it), your reading and lesson progress, and your settings. The app also ships with
a bundled, read-only dictionary and graded-content store: the same reference data for everyone,
holding none of your information.

We do not collect your name, email, phone number, contacts, location, advertising identifiers,
browsing history, health data, or payment details. There is no account. The two exceptions to the
on-device rule, purchases and the AI tutor, are set out below, and neither of them tells us who you
are.

### Where your data lives

Your cards, review logs, progress, and settings are stored on your device. If you enable iCloud sync,
Apple's CloudKit syncs them to your own private iCloud so they are available across your devices,
governed by Apple's iCloud terms. We cannot read that data: we have no access to your iCloud account,
and you control sync in iOS Settings. We do run one server of our own, the AI tutor proxy described
below, but your cards, review logs, progress and settings never go near it.

### Purchases

If you buy a subscription or a one-time purchase, the transaction is handled by Apple through the App
Store and StoreKit. We receive only the purchase and entitlement information needed to unlock what
you bought, and never your payment-card details. Apple's handling of the transaction is covered by
Apple's privacy policy.

App Store builds of the app also pass that purchase information to RevenueCat, a subscription
analytics service we use to see how many people subscribe and stay subscribed. RevenueCat runs in
observer mode: our own code completes the purchase and decides what you are entitled to, and
RevenueCat only observes the result. It receives your purchase history for the two purposes we
declare on the App Store, app functionality and analytics. We set no customer identifier, so
RevenueCat sees an anonymous install rather than a person: no name, no email address, no Apple ID.
None of this is advertising, and none of it follows you into other companies' apps or websites.

### The AI tutor

Koinori includes an optional AI tutor you can practise with. It is off until you turn it on: nothing
in this section happens until you have read the consent screen in the app and agreed, and it stops
the moment you withdraw in Settings, under Tutor. On a device with Apple Intelligence the tutor can
also answer on-device, with nothing leaving your iPhone or iPad at all.

What leaves your device. The messages you write to your tutor, and the conversation so far, so your
tutor can follow the thread.

Where they go. To our proxy, a small server we run on Supabase in London, and from there to Claude,
an AI service run by Anthropic, a company in the United States. Anthropic is our sub-processor for
this feature: it uses your messages to write your tutor's reply, and not to train its models. We do
not store your conversations on our server; they are passed along and not kept. Because your messages
are processed outside the UK, this is an international transfer, and we are finalising the detail of
the safeguards for it. We will set them out here once they are settled.

What reaches us but never reaches Anthropic. An anonymous install code, so we can count your messages
against your daily allowance. Your copy of the app made it up at random on your device: it is not
your Apple ID and it is not your name. And your subscription receipt, so we know the tutor is
included in what you bought; it says what was purchased, never who purchased it. Both of these stop
at Koinori. Claude is only ever sent your words.

What we keep on that server. The anonymous install code, the Apple-issued attestation that proves it
belongs to a genuine copy of Koinori, per-day counts of how many messages it has sent and how much
text they came to, and a record of when it ran out of allowance, so the allowance can be enforced and
we can tell whether it is set at a sensible level. No message content, ever. When the app asks our
server to confirm it is a genuine copy of Koinori, we also briefly hold a scrambled, one-way form of
the network address the request came from, to limit abuse; the address itself is never stored. We
keep none of it longer than we need it, and we will publish the exact retention periods here once the
deletion job that enforces them is running.

What stays on your device. Your name and email address, which Koinori never asks for and your tutor
is never told. Your learning history: your cards, your reviews and your progress. Your tutor
transcripts are also kept on your device, and sync through your own private iCloud if you have iCloud
sync on.

### No advertising, and no tracking across apps

The app contains no advertising, no advertising identifiers, and no third-party tracking. We do not
build advertising profiles and do not track you across other apps or websites. Apart from the
purchase information described above, nothing reports how you use the app: no analytics SDK, no
telemetry, and none of your learning data leaving the device.

So there is exactly one analytics purpose we declare on the App Store, and it is RevenueCat's
subscription figures. That is the whole of it. Your tutor conversations are not read for analytics.
If we ever add more, we will update this policy and the App Store privacy labels before that version
ships, keep it minimal and aggregate, and make anything beyond that opt-in.

### Children

Koinori is a language-learning app for a general audience. It is not directed at young children. It
contains no behavioural advertising and no third-party tracking, and there is no messaging between
users and no social features: the AI tutor is a conversation with a machine, not with other people.
There is no account and we never ask who you are, so we do not knowingly collect personal information
from children.

If you are setting the app up for a child, the section on the AI tutor above is the part to read: it
is switched off until someone turns it on, and while it is on the messages written to it leave the
device.

### Deleting your data

You are always in control. In the app's Settings you can reset your scheduling, or erase every card
and its review history. Deleting the app removes the local data; to remove the iCloud copy, delete
the app's iCloud data in iOS Settings or turn off iCloud for Koinori. We hold no separate copy of
your cards, reviews or progress to delete, because they never reach us.

If you have used the AI tutor, our server holds the anonymous install code and its per-day message
counts, and no message content. Because that code is anonymous and there is nothing linking it to
you, neither you nor we can look it up, so there is nothing there for us to find and delete on
request. Turning the tutor off in Settings stops anything further being sent, and deleting the app
leaves the code behind with nothing attached to it.

### Security and your rights

Local data is protected by your device security (passcode, Face ID or Touch ID, and iOS data
protection); synced data by Apple's iCloud security in your own account. Under UK GDPR and similar
laws you have rights over your personal data (access, correction, deletion). In practice, because
your cards, reviews and progress stay on your device and in your own iCloud and we hold no copy of
them, you exercise these directly in the app and in iOS. For the AI tutor the honest limit is the one
stated above: we deliberately send nothing that identifies you, so we cannot pick your messages out
at Anthropic on your behalf. That is the price of sending them anonymously. You may also complain to
your data protection regulator; in the UK that is the Information Commissioner's Office (ICO),
ico.org.uk.

## This website (the waitlist)

### What we collect

If you join the waitlist, we collect your email address and your consent to be emailed. If you fill
in the optional questionnaire, we collect your answers. The questionnaire is answered anonymously by
default. You may choose to add your email there too, but only if you tick the box asking us to, in
which case we link your answers to that email so we can follow up.

Alongside a waitlist signup we also store where it came from: the page and the button you signed up
from, and any campaign parameters (the utm_ values) carried in the link you arrived on. We use it to
learn which pages and which links actually bring people in. It is read from the form you submitted
and nothing else: no cookies, no third-party tracking, and nothing stored on or read from your
device.

### Why, and our lawful basis

We use your email solely to send you news about Koinori, including an early access invite and launch
updates. Our lawful basis is your consent, which you give by ticking the box and confirming via the
link we email you (double opt-in). Survey answers are used to decide what to build. If you added your
email to the questionnaire and ticked the follow-up box, our lawful basis for contacting you about
your answers is that separate consent, and we keep a record of exactly what you agreed to.

### Where your data lives

Data is stored in a Supabase database hosted in the EU (Stockholm). We send confirmation and update
emails through Resend. These are our only processors for this page. We do not sell or share your
data, and there is no advertising or third-party tracking on this site.

### Retention

We keep your email until you ask us to delete it, or until we wind the waitlist down after launch.
Every email we send includes an unsubscribe link, and one click stops all further email. If you
unsubscribe we keep a minimal record of it, your address and the date, purely so that a later signup
or import never puts you back on the list. Ask us to delete that record and we will.

### Your rights

You can ask us to access, correct, or delete your data, or to stop emailing you, at any time. Email
hello@koinori.com and we will action it. If you are in the UK or EU, you also have the right to
complain to your data protection authority.

## Who we are, and contact

Koinori is built by Frazzled Productions, the data controller for any personal data described above.
For any privacy question, or to access, correct, or delete your data, email hello@koinori.com and we
will action it.