Sapling ("the App") is operated by Nicholas Cross, a sole trader based in the United Kingdom ("I", "me", "my"). This policy explains what data is collected when you use the App, why it is collected, and your rights under UK data protection law (UK GDPR and the Data Protection Act 2018).
1. Who is the Data Controller?
Nicholas Cross is the data controller for personal data processed through Sapling. For any data-related enquiries, contact me at knack.sienna.6b@icloud.com.
2. What Data is Collected?
Data you provide
Language preference and learning progress — stored locally on your device using Apple's SwiftData framework. This data never leaves your device unless you use iCloud backup (governed by Apple's privacy policy).
Data collected automatically
Purchase and subscription data — when you subscribe, RevenueCat (our subscription management provider) processes your Apple-assigned anonymous subscriber ID, subscription status, and entitlement information. RevenueCat does not receive your Apple ID, name, or payment details — those remain with Apple.
Device and diagnostic data — Apple may collect crash reports and performance data under your device's privacy settings. I do not separately collect crash analytics.
Data I do not collect
Name, email address, or any account credentials
Location data
Contacts, camera, or microphone data
Advertising identifiers
3. Legal Basis for Processing (UK GDPR)
Performance of a contract — processing subscription status to grant you access to premium features.
Legitimate interests — maintaining app functionality and improving the learning experience using anonymised, on-device data.
4. Third-Party Services
RevenueCat, Inc. (USA) manages in-app subscriptions. Data transfers to the USA are safeguarded by Standard Contractual Clauses. For details, see RevenueCat's Privacy Policy.
On-device learning data — retained until you delete the App or clear its data in Settings.
Subscription records — retained by RevenueCat for as long as necessary to manage your subscription and comply with financial regulations (typically up to 7 years).
6. Your Rights
Under UK GDPR you have the right to:
Access the personal data held about you
Rectify inaccurate data
Erasure ("right to be forgotten") where data is no longer necessary
Restrict or object to processing
Data portability
To exercise any of these rights, email knack.sienna.6b@icloud.com. I will respond within one month as required by law.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.
7. Children
Sapling is not directed at children under the age of 13. I do not knowingly collect personal data from children. If you believe a child has provided personal data, please contact me and I will delete it promptly.
8. Changes to This Policy
I may update this policy from time to time. The "Last updated" date at the top of this page will always reflect the most recent version. Continued use of the App after changes constitutes acceptance of the updated policy.