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Govori Privacy Policy

Note: This privacy policy applies to the Govori iOS application published by Bulsu Labs (BLS Logistics and Storage d.o.o.). For questions, email info@bulsulabs.com.

1. Overview

Govori ("the app", "we", "our", "us") is a Duolingo-style language learning application for studying Montenegrin (Karadağca). We are committed to protecting your privacy. This Privacy Policy explains what information the app handles when you use Govori on iOS.

By using Govori, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the app.

2. Information We Collect

2.1 Information you provide directly

• Onboarding preferences: your selected native language and daily goal — stored only on your device.
• Voice input (optional): when you complete speaking exercises, the audio is sent to Apple's on-device speech recognition framework. The audio never leaves your device and is never recorded or stored by Govori.
• Subscription and purchase data: handled entirely by Apple App Store and RevenueCat. We do not see, process, or store your payment card details.

2.2 Information collected automatically

• RevenueCat anonymous user identifier: a randomly generated app-install identifier used to verify and restore your subscription. This ID does not contain your name, email, or any personally identifying information.
• Device information (RevenueCat): RevenueCat receives your device model, OS version, app version, and country (from the App Store) when validating your subscription receipt.

2.3 Information we do NOT collect

• We do not require an account, email address, name, or phone number.
• We do not access your contacts, calendar, location, photos, health data, or browsing history.
• We do not record, store, or transmit your microphone audio.
• We do not use third-party advertising or analytics SDKs.
• We do not track you across other apps or websites (no IDFA tracking).
• We do not sell or rent your personal data — ever.

3. How We Use Your Information

We use the information stored on your device to:

1. Provide your personalized language learning experience (lessons, progress, XP, streaks, badges).
2. Adapt difficulty and surface weak words for spaced repetition.
3. Show your interface in your selected language (12 languages supported).

The minimal data sent to RevenueCat is used solely to verify your subscription status and to enable "Restore Purchase" if you reinstall the app or switch devices.

4. Microphone & Speech Recognition

Some exercises let you practice pronunciation. When you tap a speaking exercise:

1. iOS asks for permission to access the microphone and speech recognition.
2. Audio is processed by Apple's on-device speech recognition framework — it does not reach Apple's servers, our servers, or any third party.
3. Govori receives only the recognized text string, scores your pronunciation locally, and discards everything.
4. You can revoke microphone / speech permission at any time in iOS Settings → Govori.

5. Text-to-Speech

The app uses Apple's built-in Text-to-Speech to read Montenegrin words and sentences aloud. This runs entirely on your device. No text is sent to any remote server.

6. Third-Party Services

Govori integrates with the following third-party services. Each has its own privacy policy:

• RevenueCat — Subscription management and receipt validation · privacy policy
• Apple App Store — Payments and in-app purchase processing · privacy policy
• Apple Speech Recognition — On-device speech-to-text for pronunciation exercises · privacy policy

Govori does not use any analytics SDK (Firebase, Amplitude, Mixpanel, etc.), advertising network, attribution provider, or crash-reporting service.

7. Data Storage & Security

• Your learning data (progress, XP, streaks, badges, weak words, settings) is stored locally on your device using standard iOS storage (localStorage / WKWebView storage).
• Receipt validation requests to RevenueCat are transmitted over HTTPS (TLS 1.2+).
• We use reasonable administrative, technical, and physical safeguards to protect any information that does flow through our integrations.

No system is 100% secure. In the unlikely event of a data breach affecting RevenueCat, RevenueCat is responsible for notifications under their own policy. We will additionally notify affected users within 72 hours when required by applicable law.

8. Data Retention

• Local data: retained until you delete the app or reset progress from Profile → Settings.
• RevenueCat subscription records: retained for as long as your subscription is active and for the period required by accounting and tax law thereafter (typically 7 years). See RevenueCat's privacy policy for full details.

9. Subscriptions (Govori Pro)

Govori offers auto-renewable subscriptions to unlock the full Montenegrin course and premium features:

• Monthly: $2.99 per month
• Yearly: $19.99 per year (best value, save 44%)

Free users get the first 3 units, Cyrillic alphabet practice, and basic lessons. Govori Pro unlocks units 4 and above, the AI Chat companion, all Practice modes, and interactive Stories.

Auto-renewal: Subscriptions automatically renew unless cancelled at least 24 hours before the end of the current period. Your iTunes/Apple ID account will be charged at confirmation of purchase. Renewal is charged within 24 hours prior to the end of the current period.

Manage / cancel: You can manage or cancel your subscription at any time in Settings > Apple ID > Subscriptions on your iOS device. Cancellation takes effect at the end of the current billing period. No refund is provided for the unused portion of the term.

Payment processing: All payments for in-app purchases are processed by Apple. We do not have access to your payment card details.

Terms of Use (EULA): The standard Apple End User License Agreement applies to the use of Govori.

10. Your Rights

Depending on your location, you have the following rights:

All users

• Access: request a copy of any personal data we hold (limited to subscription records on RevenueCat).
• Deletion: delete the app to wipe all local data instantly. To request deletion of your RevenueCat anonymous identifier, email us — see contact below.

European Economic Area (GDPR)

In addition to the above, you have the right to:

• Restrict processing
• Data portability (receive your data in a portable format)
• Object to processing
• Lodge a complaint with your local data protection authority

California residents (CCPA)

• Right to know what personal information is collected.
• Right to delete personal information.
• Right to opt out of the sale of personal information. Govori does not sell personal information.
• Right to non-discrimination for exercising your rights.

To exercise any of these rights, email info@bulsulabs.com.

11. Children's Privacy

Govori is suitable for all ages and does not require an account. Since we do not collect personal data, we do not knowingly collect information from children under 13 (or the equivalent minimum age in your jurisdiction).

12. International Data Transfers

Govori is operated globally. Your subscription data may be transferred to and processed by RevenueCat in the United States. Where required, we rely on RevenueCat's appropriate safeguards (Standard Contractual Clauses) for transfers out of the European Economic Area.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The "last updated" date at the top of this page reflects the effective date of the current version. Material changes will be reflected in the app and on this page.

14. Contact

If you have any questions about this Privacy Policy or Govori's data handling, please contact us at info@bulsulabs.com.

Bulsu Labs is the trading name of BLS Logistics and Storage d.o.o., a Montenegrin limited liability company.