This Privacy Policy explains how Cleverly Interactive ("we", "us", or "our") handles information in connection with the Tagalog Flow mobile application (the "App"). We built Tagalog Flow to be simple and privacy-respecting: the App has no user accounts, and we do not ask you for your name, email address, or any other personal details to use it.
We do not directly collect, sell, or rent your personal information. The App does, however, rely on a small number of trusted third-party services — namely Google AdMob (advertising) and RevenueCat (subscription and purchase management) — which may collect certain data as described below. This policy is written to meet the requirements of both the Google Play Store and the Apple App Store, as well as applicable privacy laws including the EU/UK GDPR and the California Consumer Privacy Act (CCPA/CPRA).
1. Summary at a glance
- No account required. You can use the App without registering or providing personal details.
- Learning progress stays on your device. Your lessons, streaks, XP, and badges are stored locally on your device.
- We show ads through Google AdMob, which may use device and usage data to serve and measure ads.
- We offer optional purchases (such as an ad-free or premium upgrade) managed by RevenueCat together with the Apple App Store and Google Play.
- We do not sell your personal information as that term is defined under U.S. state privacy laws.
2. Information we and our partners collect
2.1 Information you provide
Because there are no accounts, we do not collect names, email addresses, phone numbers, or similar identifiers from you. If you contact us for support by email, we will receive the information you choose to include in that message (such as your email address and the contents of your message) so we can respond.
2.2 Information stored on your device
Your learning data — including lesson progress, completed exercises, streaks, XP, badges, and in-app settings — is stored locally on your device. This information is not transmitted to us. Deleting the App will remove this locally stored data.
2.3 Information collected automatically by third parties
Our advertising and purchase partners may automatically collect certain information when you use the App. Depending on your device and settings, this may include:
- Device identifiers, such as the advertising identifier (Google Advertising ID on Android or Apple's IDFA on iOS) and app instance identifiers.
- Device and technical information, such as device model, operating system and version, language, region/coarse location inferred from IP, network information, and crash or diagnostic data.
- IP address.
- Usage and interaction data, such as ads shown, ad clicks, and general app activity used for advertising frequency capping, fraud prevention, and measurement.
- Purchase information, such as which product was purchased, transaction and receipt identifiers, subscription status, and a randomly generated anonymous app user ID. We do not receive or store your full payment card details — payments are processed by Apple or Google.
3. Third-party services we use
The App integrates the following third-party SDKs and services. Each is an independent data controller for the data it collects through its SDK, and each maintains its own privacy policy that we encourage you to review.
| Service | Purpose | Examples of data processed | Privacy policy |
|---|---|---|---|
| Google AdMob (Google LLC / Google Ireland Ltd.) | Displaying in-app advertising; ad measurement, frequency capping, and fraud prevention. | Advertising ID, IP address, device & OS info, ad interaction data, cookies and similar SDK identifiers. | policies.google.com/privacy · AdMob & data |
| RevenueCat, Inc. | Managing in-app purchases and subscriptions, validating receipts, and providing purchase analytics to us. | Anonymous app user ID, purchase/subscription history, transaction identifiers, device & OS info, IP address, country. | revenuecat.com/privacy |
| Apple App Store / Google Play | Processing payments and distributing the App. | Payment and transaction data processed directly by the platform under its own policy. | Apple · Google |
4. Cookies and similar technologies
The App does not use browser cookies in the traditional sense. However, our partners' SDKs may use cookies, mobile advertising identifiers, local storage, software development kits (SDKs), and similar technologies to operate, including to deliver and measure advertising, prevent fraud, and remember purchase status. In particular, Google AdMob may use these technologies to serve personalized or non-personalized ads as described in How Google uses information from sites or apps that use our services.
5. How information is used
- To provide, operate, and maintain the App and its learning features.
- To display advertising and to measure and improve ad performance (via AdMob).
- To process and restore in-app purchases and subscriptions, and to prevent purchase fraud (via RevenueCat and the app stores).
- To understand aggregate, anonymized usage so we can improve the App.
- To detect, prevent, and address technical issues, abuse, or security incidents.
- To comply with legal obligations and enforce our terms.
6. Legal bases for processing (EEA/UK users)
Where the GDPR applies, we and our partners rely on the following legal bases: performance of a contract (to deliver the App and process purchases you request); consent (for personalized advertising and any non-essential tracking, where required — collected through a consent prompt such as a Google-certified consent management platform and Apple's App Tracking Transparency); and legitimate interests (to secure the App, prevent fraud, and serve non-personalized advertising and measurement).
7. Advertising choices and your controls
You have several ways to control how your data is used for advertising:
- Consent prompts. Where required by law, you will be asked to consent to personalized advertising. On iOS, you can allow or deny tracking through Apple's App Tracking Transparency prompt and in Settings → Privacy & Security → Tracking.
- Reset or limit your advertising ID. On Android, go to Settings → Google → Ads to reset or delete your advertising ID and opt out of ad personalization. On iOS, manage tracking in Settings → Privacy & Security.
- Google ad settings. Manage personalization across Google services at adssettings.google.com.
- Remove ads. Purchasing the optional premium / ad-free upgrade removes advertising from the App.
8. Sharing of information
We do not sell your personal information. Information is shared only with the third-party service providers listed in Section 3, who process it to provide their services, and as required to comply with the law, enforce our terms, or protect the rights, safety, and security of our users and the public. If our business is involved in a merger, acquisition, or asset sale, information may be transferred as part of that transaction, subject to this policy.
9. International data transfers
Our partners may process and store information in countries other than your own, including the United States. Where such transfers occur, the relevant provider implements safeguards (such as the EU Standard Contractual Clauses) as described in their respective privacy policies.
10. Data retention
Learning data stored on your device remains until you delete it or uninstall the App. Data processed by our partners is retained according to their own retention schedules, described in their privacy policies. Support emails are kept only as long as needed to assist you and to keep reasonable records.
11. Your privacy rights
Depending on where you live, you may have rights to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to withdraw consent. California residents have rights under the CCPA/CPRA, including the right to know, delete, and correct personal information and to opt out of the "sale" or "sharing" of personal information; we do not sell personal information and honor applicable opt-out preference signals where required.
Because the App has no accounts and we hold little or no information about you directly, many requests are best exercised through your device settings or directly with the relevant partner. You can also contact us using the details in Section 14, and we will respond as required by applicable law. We will not discriminate against you for exercising your rights.
12. Children's privacy
The App is not directed to children under the age of 13 (or the equivalent minimum age in your jurisdiction), and we do not knowingly collect personal information from children. The App is rated and intended for a general audience. If you believe a child has provided personal information, please contact us so we can take appropriate action. We instruct our advertising partner to serve only ads appropriate for the App's content rating.
13. Data security
We and our partners use reasonable technical and organizational measures designed to protect information, including encryption in transit. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
14. Contact us
If you have questions or requests regarding this Privacy Policy or your information, contact us at:
Cleverly Interactive
Email: support@cleverly.no
15. Changes to this policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, provide additional notice. Your continued use of the App after an update means you accept the revised policy.