Privacy Policy

Summary

• PhrasePro stores learning status, favorites and settings on your device. There is no user account and no Curiovo server to which the app sends data.
• Google's consent request (User Messaging Platform, UMP) decides on advertising in the free version. Premium users see no ads, and the app does not call up this request for them on its own initiative.
• Data goes to Google in these cases in particular:
  • The app calls up Google's consent request or loads ads.
  • At startup and when you return to the app, the app queries Google Play for your purchases.
  • You use speech recognition.
  • Google Play displays the review dialog.
  • You delete a previously created Google Drive backup.
• The Google Drive backup is hidden as of version 3.3.1. You can still delete an existing backup. For older versions that Google Play distributed until 2 October 2026, there is a note at the end of section 05.

01 Data protection at a glance

Scope

This privacy policy applies to the website curiovo.de and to the Android app PhrasePro, which is offered via Google Play. Personal data is any information with which you can be identified directly or indirectly.

Controller

The controller is Curiovo, owner Marc Faber (contact details in section 03). You can find further provider information in the legal notice (Impressum, in German).

Your rights in brief

You can request access, rectification, erasure, restriction of processing and data portability, object to processing, withdraw consents with effect for the future and lodge a complaint with a data protection supervisory authority. Details are given in section 08, the right to object in section 09.

02 Website hosting

This website is hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. IONOS processes the data on our behalf as a hosting service provider.

When the website is accessed, the server processes in particular the IP address, browser type and version, operating system, referrer, time of the request and the requested resource, and may store them in server log files. This serves to provide the website in a secure, stable and efficient manner and to detect and fend off attacks.

• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in the secure and error-free operation of the website.
• Storage period: According to IONOS, the log files are kept for a maximum of eight weeks and then deleted automatically; the IP addresses are stored in them in anonymized form. Curiovo does not create its own copies and does not combine them with other data sources.
• Objection: possible as described in section 09.

Visitor statistics with IONOS WebAnalytics

For visitor statistics of the website, we use IONOS WebAnalytics, a service of our hosting provider. According to IONOS, WebAnalytics records the previously visited page (referrer), the page or file accessed, browser type and version, operating system, device type, the time of access and the IP address in anonymized form. According to IONOS, WebAnalytics obtains the data either via a counting pixel or from a log file; according to IONOS, WebAnalytics does not use cookies. According to IONOS, the IP address is transmitted when the page is accessed, anonymized immediately afterward and processed without any personal reference. This serves the statistical analysis and the technical improvement of the website.

• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in statistically analyzing the use of the website and improving the website technically.
• Recipients: IONOS SE as a processor.
• Storage period: According to IONOS, your IP address is anonymized immediately after transmission and then processed without any personal reference.
• Objection: possible as described in section 09.

03 General mandatory information

Controller

Curiovo
Owner: Marc Faber
Feuchtmayrstr. 4, 88250 Weingarten, Germany
Email: info@curiovo.de

Curiovo has not appointed a data protection officer because there is no legal obligation to do so. For data protection questions, contact the address given above.

Legal bases

We state the legal basis for each processing operation in sections 02 to 05; the overview in section 06 summarizes them. The following may apply:

• Consent: Art. 6(1)(a) GDPR. Insofar as information is stored on your device or read from it, additionally Section 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act).
• Contract or pre-contractual measures: Art. 6(1)(b) GDPR, for example for providing the app functions and the Premium purchase.
• Legal obligation: Art. 6(1)(c) GDPR.
• Legitimate interests: Art. 6(1)(f) GDPR. You can object to these processing operations (section 09).
• Storing and reading information on your device where this is strictly necessary for a function you have requested: Section 25(2) no. 2 TDDDG.

You can withdraw consent at any time with effect for the future. Processing carried out until the withdrawal remains lawful.

Recipients

Curiovo does not sell personal data. The recipients are the bodies and categories of recipients named in this policy:

• IONOS SE, Montabaur, as hosting service provider of the website, including the WebAnalytics visitor statistics, and as provider of the email mailbox info@curiovo.de, in each case as a processor (sections 02 and 04).
• Google: For users with their habitual residence in the European Economic Area (EEA) or Switzerland, according to Google's privacy policy this is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For users outside the EEA and Switzerland, including in the United Kingdom, Google LLC is responsible according to Google's privacy policy. Data may also be transferred to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google is a recipient for advertising (AdMob and UMP), for the Premium purchase and purchase reconciliation via Google Play, for the Google Play review dialog, for speech recognition, where applicable for text-to-speech, and for the Google Drive backup. The role Google has in each case is stated in the respective section. Google provides the statistics and reports of the Google Play Console for Curiovo (section 05).
• Advertising partners: With your consent in Google's form, the ad technology providers listed there (section 05, Advertising).

Transfers to third countries

In the case of the Google services, data may be transferred to the USA and to other countries outside the EEA in which Google or its service providers process data. For the USA, the European Commission adopted an adequacy decision on the EU-US Data Privacy Framework on 10 July 2023 (Implementing Decision (EU) 2023/1795, Art. 45 GDPR); according to its own statements, Google LLC is certified under it. Google bases transfers that are not covered by it, including transfers to other third countries, on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR). For AdMob, they are part of the Google Ads Controller-Controller Data Protection Terms. You can find a copy at the following links or obtain one from us on request.

• Information from the European Commission on the EU-US Data Privacy Framework
• Official website of the Data Privacy Framework (U.S. Department of Commerce) with list of participants
• Google's information on frameworks for data transfers
• Standard contractual clauses in the Google Ads Controller-Controller Data Protection Terms

No obligation to provide data

You are neither legally nor contractually obliged to provide personal data. PhrasePro works without a user account. If you do not provide certain data or permissions, only the functions concerned are unavailable:

• Without microphone permission, the pronunciation exercise is unavailable.
• Without notification permission, the reminders are unavailable.
• Without consent in Google's request, there is no personalized advertising. Google then delivers, where applicable, only non-personalized or limited ads or no ads at all. Functions that are tied to a rewarded video may then not be available.
• Without a purchase, the Premium content is unavailable.

No automated decision-making

Curiovo does not make any solely automated decisions within the meaning of Art. 22 GDPR that produce legal effects concerning you or similarly significantly affect you. The app calculates the scheduling of reviews and the assessment of your pronunciation locally on your device; they serve learning purposes only. Google describes in its own information how Google creates interest profiles for personalized advertising (see section 05, Advertising).

Data security

The website uses TLS encryption. The app's connections to Google services run in encrypted form via the respective Google interfaces. Nevertheless, data transmission over the internet, in particular by email, cannot be completely protected against access by third parties.

04 Data processing on this website

No cookies, no advertising services

The website does not set any cookies and does not integrate any advertising services. Section 02 describes the visitor statistics with IONOS WebAnalytics.

Contact by email

If you write to us by email, we process your address, your name (if provided) and the content of your message in order to handle the inquiry and answer follow-up questions. The website's contact form does not send anything to a server either: it opens your email program with a prepared message to info@curiovo.de.

If you write to us from PhrasePro (Settings → Help & FAQ → “Contact Support”), the app opens your email program with a prepared message to info@curiovo.de. It contains the app version and build number, the Android version with API level and the language of the app. If you report a mistake via “Report a mistake” on the detail page of a phrase, the app likewise opens your email program with a prepared message to info@curiovo.de; it contains the same information and additionally the number and the English text of this phrase. You see this information before sending and can delete it. If Android does not find an email app, PhrasePro displays the address instead.

• Legal basis: Art. 6(1)(b) GDPR if your inquiry is related to a contract, for example to the Premium purchase. Otherwise Art. 6(1)(f) GDPR; our legitimate interest lies in answering your inquiry.
• Recipients: IONOS SE as provider of the email mailbox (processor).
• Storage period: until the inquiry has been dealt with, thereafter only as long as statutory retention obligations require.

Locally embedded fonts

The website loads the fonts Archivo, Archivo Black, IBM Plex Mono and Inter from its own web server. No connection to Google Fonts is established in the process.

05 PhrasePro

PhrasePro is an Android app for learning English phrases (idioms). It works without a user account and without a server of Curiovo's own. The learning functions run on the device. The following sections describe which data is stored on the device and in which cases data leaves the device, including when you share something yourself.

Local app data

PhrasePro stores the following in the app storage of your device: learning progress, the review schedule with the history of your ratings (with dates), answer statistics per phrase, progress in the Learning Path, XP, level, streaks with Streak Freeze and bonus data, results of the Speed modes, favorites, settings (including the English level chosen at first launch and your daily goal), your notification settings, an interrupted exercise, counters for viewed ads and rewards as well as for the review dialog, your privacy choices and the local Premium status, and also the data for the widget (see “Home screen widget”). Curiovo does not receive this data.

If you connected Google Drive in an earlier version, the app also stores the email address, name and profile picture address of this Google Account until you disconnect the account under Backup & Sync (see “Google Drive backup”).

If Android backup is enabled on your device, Android may include PhrasePro's app data in the backup of your own Google Account and restore it on a new device. You control this in the Android settings; Curiovo has no access to this backup.

• Legal basis: Section 25(2) no. 2 TDDDG for storage on the device. Insofar as this constitutes processing by Curiovo, Art. 6(1)(b) GDPR (provision of the app).
• Storage period: until you delete the app data or uninstall the app. “Reset Progress” deletes only part of this data. The ways to delete the data are described on the Delete data page.

Local usage statistics and logs (versions before 3.3.2)

Versions before 3.3.2 could record local usage statistics with your consent and, independently of this, stored the history of the initial setup, your sharing actions, the scheduled and opened reminders and a random session identifier on the device. The app did not evaluate these entries and did not transmit them to Curiovo or third parties. As of version 3.3.2, PhrasePro records none of this and, at startup, deletes existing entries and a previously exported statistics file in the app storage.

Advertising with Google AdMob and Google's consent request (UMP)

The free version may show rewarded videos and full-screen ads (interstitial ads) via Google AdMob.

Process. After the initial setup and at every subsequent app start, PhrasePro first queries Google's User Messaging Platform (UMP). Where Google requires consent, in particular in the EEA, the United Kingdom and Switzerland, Google displays its own form as soon as you are on one of the app's main screens – not during a lesson or exercise. AdMob is only started and ads are only requested once the UMP permits this. Whether ads may be personalized depends solely on your choices in this form. If you decline there, Google may still deliver non-personalized or limited ads.

Regions without a consent request. In all regions, PhrasePro requests personalized ads only with your consent in Google's form. In regions in which Google does not ask for consent under European data protection law, Google does not display a form; there, PhrasePro requests only non-personalized ads, unless you have previously consented to personalized advertising in Google's form, for example in the EEA, the United Kingdom or Switzerland. For certain US states, Google may additionally display a separate privacy notice via the UMP.

Premium. With Premium, PhrasePro shows no ads, requests none and does not call up Google's consent request on its own initiative.

Processed data. According to Google, the Google Mobile Ads SDK processes in particular the IP address (and the approximate location derived from it), device and advertising identifiers such as the Android advertising ID and the app set ID, interactions with the app and with ads, and diagnostic and performance data. Google uses this data for delivering and measuring ads, for fraud prevention and, only with your consent, for personalized advertising. According to Google, even for non-personalized ads the SDK reads identifiers such as the advertising ID, for example for frequency capping, aggregated reporting and combating fraud. On Android devices with Privacy Sandbox, the SDK may also use topics that Android derives from your app usage (Topics) and data for measuring ads (Attribution). Google stores the choices you make in Google's form on your device. PhrasePro only requests ads that are rated for a general audience.

Role of Google. AdMob is subject to Google's data protection terms for advertising products, under which Google and the app provider each act as independent controllers. For processing by Google, Google's own information is authoritative:

• Data disclosure of the Google Mobile Ads SDK
• How Google uses data from apps that use Google services
• Google Ads Controller-Controller Data Protection Terms
• Google's privacy policy

Other advertising partners. If you have consented in Google's form, the advertising partners listed individually there (ad technology providers) may also receive, in addition to Google, data such as the advertising ID, the IP address and interactions with ads, for example in order to take part in bidding during delivery and to measure delivery. You can see the current list and the purposes for each partner in the form under Settings → Manage Privacy → “Google ad privacy choices”. Google provides information about these partners at Ad technology partners. Without your consent, PhrasePro only requests non-personalized ads.

Legal bases.

• Retrieval of Google's consent request: Art. 6(1)(f) GDPR. Our legitimate interest lies in obtaining consent in a legally compliant manner and observing the requirements applicable to your region.
• Storage of your choices: Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR (proof of consent) and Section 25(2) no. 2 TDDDG.
• Personalized advertising and the storing or reading of information on your device, insofar as Google asks for consent for this: your consent, Section 25(1) TDDDG and Art. 6(1)(a) GDPR. Without this consent, PhrasePro does not request personalized ads.
• Non-personalized or limited ads, including in regions without a consent request: Art. 6(1)(f) GDPR. Our legitimate interest lies in financing the free version.
• Reading identifiers on the device for non-personalized ads in regions without a consent request: PhrasePro does not obtain consent for this in these regions. The previous point (Art. 6(1)(f) GDPR) applies to the processing of the data read. Google's form only appears where Google requires consent (see “Process”). If you made your choices in the EEA, the United Kingdom or Switzerland and later use PhrasePro outside these regions, this point also applies: according to its own statements, Google then does not apply your choices when delivering ads. If you delete the advertising ID in the Android settings, where your device offers this (see “Your controls”), apps receive, according to Google, only zeros instead of the advertising ID. The SDK can still use other identifiers such as the app set ID.

Recipients and third country. Google Ireland Limited and Google LLC (USA), see section 03; with your consent, the advertising partners listed in Google's form.

Your controls.

• In PhrasePro under Settings → Manage Privacy → “Google ad privacy choices”. The button appears if Google provides privacy options for your region.
• “Reset Consent Preferences” in the same place resets your choices with Google on the device. Google then asks again at the next start, where this is provided for.
• In the Android settings, you can reset or delete the advertising ID. The menu path depends on the device, usually under “Google” or “Privacy” → “Ads”.
• You manage Topics and Attribution in the Android settings under “Privacy” → “Ad privacy” (name depends on the device).
• You manage your ad settings with Google in Google's “My Ad Center”.
• With Premium, there is no advertising at all.

Storage period. Curiovo does not store any advertising data. How long Google stores data is governed by Google's information.

Premium purchase and purchase reconciliation via Google Play

PhrasePro offers the one-time, non-consumable purchase “Premium” (product ID premium_lifetime) via Google Play. Google processes the payment. Curiovo does not receive any payment data such as credit card or account numbers.

Purchase reconciliation. At startup and every time you return to the app, PhrasePro uses the device's Google Play interface to query which purchases your Google Account has made in PhrasePro. This happens for all users, even without a purchase. In doing so, the app processes the product ID, purchase status and purchase and transaction identifiers from Google Play. The app acknowledges new purchases to Google Play because Google otherwise automatically refunds unacknowledged purchases after a few days. If Google Play no longer reports a valid Premium purchase, for example after a refund, the app removes the Premium status on the device. If Google Play cannot be reached, the previous status remains unchanged.

The Premium status is stored locally. The proof of purchase remains in your Google Account. After the app data has been deleted or on a new device, the reconciliation restores Premium with the same Google Account; in addition, there is the “Restore Previous Purchase” button on the Premium screen.

Order and sales reports. Google provides Curiovo with order and sales reports in the Google Play Console. They contain, for example, the order number, date, product, price, taxes, purchase token and the buyer's country, and in the downloadable financial reports also the device model and in some cases the buyer's state or region, city and postal code. In the Play Console, orders can be searched by order number or by the buyer's full email address. Curiovo uses the reports for accounting and tax returns and retains them for the periods prescribed by tax and commercial law (Section 147 AO (German Fiscal Code), Section 257 HGB (German Commercial Code); up to ten years).

• Legal basis: Art. 6(1)(b) GDPR (performance of the purchase, provision of Premium including the reconciliation as to whether a valid purchase exists). For the retention of the order and sales data and insofar as other legal obligations exist, Art. 6(1)(c) GDPR.
• Recipients: Google as operator of Google Play. Payment processing and the purchase history are subject to Google's terms and privacy policy.
• Storage period: The local status remains until the app data is deleted. Google manages the purchase history according to its own rules. Order and sales data at Curiovo: until the statutory retention period expires.

Reminders and notices

PhrasePro schedules a daily learning reminder with the phrase of the day locally on the device. The time is based on the learning time you choose at first launch; you can change it under Settings → Notifications. If you have already reached your daily goal on a given day, there is no reminder on that day; if you have started it, the reminder states the number of phrases still missing. After your last learning day, it still comes on the two following days; after that, PhrasePro reminds you on the third and on the seventh day after the last learning day and then no longer. If, when you open the app, no date in this series lies in the future anymore, the series starts over from that day. You switch these reminders on and off together.

In addition, review reminders, streak warnings, Streak Freeze warnings, a weekly summary and a reminder about an interrupted learning session, which names the station and the number of remaining exercises 30 minutes after you leave a lesson, can be switched on and off individually. If PhrasePro has not yet saved any notification settings on your device, for example after a new installation, these additional reminders are initially switched off. Settings from earlier versions are retained; types for which there was no separate switch there yet are switched on as before. In the Android settings, the reminders have their own notification categories for each type.

On Android 13 and later, PhrasePro shows an explanation of the reminders after your first completed learning session; the Android prompt for the notification permission only appears when you choose “Allow reminders” there. After “Not now”, PhrasePro no longer asks on its own initiative; if you close the explanation with the back button, it appears again after the next learning session. You can grant the permission later at any time under Settings → Notifications (“Allow notifications”). On older Android versions, notifications are allowed without a prompt; there, the daily reminder is switched on from the first launch. PhrasePro does not use push messages and does not send any data to Curiovo or third parties for reminders. You can switch off reminders in PhrasePro or in the Android settings at any time.

• Legal basis: Art. 6(1)(b) GDPR and Section 25(2) no. 2 TDDDG. You allow the notifications themselves via the Android permission.

Home screen widget

On Android, you can place a PhrasePro widget on the home screen. It shows the phrase of the day with its meaning; a tap opens it in PhrasePro. So that the widget can change the day without the app, PhrasePro stores the phrases of the next 60 days with their meanings as well as the heading and a note text in the language of the app in the app storage. The app rewrites this data every time it starts and every time you return to the app, even if no widget has been placed. This is learning content of the app, not information from you; which phrases they are depends only on the date and on whether you have Premium. The widget does not load anything from the internet, and PhrasePro does not send any data to Curiovo or third parties for it. It is displayed by your device's home screen.

• Legal basis: Section 25(2) no. 2 TDDDG for storage on the device. Insofar as this constitutes processing by Curiovo, Art. 6(1)(b) GDPR (provision of the app).
• Storage period: until you delete the app data or uninstall the app.

Microphone, speech recognition and your own recordings

The pronunciation exercise uses the microphone with your permission. For this, PhrasePro starts the device's speech recognition service; on Android devices, this is generally a Google service, usually the Google app. The service returns the recognized text, which PhrasePro compares locally with the target sentence. Depending on the device, language and settings, the service may transmit the recording to Google for recognition and process it there. This processing is subject to the terms and the privacy policy of the service provider. With speech recognition, PhrasePro stores neither the recording nor the recognized text; only your learning result is stored.

If no speech recognition is available on the device, you can record yourself and listen to the recording. This recording remains on the device and is not transmitted. PhrasePro deletes it as soon as you record again, move to the next phrase or leave the exercise. If the app is closed before that, the file remains in the app's cache until Android clears it or you delete the app data.

• Legal basis: Art. 6(1)(b) GDPR (the exercise you started) and Section 25(2) no. 2 TDDDG. You allow microphone access via the Android permission and can revoke it there at any time.
• Recipients and third country: the provider of the speech recognition service, usually Google (section 03).

Speech recordings and text-to-speech

To read phrases, their meanings and example sentences aloud, including in Car Mode, PhrasePro plays speech recordings that are included in the app. The voices of these recordings are AI-generated: Curiovo created the recordings in advance with the speech synthesis service ElevenLabs. They are installed with the app and played on the device. When playing these recordings, PhrasePro does not send any data to Curiovo or third parties.

PhrasePro continues to use the device's text-to-speech for texts for which there is no recording or whose recording cannot be played, for individual fixed announcements such as “Level Up!” or the medal after a Daily Challenge (in the language of the app) and, in Car Mode, for the part currently being read when the app moves to the background, for example when the screen is locked. Versions before 3.7.0 read all texts aloud with the device's text-to-speech. The app passes only the English learning content and these fixed announcements to the text-to-speech, not any input from you. Depending on the settings of your device's text-to-speech, its provider, usually Google, may process the texts online; in doing so, the provider receives your IP address.

• Legal basis: Art. 6(1)(b) GDPR and Section 25(2) no. 2 TDDDG.
• Recipients and third country: for text-to-speech, its provider, usually Google (section 03); none when the speech recordings are played.

Google Play review dialog

After exercises, Learning Path stations, Daily Challenges and review sessions that you complete with a good result, PhrasePro asks Google Play to display the review dialog: for the first time after three such units or already after one Learning Path station with at least two stars, after that at the earliest after 40 further completed units and 30 days. Completed exercises from versions before 3.4.0 count toward this. PhrasePro does not ask for it while a full-screen ad or a rewarded video is running or in the five minutes afterward. If PhrasePro has asked for it after a unit, it does not show a full-screen ad when you leave the result. Google decides whether the dialog appears. You submit a review directly on Google Play with your Google Account; PhrasePro does not learn whether and how you rate. Published reviews appear publicly on Google Play with your profile name; Curiovo sees them in the Google Play Console and can reply to them.

• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in receiving feedback on the app.
• Recipients and third country: Google as operator of Google Play (section 03).

Sharing

If you share achievements, levels, streaks, Daily Challenges or phrases, PhrasePro creates an image or a text and passes the content to the Android share menu. You determine where the content goes with the app you choose; its provider is responsible for further processing. Curiovo receives nothing in the process. Images remain in the app's cache until Android clears it or you delete the app data.

• Legal basis: Art. 6(1)(b) GDPR (the function triggered by you).

Google Drive backup (hidden as of version 3.3.1)

As of version 3.3.1, the Google Drive backup is hidden. You cannot create new backups or restore any backup. To delete an existing backup, PhrasePro signs in with your Google Account if required (access to the app-specific area only). The “Backup & Sync” entry only appears if PhrasePro finds traces of earlier use on the device.

If you connected Google Drive in an earlier version, there may still be a PhrasePro backup file in your Google Drive. For this, PhrasePro only has access to the hidden, app-specific area of your Google Drive (“drive.appdata” permission). The file contains learning progress, favorites, settings, XP, streaks and other app states. The transfer takes place directly between the app and Google Drive; Curiovo does not operate a server for this and does not receive the contents. The app stores the name, email address and profile picture address of the connected account only locally; it displays the email address under “Connected as”. PhrasePro does not additionally encrypt the backup file; protection is based on transport encryption and the security mechanisms of Google Drive.

In PhrasePro, you can still choose “Delete Backup” and “Disconnect” (next to “Connected as”) under Settings → Backup & Sync. “Disconnect” signs PhrasePro out of your Google Account and deletes the account data stored in the app and the date of the last backup. The backup file is retained, as is the access permission in your Google Account; you remove the latter under Google Account → Third-party apps & services. You can also delete the file in Google Drive on the web: Settings → Manage apps → PhrasePro → “Delete hidden app data”.

• Legal basis: Art. 6(1)(b) GDPR (the backup you set up and its deletion).
• Recipients and third country: Google as provider of Google Drive and Google sign-in, see section 03. Storage in your Google Account is subject to Google's terms and privacy policy.
• Storage period: backup file until you delete it; account data in the app until you choose “Disconnect” or delete the app data.

Statistics, reports and reviews in the Google Play Console

In the Google Play Console, Google provides Curiovo, as the provider, with aggregated statistics, for example on installations, countries and device types, as well as the public reviews with profile names and the order and sales reports (see “Premium purchase”). If you have agreed in Android to the sharing of usage and diagnostic data with Google, Curiovo also receives crash and error reports there with technical information such as the device model and Android version. Beyond that, PhrasePro does not contain its own analytics or crash reporting tool.

• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in detecting and fixing errors and replying to reviews. For the order and sales reports, Art. 6(1)(c) GDPR (see “Premium purchase”).
• Source: Curiovo receives this data from Google (Google Play).
• Storage period: Curiovo does not store statistics, crash reports or reviews outside the Play Console; Google determines how long it makes them available. Order and sales data: see “Premium purchase”.

Note on versions before 3.3.1

Until 2 October 2026, Google Play distributed older versions of PhrasePro, including test version 2.8.0 in the closed test. Since then, Google Play has only distributed version 3.3.1 or newer versions. The older versions additionally asked about advertising in a separate privacy dialog and offered a Google Drive backup under Settings → Backup & Sync. A backup created there remains in your Google Drive; how to delete it is described in the section “Google Drive backup” and on the page “Delete PhrasePro data”. If you still have an older version installed, update PhrasePro via Google Play.

06 Overview of processing operations and recipients

07 Storage period and deletion

Curiovo stores contact data and website operation data only for as long as the respective purpose exists or statutory retention obligations require. Curiovo retains order and sales data from the Google Play Console until the statutory retention period expires. Local app data remains on the device until you delete the app data or uninstall the app; “Reset Progress” deletes only part of it. A Google Drive backup remains in your Google Account until you delete it. Google manages proofs of purchase and advertising data according to its own rules.

The Delete data page describes all ways to delete data.

08 Your data protection rights

Subject to the statutory requirements, you have the following rights:

• access to your data processed by us (Art. 15 GDPR),
• rectification of inaccurate data (Art. 16 GDPR),
• erasure (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• objection to processing (Art. 21 GDPR, see section 09),
• withdrawal of consent with effect for the future (Art. 7(3) GDPR).

You can also lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the Member State of your place of residence, your place of work or the alleged infringement. The authority competent for Curiovo is the State Commissioner for Data Protection and Freedom of Information Baden-Württemberg.

Curiovo cannot view data that is stored only on your device or in your Google Account and cannot delete it remotely. For this, use the steps on the Delete data page. For data that Google processes under its own responsibility, contact Google.

10 Children and young people

PhrasePro is aimed at persons aged 16 and over and is not intended for children and young people under the age of 16. Curiovo does not ask children and young people to submit personal data. PhrasePro does not verify age. Anyone younger than 16 should not consent to personalized advertising; such consent is only effective with the approval of the holders of parental responsibility (Art. 8 GDPR). If we learn that a child under 16 has sent us data, we will delete it. Holders of parental responsibility can contact info@curiovo.de with questions.

11 Contact and changes

For data protection questions and requests concerning data held by Curiovo, write to info@curiovo.de, subject “Privacy request PhrasePro”. We adapt this policy when functions of the app, services used or legal requirements change. The version with the date stated above is authoritative.