Privacy policy
This policy explains which personal data Perastro processes when you use the Ciarla app or visit this website, why, where it goes, and what rights you have. We keep it short where we can and precise where it matters.
1. Who is responsible
The controller under the General Data Protection Regulation (GDPR) is:
Martin-Luther-Straße 47
10779 Berlin, Germany
Email: contact@perastro.com
We have not appointed a data protection officer because we are not legally required to. Write to the address above with any privacy question.
2. Overview
| What | Why | Legal basis | Where |
|---|---|---|---|
| Learning progress and settings on your phone | The app works offline | – | Only your device |
| Email address, sign-in data | Your account | Art. 6(1)(b) GDPR | Supabase, EU |
| Learning progress, settings | Sync and restore on a new phone | Art. 6(1)(b) GDPR | Supabase, EU |
| Chat messages you write | Replies and feedback | Art. 6(1)(b) GDPR | Anthropic, USA |
| Voice recordings | Speech recognition, pronunciation feedback | Art. 6(1)(a) GDPR (your consent) | Microsoft Azure, EU |
| Card reports | Fixing mistakes in the content | Art. 6(1)(f) GDPR | Supabase, EU |
| Crash reports | Finding and fixing bugs | Art. 6(1)(f) GDPR | Sentry, EU |
| Website access logs | Delivering the site securely | Art. 6(1)(f) GDPR | Cloudflare |
We do not use your data for advertising, we do not track you across apps or websites, and we do not sell data.
3. This website
The website is hosted by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. When you open a page, your browser sends technical data that the server records in log files: IP address, date and time, the page requested, the referring page, and browser and operating system. We need this to deliver the site and protect it against attacks (Art. 6(1)(f) GDPR). The logs are deleted after a short period.
The website sets no cookies and uses no analytics or tracking. Fonts are loaded from our own server, not from Google. If you switch the language, that choice is saved in your browser’s local storage and never sent to us.
4. The app on your phone
Ciarla keeps your learning progress, settings and streak on your phone, so word and grammar cards work without a connection. You can use your first session without an account; in that case nothing about your learning leaves the phone, except what you send in a chat (section 6).
- Daily reminder. The reminder is a local notification scheduled on your phone. No data is sent for it. You can turn it off in the app or in your phone’s settings.
- Audio. Italian words and sentences are read aloud by your phone’s built-in voice, on the device.
- Microphone. The app asks for microphone and speech recognition access only for voice chats. You can withdraw it in your phone’s settings at any time.
5. Your account and sync
After your first session, Ciarla asks you to create an account so your progress is kept and can be restored on a new phone. You can sign up with an email address and password, or with Google. With Google, we receive your name, email address and a Google account ID from Google; Google’s privacy policy applies to the sign-in itself. Passwords are stored only as a secure hash.
With an account, we store on our servers:
- your profile: interface language, learning goals, estimated level, daily goal, reminder settings and your choice for voice chats;
- your learning state: for each word and grammar point its stage and when it is due, your skill levels, and which chats you have finished;
- your answers as review events: which card, whether it was right, and signals such as response time or whether you used a hint;
- a count of chat checks per day, to keep usage within fair limits.
This is necessary to provide the service you signed up for (Art. 6(1)(b) GDPR). The database is operated for us by Supabase, Inc. in a data centre in the European Union.
6. Chats with AI feedback
In a chat, someone writes to you and you answer in Italian. To write the next message and to give you feedback, your messages are sent through our server to Anthropic PBC, 548 Market St, San Francisco, CA 94104, USA, whose AI model Claude generates the reply and the correction. Along with your messages we send the chat’s situation, your level and your interface language. We do not send your name, your email address or your account ID.
Anthropic processes this data on our behalf and does not use it to train its models. Please do not write personal details about yourself or other people in chats that you would not want processed this way.
Legal basis: Art. 6(1)(b) GDPR, as the feedback is part of the service. For the transfer to the USA, see section 10.
7. Voice chats
Before your first voice chat, Ciarla asks how your voice messages should be recognised.
With cloud recognition (only if you allow it)
Your recording is sent through our server to Microsoft Azure AI Speech (Microsoft Ireland Operations Limited, Dublin), processed in a data centre in the EU (West Europe region). Azure turns it into text and rates your pronunciation. We do not store the recording; it is processed in memory and discarded. The transcript and the pronunciation scores become part of the chat and its feedback (section 6). The messages you hear are read by an Azure neural voice; for that, the text of the message is sent to Azure.
Legal basis: your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time in the app under Settings → Audio. Withdrawal does not affect processing that happened before.
Without cloud recognition
Your phone’s built-in speech recognition turns your voice into text. This is a feature of your operating system, provided by Apple (iPhone) or Google (Android). Depending on your device, language and settings, the operating system may process the audio on Apple’s or Google’s servers; their privacy policies apply. The recognised text is then sent as a chat message (section 6). A copy of your recording stays on your phone so you can play it back.
8. Card reports
If you report a card (for example a wrong translation), we store the card, the reason you chose, your optional message and some technical context about the card, linked to your account. We use it only to fix the content (Art. 6(1)(f) GDPR; our legitimate interest is correct learning material).
9. Crash reports
When the app crashes or hits an error, it sends a technical report to Sentry (Functional Software, Inc., 45 Fremont Street, San Francisco, CA 94105, USA), stored in Sentry’s EU data region. The report contains the error and where in the code it happened, the app version, device model and operating system version. It contains no name, email address or learning content. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is a stable app.
10. Service providers and transfers
We use these providers as processors under Art. 28 GDPR. Each has signed a data processing agreement with us.
| Provider | Purpose | Location |
|---|---|---|
| Supabase, Inc. | Accounts, database, server functions | EU data centre |
| Anthropic PBC | Chat replies and feedback | USA |
| Microsoft Ireland Operations Ltd. (Azure AI Speech) | Voice recognition, pronunciation, voices | EU (West Europe) |
| Functional Software, Inc. (Sentry) | Crash reports | EU data region |
| Cloudflare, Inc. | Website hosting | Global network |
Some of these companies are based in the USA. Where personal data is transferred to the USA or can be accessed from there, the transfer is based on the EU–US Data Privacy Framework where the provider is certified, and otherwise on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).
Apple and Google also process data when you download the app from their stores, under their own responsibility.
11. How long we keep data
- Account and learning data: as long as your account exists. When you delete your account, it is erased right away. Copies in our provider’s backups are overwritten within the backup rotation period.
- Voice recordings sent to the cloud: not stored.
- Card reports: until the report is resolved, and at the latest when your account is deleted.
- Crash reports: at most 90 days.
- Website logs: a short period for security.
- Data on your phone: until you reset the app, sign out, or delete the app.
12. Your rights
You have the right to access your data (Art. 15 GDPR), to have it corrected (Art. 16), erased (Art. 17) or restricted (Art. 18), to receive it in a portable format (Art. 20), and to object to processing based on legitimate interests (Art. 21). You can withdraw consent at any time with effect for the future (Art. 7(3)). Email contact@perastro.com from the address of your account.
You also have the right to complain to a data protection authority (Art. 77 GDPR). The authority responsible for us is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59–61, 10555 Berlin, Germany.
13. Deleting your account
In the app: Settings → Account → Delete account. This deletes your account and all data linked to it on our servers, and clears the app on your phone. Deleting the app alone does not delete your account. Without the app, see Delete your account.
14. Other points
- Ciarla is intended for people aged 16 and over.
- We do not make decisions based solely on automated processing that have legal or similarly significant effects on you (Art. 22 GDPR). The AI feedback in chats only helps you learn.
- Providing your data is voluntary. Without an account, Ciarla works only for the first session.
- We update this policy when the app or the law changes. The current version is always on this page.