Privacy and your data
Written so it can be given to a customer who asks "what do you know about me?", and so a support agent can answer accurately without guessing.
No account, no sign-up
Verbie has no login, no registration, no email address and no password. There is nothing to sign in to, and Verbie does not know the customer's name or email address.
To keep progress and daily goals consistent, Verbie generates a random anonymous identifier the first time it runs and stores it in the device keychain. It is a random value, not derived from the customer, the device's serial number, or their Apple Account.
Who is responsible for your data
Verbie is operated by DJB Consulting, a sole proprietorship registered in the Netherlands. For the purposes of the GDPR, DJB Consulting is the data controller.
| Organisation | DJB Consulting |
| Address | Weteringschans 165 C, 1017 XD Amsterdam, Netherlands |
| Chamber of Commerce (KvK) | 42130315 |
| VAT | NL005519447B11 |
| Privacy contact | djb-consulting-j2a15a@inbox.chatops.encoreinteractive.ca |
Write to the privacy contact for any request about your data — a copy of it, a correction, or its deletion. If you are unhappy with the response, you have the right to complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens.
What stays on the device only
| Data | Notes |
|---|---|
| Bookmarks | All saved verbs, adjectives, sentences, words, numbers and phrases |
| Learning progress | Which questions were answered, whether correctly, how long each took, and when each is next due for review |
| Settings | Practice levels, voice, voice speed, speaker gap, automatic speaker mode |
| Voice recordings | The customer's own recordings from the Speaker activities |
| Downloaded audio | Cached recordings, in Settings → Storage |
None of this is uploaded. It is included in an iCloud or encrypted local device backup, which is how it moves to a replacement phone.
Voice recordings specifically: only the most recent recording is kept, it lives in temporary storage, it is overwritten by the next recording, and it is never sent anywhere. Verbie does no speech recognition and no pronunciation scoring.
What is sent to Verbie's servers
| Data | Why | What goes with it |
|---|---|---|
| XP, streak, last practice date | So progress survives a reinstall | The anonymous identifier |
| Daily goal requests and completions | To issue one goal a day and record whether it was met | The anonymous identifier, the practice levels requested, the quiz result |
| Free preview time used | To apply the 2-hour preview consistently across the customer's devices | An App Store transaction identifier from Apple |
| Text typed into Translate | To translate it and to generate spoken audio | The anonymous identifier |
| Translation history | So your past translations and saved phrases are still there next time | The anonymous identifier |
| Content problem reports | So the team can fix a bad sentence or recording | The question ID, level, category, the problem type, the app version, and the question's own content |
| Your device's IP address | Recorded in the server's request log to keep the service secure — to spot and stop abuse, misuse of the paid translation service, and attempts to break into the admin pages | The time of the request, which part of the service was called, and whether it succeeded. It is not stored together with the anonymous identifier |
Nothing here includes a name, an email address, contacts, location, photos, or the customer's voice.
An IP address is assigned by an internet or mobile provider, not by Verbie, and on a mobile network it is usually shared by many people and changes often. Verbie uses it only to keep the service running safely: never to build a profile, never for analytics or advertising, and it is never matched up with a customer's translations, progress or membership.
Who else processes your data
Verbie's servers run on Amazon Web Services in the eu-central-1 (Frankfurt) region, so records stay within the EU. Two other services receive text in order to do their job:
| Service | What it receives | Why |
|---|---|---|
| Amazon Web Services (Frankfurt, EU) | Everything listed above — it is where Verbie's servers and databases run | Hosting |
| Google Cloud Translation | The text typed into Translate, and its language | To translate it |
| ElevenLabs | The Dutch or English text that needs to be spoken | To generate the spoken recording |
Neither Google nor ElevenLabs receives the anonymous identifier, so neither can connect a piece of text to a particular customer. Apple receives nothing from Verbie beyond the transaction identifier used to check whether a membership is active.
There is no advertising network, no analytics service and no data broker in this list, and there never has been.
How long data is kept
| Data | Kept for |
|---|---|
| Translation history | Until you delete the entry, or until the whole record is deleted on request |
| XP, streak, daily goals | Until deleted on request |
| Membership and preview time | Until deleted on request; some purchase records are kept longer where Dutch tax law requires it |
| Content problem reports | Until deleted on request. These carry no identifier, so they cannot be traced back to a customer |
| Generated audio | Kept indefinitely. It is shared between all customers and contains nothing personal |
| Server access logs (IP addresses) | 14 days, then deleted automatically |
| Application logs on the server | 30 days, then deleted automatically |
Verbie does not put an automatic expiry date on the records above: they are kept for as long as the app is in use, and removed when a customer asks. The two log rows are the exception — those delete themselves on the schedule shown, because a security log only needs to be recent enough to investigate a problem. Voice recordings are the exception in the other direction: they never leave the device at all, and each one overwrites the last.
What Apple handles, not Verbie
Payment for the membership goes entirely through the App Store. Verbie never sees card details, billing address, or the customer's Apple Account email — only whether an active membership exists.
Permissions Verbie asks for
| Permission | Why | If declined |
|---|---|---|
| Microphone | Recording the customer's voice in the Speaker activities | Everything else works; only recording is unavailable |
Verbie does not request contacts, location, photos, calendar, or notifications.
Deleting data
- Bookmarks and translations — remove individually (swipe to delete), or delete the app to remove all device-side data.
- Cached audio — Settings → Storage → Clear Audio Cache.
- Server-side progress — there is no in-app control for this yet. Write to the privacy contact above and it will be deleted. Records are found by the anonymous identifier held on the device, so the request has to come from the device that holds it — please send it before deleting the app.
Your rights
Under the GDPR you can ask for a copy of the data Verbie holds about you, ask for it to be corrected, ask for it to be deleted, ask for it in a portable form, or object to how it is used. Write to the privacy contact above. There is no charge, and you will get an answer within one month.
One note on the security log: IP addresses are kept on the basis of Verbie's legitimate interest in keeping the service secure, and the log has no customer identifier in it, so there is no way to search it for one person's entries. It deletes itself after 14 days, which is sooner than a request could be answered.
For support: requests for deletion, access or portability are not something to answer at the desk — pass them to the privacy contact. Do not promise a deletion timeline beyond the one month the GDPR allows.
For support: the anonymous identifier is held in the device keychain, and keychain entries generally survive deleting an app. A reinstall on the same device therefore usually re-attaches the same identifier, and the customer's XP, streak and translation history come back with it. Never tell a customer that reinstalling deletes their server-side data, and do not promise a deletion timeline — escalate the request.
Answers to common privacy questions
"Do you record me?" Only when the customer taps Record, and only on their own device. The recording never leaves the phone and is overwritten by the next one.
"Is my typing in Translate stored?" Yes. The text is sent to Verbie's servers to be translated and spoken, and the translation is kept there so the history is available next time. It is tied only to the anonymous identifier, never to a name or email address. Deleting an entry in the history sheet deletes it from the server too.
"Can you see my quiz answers?" Individual answers stay on the device. Only the totals — XP, streak, last practice date — and daily-goal outcomes are sent.
"Do you sell my data or run ads?" Verbie has no advertising and no third-party analytics or tracking SDKs.
"Can I move my data to a new phone?" Restore the new phone from an iCloud or encrypted local backup and everything comes across, including bookmarks. A fresh install on a new phone starts over: bookmarks are lost, because they live only on the old device. XP, streak and translation history are held on Verbie's servers, but they are reachable only through the anonymous identifier from the old device — so on a genuinely fresh install they do not come back either.