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Privacy Policy

Last updated: February 19, 2026

This privacy notice explains how Mensch, Nina! UG (haftungsbeschränkt) ("ETM-Network", "we", "us") processes personal data when you use our mobile applications and the etmnetwork.de website. We operate in accordance with the EU General Data Protection Regulation (GDPR) and other applicable laws.

1. Controller

Mensch, Nina! UG (haftungsbeschränkt)
Danziger Weg 8, 82538 Geretsried, Germany
Email: ortizzjustin208@gmail.com
Managing Director: Katharina Schlude

A data protection officer is currently not required because the statutory conditions in Art. 37 GDPR / § 38 BDSG are not met.

2. Age Restriction (16+)

Our apps and services are directed at users aged 16 and above. We do not knowingly collect data from children under 16. If we become aware that such data has been collected, we will erase it without undue delay.

3. Data We Collect and Purposes

3.1 User Account Data (Firebase Authentication)

Processed data: email address, encrypted password (never readable by us), username/display name, authentication tokens, Google Sign-In credentials (OAuth).

Purpose: account creation, login, and providing core functionality.
Legal basis: Art. 6(1)(b) GDPR (contract performance).

3.2 App Data (Firebase Firestore & Storage)

Depending on app features we store profile photos, streaks and challenge progress, interaction and gameplay data, user statistics, and other in-app states required to deliver the feature set.

Purpose: provide core app functions and persist user progress.
Legal basis: Art. 6(1)(b) GDPR.

3.3 Firebase Crashlytics

Automatically collected diagnostic information such as crash logs, device model, operating system, app version, and technical error metadata.

Purpose: improve stability and diagnose issues.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in maintaining reliable services).

3.4 Google AdMob

Depending on consent, Google may process advertising identifiers, device information, approximate location, app events, and a truncated IP address.

Purpose: display ads, measure performance, and prevent fraud.
Legal basis: non-personalised ads — Art. 6(1)(f) GDPR; personalised ads — Art. 6(1)(a) GDPR (consent).

3.5 Payments & Subscriptions (Future Feature)

If subscriptions or in-app purchases are activated we may process purchase tokens, subscription status, payment confirmations, order history, email, and billing information supplied by Google Play or the Apple App Store.

Purpose: deliver paid features, manage billing, and verify purchases.
Legal basis: Art. 6(1)(b) GDPR.

3.6 Server and Website Data (Netcup Hosting)

When you access our website the hosting provider processes your IP address, timestamp, browser and operating system information, and referrer URL.

Purpose: ensure security and stability of our infrastructure.
Legal basis: Art. 6(1)(f) GDPR.

3.7 Audio Recording and Processing (NeuralAudio App)

Processed data: audio recordings captured via your device's microphone, uploaded audio files.

Important: All audio data remains exclusively on your device. We do not collect, transmit, store, or have any access to your audio recordings. All noise removal processing is performed locally on your device using offline AI technology. Audio files are never sent to our servers or any third-party services.

The microphone permission (RECORD_AUDIO) is used solely to:

  • Record audio for noise removal processing
  • Process audio files you choose to upload

You have full control over your audio files and may save, share, or delete them at your discretion using your device's standard file management.

Purpose: provide offline AI-based audio noise removal.
Legal basis: Art. 6(1)(b) GDPR (contract performance — delivering the app's core functionality).

3.8 Text-to-Speech and OCR (Neural-TTS App)

Processed data: Camera input (for OCR), Microphone input (for Voice Notes).

Important: All processing is performed locally on your device.

  • Camera Data: Used strictly for the Text Scanner (OCR) feature to convert images of text into speech. Image processing is performed locally using Google ML Kit. We do not store, upload, or share your photos or the extracted text.
  • Audio Data: Used for the Voice Note feature to dictate text. Speech-to-text conversion is handled by your device's built-in speech recognition service. We do not store or upload your voice recordings.

You can revoke Camera and Microphone permissions at any time through your device settings, which will disable the respective features.

Purpose: Provide text-to-speech and OCR functionality.
Legal basis: Art. 6(1)(b) GDPR (contract performance).

3.9 Speech-to-Text Processing (Neural-STT App)

Processed data: Audio recordings captured via your device's microphone.

Important: All audio data remains exclusively on your device. We do not collect, transmit, store, or have any access to your audio recordings. All speech-to-text transcription is performed locally on your device using offline AI technology (Sherpa-ONNX). Audio files are never sent to our servers or any third-party services.

The microphone permission (RECORD_AUDIO) is used solely to:

  • Record audio for real-time speech-to-text transcription
  • Process uploaded audio files for transcription

Generated transcriptions are stored locally on your device. You have full control over your transcription history and may export, share, or delete them at your discretion.

Purpose: Provide offline AI-based speech-to-text transcription.
Legal basis: Art. 6(1)(b) GDPR (contract performance).

3.10 Offline Audiobook Generation (NeuralVoice App)

Processed data: Text input, imported documents (PDF, EPUB), and downloaded public domain books.

Important: All text-to-speech processing is performed locally on your device. We do not collect, transmit, store, or have any access to the documents, text, or books you import into the app. All AI voice generation is performed offline using on-device models. Your reading materials and generated audio are never sent to our servers or any third-party services.

Purpose: Provide offline AI-based text-to-speech and audiobook generation.
Legal basis: Art. 6(1)(b) GDPR (contract performance — delivering the app's core functionality).

4. Consent for Ads and Tracking

Personalised advertising and non-essential tracking technologies require your consent. You may withdraw consent at any time via in-app settings, device settings, or by contacting us. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

5. Data Retention

  • User accounts and associated app data: retained until the account is deleted or the data is no longer required.
  • Crashlytics diagnostic data: up to 180 days.
  • Server logs: 7 to 30 days.
  • Support correspondence: up to 24 months after resolution.
  • Payment records (once activated): 10 years to comply with German commercial and tax retention duties.

6. International Data Transfers

Google services (Firebase, AdMob, OAuth, Crashlytics) may transfer data to the United States or other third countries. Transfers rely on the EU–US Data Privacy Framework and/or Standard Contractual Clauses pursuant to Art. 46 GDPR.

7. Your Rights

You have the following rights under GDPR:

  • Access (Art. 15), rectification (Art. 16), erasure (Art. 17), and restriction of processing (Art. 18).
  • Data portability (Art. 20) and the right to object to processing based on Art. 6(1)(f) GDPR (Art. 21).
  • Withdraw consent at any time (Art. 7).
  • Lodge a complaint with a supervisory authority (Art. 77). The competent authority for us is the Bavarian Data Protection Authority (BayLDA): https://www.lda.bayern.de/.

8. Security Measures

We implement appropriate technical and organisational measures, including TLS/SSL encryption, access controls, authentication safeguards, and regular security reviews. Nevertheless, no system is entirely secure; please protect your login credentials and alert us immediately of suspected misuse.

9. Changes to This Privacy Policy

We may update this policy to reflect new features, legal requirements, or improvements. The current version is always available within the app and on our website. Substantial changes will be communicated through the Services.

10. Contact

For privacy enquiries or to exercise your rights, contact ortizzjustin208@gmail.com. We will respond within the time limits required by applicable law.