Mera Privacy Policy

1. Who We Are

Responsible Party (Data Controller)

Email: contact@petalbe.com
Website: petalbe.com

The responsible party is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

About Mera: Mera is a Hindi vocabulary learning app for iOS that helps you build conversational Hindi skills through personalised exercises and spaced repetition.

2. Data We Collect

2.1 Vocabulary Data

When you use Mera, the following data is stored locally on your device:

• Vocabulary items: Hindi words, English translations, parts of speech, categories, example sentences, and notes that you add or upload
• Learning progress: Your mastery level, correct and incorrect answer counts, review dates, and spaced repetition schedules for each vocabulary item
• Exercise statistics: Exercise completion data, scores, accuracy rates, and time spent practising
• User preferences: Daily goals, notification settings, and app configuration choices
• Learning analytics: Your daily study streaks, time spent per session, words learned per day and week, and goal completion rates are stored locally and used to display your progress statistics

Storage location: All this data is stored locally using Apple's Core Data framework on your device. If you enable iCloud sync, this data is automatically synchronised across your Apple devices via CloudKit.

2.2 Apple ID Information

If you use iCloud sync, Apple uses your Apple Account to synchronise Mera data across your devices. We do not receive, collect, or store your Apple Account credentials, Apple ID email address, or iCloud login information. Apple handles authentication and iCloud synchronisation.

2.3 What We Don't Collect

We explicitly do not collect:

• Your vocabulary words, translations, notes, example sentences, or learning progress on our own servers
• Your name, email address, phone number, or Apple Account credentials
• Location data or GPS coordinates
• Device identifiers for advertising purposes
• Browsing history or activity outside the app
• Contacts, photos, or other sensitive device data
• Payment information, which is handled by Apple where applicable

We do collect limited app usage analytics as described in Section 6.

3. How We Use Your Data

3.1 Purpose of Data Processing

Your vocabulary and learning data is used exclusively to:

• Personalise your learning: Track which words you've mastered, which need review, and optimise spaced repetition schedules
• Generate exercises: Create personalised flashcards, quizzes, and practice sessions based on your learning history
• Display progress: Show your learning statistics, streaks, mastery levels, and achievements
• Sync across devices: Keep your vocabulary and progress synchronised across all your Apple devices via iCloud

3.2 Local Processing

All vocabulary processing, exercise generation, and progress calculations happen entirely on your device. When you upload CSV files with vocabulary, they are parsed locally without sending data to external servers.

4. Data Storage and Security

4.1 Core Data and CloudKit

Mera uses Apple's Core Data framework for local storage and CloudKit for optional iCloud synchronisation.

• Local storage: Data is stored locally on your device and protected by Apple's device security mechanisms, such as your device passcode, Face ID, Touch ID, and iOS data protection.
• iCloud sync: If enabled, data syncs via Apple's CloudKit infrastructure. iCloud data is encrypted in transit and at rest according to Apple's iCloud security model.
• Access control: Your synced Mera data is associated with your Apple Account. We do not access your personal learning content through iCloud.

4.2 Data Retention

Your data remains on your device and in your iCloud account until you choose to delete it. We do not have access to delete your data on your behalf.

5. Third-Party Services

5.1 Apple Services

Mera relies on Apple's infrastructure:

• Apple ID: For user authentication and iCloud sync (Apple's Privacy Policy applies)
• CloudKit: For cross-device data synchronisation (covered by Apple's iCloud Terms)
• TestFlight: For beta testing, which collects anonymised crash reports and usage analytics handled by Apple
• App Store: For app distribution and in-app purchases (Apple's standard terms apply)

Apple's Privacy Policy: apple.com/legal/privacy

5.2 Limited Analytics Usage

Mera uses anonymised analytics only for improving app functionality. We do not use:

• Advertising networks or user tracking for marketing purposes
• Social media integration that shares your data
• Analytics data for advertising or selling to third parties

For information about our analytics usage, see Section 6 below.

6. Analytics and Usage Data

6.1 Aptabase

To understand how Mera is used and to improve the app experience, we use Aptabase, a privacy-focused analytics service provided by Sumbit Labs Ltd.

6.2 Purpose of Analytics

We use analytics to understand general app usage patterns, app stability, and feature usage. This helps us decide which features to improve, whether important screens are useful, which exercise types are used, and whether features such as CSV import work reliably.

6.3 Data Collected

If analytics is enabled, Mera may send limited usage and technical data to Aptabase, such as:

• App events: for example app opened, screen viewed, exercise started, exercise completed, CSV import completed, or CSV import failed
• Feature information: for example the screen name, exercise type, import result, or general error category
• Technical information: for example app version, iOS version, device type, language, country or region, and event timestamp

6.4 Analytics Configuration

We configure analytics in a minimal way. Mera only sends manually selected events that help us understand app functionality and improve the product. We do not use analytics for advertising, cross-app tracking, user profiling, or selling data.

6.5 Legal Basis

The use of limited analytics is based on our legitimate interest in understanding how Mera is used, improving app functionality, and maintaining app stability (Art. 6(1)(f) GDPR). Where consent is required by applicable law or platform rules, we will ask for consent.

6.6 Analytics Control

You can disable analytics in Mera's Settings under Privacy by turning off "Share Anonymous Analytics". If analytics is disabled, Mera will stop sending analytics events from that device.

6.7 No Advertising Use

We do not use analytics data for advertising purposes and do not share analytics data with advertising networks. Analytics data is used only to understand app usage, improve features, and maintain app quality.

Further details about Aptabase's privacy practices are available in Aptabase's Privacy Policy.

7. Your Privacy Rights

7.1 Access and Control

You have complete control over your data:

• View your data: All your vocabulary and progress is visible within the app's Library and Statistics sections
• Edit your data: You can edit or delete individual vocabulary items at any time
• Export your data: You can export your vocabulary data in standard formats (future feature)
• Delete all data: Delete the app to remove all local data. For iCloud data, manage it through your Apple ID settings
• Control analytics: Toggle "Share Anonymous Analytics" in Mera's Settings to disable Aptabase analytics on that device

7.2 iCloud Data Management

To manage your iCloud data:

• Go to iPhone Settings → [Your Name] → iCloud → Manage Storage → Mera
• You can disable iCloud sync or delete iCloud data from here
• Deleting iCloud data will not affect local data stored on your device

7.3 Right to Be Forgotten

Since we do not collect personal learning data on our servers, simply deleting the app removes all local data. For iCloud data, use Apple's iCloud management tools as described above. Analytics data processed via Aptabase is anonymous or aggregated and cannot be linked by us to an identified individual.

8. Children's Privacy

Mera is not specifically directed at children. We do not knowingly collect personal information from children. Vocabulary and learning data is stored locally on the device and, if enabled, synced via Apple's iCloud infrastructure.

If a parent or guardian believes that a child has provided personal data to Mera in a manner inconsistent with this policy, please contact us at contact@petalbe.com.

9. International Data Transfers

Mera processes all data locally on your device. If you enable iCloud sync, your data is stored in Apple's iCloud infrastructure, which may involve international data transfers according to Apple's policies. Apple complies with applicable data protection laws including GDPR for European users.

Analytics data is processed via Aptabase. We use Aptabase's EU data region where available. Aptabase is operated by Sumbit Labs Ltd., based in Ireland. Aptabase may process limited technical data to provide anonymous app analytics.

10. Data Breach Notification

Since we do not collect or store your data on our servers, the risk of a data breach affecting your Mera data is minimal. Your data security depends on:

• Your device's security (passcode, Face ID, Touch ID)
• Your Apple ID security (two-factor authentication recommended)
• Apple's iCloud security infrastructure

If Apple notifies us of any security incident affecting Mera users, we will promptly inform affected users according to applicable legal requirements.

11. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process your data based on:

• Contractual necessity (Art. 6(1)(b) GDPR): Processing vocabulary and progress data is essential to provide the app's core learning functionality
• Legitimate interest (Art. 6(1)(f) GDPR): Storing user preferences and settings to improve the user experience, and processing limited analytics data via Aptabase to understand app usage, improve functionality, maintain app stability, and prioritise product improvements
• Consent (Art. 6(1)(a) GDPR): Where applicable, such as enabling optional iCloud sync features or sharing analytics data (which you can opt out of at any time)

12. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make significant changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you through the app (for material changes)
• Request your consent if required by applicable law

We encourage you to review this policy periodically. Continued use of Mera after changes constitutes acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this privacy policy or your data, please contact us:

We will respond to your inquiry within 30 days.

14. Supervisory Authority

If you are located in the EEA, UK, or Switzerland and believe we have not addressed your privacy concerns adequately, you have the right to lodge a complaint with your local data protection authority:

• Germany: Contact your state's data protection authority (Landesdatenschutzbehörde) or the Federal Commissioner for Data Protection and Freedom of Information (BfDI)
• EU/EEA: Find your national authority at edpb.europa.eu
• UK: Information Commissioner's Office (ICO) at ico.org.uk