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Privacy Policy

Last updated: September 12, 2026

On this page

  1. Introduction
  2. Data controller
  3. Data we collect
  4. How we use your data
  5. Legal basis
  6. Data retention
  7. Sharing and third parties
  8. International data transfers
  9. Data security
  10. Your rights under GDPR
  11. Your rights under Turkish law (KVKK)
  12. Children's privacy
  13. Deleting your account and data
  14. Changes to this policy
  15. Contact

1. Introduction

This Privacy Policy explains what personal data is collected when you use the Lisanova mobile app ("the App"), how that data is processed, and what rights you have. Lisanova is a language-learning app designed for Turkish-speaking adults who want to learn English, Bosnian, or Spanish. By using the App, you agree to the practices described in this policy.

2. Data Controller

The data controller responsible for your personal data under the EU General Data Protection Regulation ("GDPR") and Turkey's Personal Data Protection Law No. 6698 ("KVKK") is:

Nezih Dertsiz (independent developer) — Istanbul, Turkey
Email: nzhdrzts034@gmail.com

3. Data We Collect

Lisanova collects a limited amount of data, only what is needed to provide the service. The App does not use advertising networks or third-party analytics/tracking tools.

Data category Examples Purpose
Account data Email address, password (stored encrypted) Creating your account, signing in, and authentication
Learning and usage data Completed lessons, XP, daily streak, CEFR level, chosen target language Tracking your progress and personalizing your lesson flow
Speech and audio data Microphone recordings made during speaking practice, and their transcripts Generating AI conversation turns and pronunciation feedback
Device and technical data Operating system, app version, error logs Diagnosing issues and keeping the App running correctly
The App shows no ads, offers no in-app purchases, and does not use third-party marketing or analytics SDKs.

4. How We Use Your Data

  • Creating your account and keeping your sign-in secure
  • Adapting lesson content and difficulty to your progress
  • Powering AI-driven conversation practice and pronunciation feedback
  • Calculating your spaced-repetition (SRS) review schedule
  • Troubleshooting technical issues and improving the App
  • Meeting our legal obligations

5. Legal Basis

Your data is processed under KVKK Article 5 and GDPR Article 6, based on the following legal grounds:

  • Your explicit consent (for example, for microphone access and processing of audio data)
  • Performance of the service agreement between you and us (creating an account and running the App)
  • Legitimate interest (keeping the service secure and functional)

6. Data Retention

Your data is kept for as long as your account is active. When you delete your account, your account and usage data are permanently deleted within a reasonable period — no later than 30 days, including removal from backups. Data we are legally required to retain may be kept for the period required by applicable law.

7. Sharing and Third Parties

We do not sell your data or share it with third parties for marketing purposes. To operate the App, limited, purpose-specific data is shared with the following service providers:

  • Supabase — authentication, database, and file storage infrastructure (data is hosted in the EU, Frankfurt / eu-central-1 region)
  • DeepSeek API — text generation for conversation practice and lesson content (your conversation input is sent for processing)
  • ElevenLabs — audio generation and pronunciation feedback
  • Expo / EAS — building and distributing the App (this provider does not access your user data)

These providers process data solely on Lisanova's behalf, for the stated purposes, and are subject to their own privacy policies.

8. International Data Transfers

Your core data is hosted within the European Union (Frankfurt, eu-central-1). During speaking practice, some data may be transferred outside the EU for processing by providers such as DeepSeek and ElevenLabs in order to deliver the service. Where applicable, such transfers are safeguarded through standard contractual clauses or equivalent protection mechanisms.

9. Data Security

Your data is encrypted in transit using TLS (Transport Layer Security). Access is restricted to the systems required to operate the service. That said, no method of transmission over the internet is ever 100% secure.

10. Your Rights Under GDPR

If you are located in the European Economic Area, you have the following rights:

  • Right of access (Article 15)
  • Right to rectification (Article 16)
  • Right to erasure / "right to be forgotten" (Article 17)
  • Right to restriction of processing (Article 18)
  • Right to data portability (Article 20)
  • Right to object (Article 21)
  • Right to withdraw consent at any time
  • Right to lodge a complaint with your local data protection authority

11. Your Rights Under Turkish Law (KVKK)

Under Article 11 of KVKK (Law No. 6698), you have the right to:

  • Learn whether your personal data is being processed
  • Request information about it if it has been processed
  • Learn the purpose of processing and whether data is used accordingly
  • Know the third parties to whom data is transferred, domestically or abroad
  • Request correction of incomplete or inaccurate data
  • Request deletion or destruction of your data
  • Request that corrections or deletions be notified to third parties the data was transferred to
  • Object to a result that is to your detriment arising solely from automated analysis of your data
  • Claim compensation for damages arising from unlawful processing

To exercise these rights, contact us at nzhdrzts034@gmail.com.

12. Children's Privacy

Lisanova is designed for adult users and does not knowingly collect data from individuals under 18. If you believe we have collected data from a child, please contact us; any such data will be deleted promptly upon verification.

13. Deleting Your Account and Data

You can permanently delete your account and all associated data from within the App via Settings → Delete My Account. This action cannot be undone. If you no longer have access to the App, you can request deletion by emailing nzhdrzts034@gmail.com.

14. Changes to This Policy

We may update this policy from time to time. If we make material changes, the updated policy will be posted on this page and the "last updated" date at the top will be revised.

15. Contact

For privacy questions: nzhdrzts034@gmail.com

© 2026 Nezih Dertsiz. All rights reserved.

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