Privacy Policy
Last updated: 13 November 2026
Short version: Lemfio has no accounts. We do not set cookies. We keep your practice progress in your own browser. We measure the Site with anonymous statistics that do not identify you. If you join the Pro launch list, we keep your e-mail address to tell you when Pro launches. Nothing is on sale.
1. Who is responsible
Ivan Kyrylko, an individual, contact: [email protected] (the “controller”). A postal address for legal correspondence will be published on the Contact page before any e-mail is sent to the Pro launch list. For residents of Quebec, Canada, the person responsible for personal information is Ivan Kyrylko, at the same e-mail.
2. Our audience
The Site is for people aged 13 and over. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has used the Site or left an e-mail address, write to us and we will delete what we have. The Pro launch list is for adults (18 or over, or the age of majority where you live) and for parents or guardians signing up; please do not join it if you are younger.
3. What we process, why, and on what legal basis (EU/UK GDPR)
| Data | Why | Basis |
|---|---|---|
| Technical request data (IP address, browser type) processed transiently by our host Cloudflare and our server functions to deliver the pages, keep the Site secure and prevent abuse | To serve and protect the Site | Legitimate interests (secure, working Site) |
| Anonymous usage statistics: page path, referring website domain, campaign tags in the link (utm_*), country (derived from IP at the server; the IP address is not stored or sent on to our analytics), event type (page view, exercise answered with result and verb tense, Pro button clicked, launch-list sign-up without the address), a random one-off event ID that is not stored on your device | To see whether the Site is used and works, and improve it | Legitimate interests (understanding use with minimal data) |
| E-mail address, sign-up time and consent-text version if you join the Pro launch list (see “Pro launch waitlist” below) | To tell you once when Pro launches | Your consent |
| Messages you send us (e-mail, “Report a mistake”, withdrawal or refund requests) | To answer you | Legitimate interests; contract |
We do not sell your personal information. We do not share it for cross-context behavioural advertising. We show no ads and do no profiling or automated decisions about you.
4. Cookies and browser storage
We do not set cookies. We use your browser’s local storage, only for things you ask the Site to do. Keys start with lemfio.v1.:
| Key | What it holds | Why |
|---|---|---|
settings |
your chosen language, tenses and persons | remembers practice settings |
daily |
today’s date and number of answers | applies the free daily limit |
stats |
your accuracy totals per tense | shows your progress |
srs |
review schedule per verb form | Pro spaced repetition |
lists |
your own verb lists | Pro lists |
pro |
your licence key and its status | keeps Pro active on your device |
analytics_optout |
your choice to turn off statistics (if you use it) | remembers your choice |
This data stays on your device. Our anonymous statistics do not read or use it, except that they check the analytics_optout key so that your choice is respected. You can delete it at any time in your browser settings or with “Reset progress”. If you delete the pro key you must enter your licence key again.
You can turn off anonymous statistics with the switch in the opt-out section below, or with the “Usage statistics: opt out” link in the footer, which leads to it.
5. Who receives data
| Recipient | Role | What for |
|---|---|---|
| Cloudflare, Inc. | processor (hosting, CDN, serverless functions, security, launch-list database) | delivering the Site; processes IP addresses; stores the launch list |
| PostHog (EU cloud, Frankfurt, Germany) | processor | anonymous usage statistics, kept as described in section 7 |
Our processors handle data under data processing agreements with us. Authorities or advisers may receive data where the law requires.
6. International transfers
Some providers (Cloudflare and PostHog as companies) are based in or may access data from outside the EU/UK, including the United States. The launch-list database is set to be stored in the EU, but our server function and the provider’s staff and systems can reach it from other countries, so your address may be processed outside the EU/UK. For these transfers we rely on the safeguards each provider offers: Cloudflare participates in the EU–US Data Privacy Framework (and its UK extension) and its data processing agreement includes the EU standard contractual clauses with the UK addendum; PostHog participates in the EU–US Data Privacy Framework and its data processing agreement applies. You can ask us for a copy of the safeguards at [email protected].
7. How long we keep data
- Anonymous statistics: up to 12 months.
- Server logs: kept by Cloudflare for a short period for security and operation, under its own retention rules.
- Support messages: up to 24 months after the last message.
- Launch-list e-mail addresses: see “Pro launch waitlist” below.
- Local storage: until you delete it.
8. Your rights
If you are in the EU or UK you can ask us to: access your data, correct it, delete it, restrict or object to processing, and receive it in a portable form; you can complain to your data protection authority. Because the statistics are anonymous and not linked to you, we usually cannot find data about you; we will explain this if you ask.
If you live in California or another US state with a privacy law, you have similar rights to know, delete, correct and opt out of sale or sharing. We do not sell or share personal information. We do not treat anyone differently for using these rights. We respond to the Global Privacy Control signal in the same way as we would an opt-out (it requires no action because we do not sell or share).
If you live in Canada, you can ask for access and correction and complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information.
To use any right, write to [email protected]. We answer within one month (or the period the law gives).
9. Security
We use HTTPS, restrict what our server functions accept, and keep data minimal. No system is perfectly secure.
10. Changes
We will change the date above when we update this policy and, if the change is material, say so on the Site.
Pro launch waitlist
While Pro is not on sale, you can leave your e-mail address on the Pro page to be told when it launches.
- What we store: your e-mail address, the date and time you signed up, and the version of the consent text you ticked. Nothing else (no name, no IP address).
- Why: to send you e-mail about the Pro launch only: one confirmation message asking you to confirm your address, and one message when Pro launches. We do not use the list for anything else, do not sell or share it, and do not send marketing about anything else. Basis: your consent, which you can withdraw at any time. Withdrawing does not affect what we did before.
- Before we send you anything: we will first send one e-mail asking you to confirm that the address is yours. If you do not confirm, we send nothing more and delete the address. Until this confirmation step is in place, we send no e-mails to the list.
- Every e-mail will say who we are, give our contact details and a simple way to unsubscribe.
- Where: in a database at Cloudflare (D1) set to the EU jurisdiction. Our server function and our provider can reach it from other countries (see “International transfers”).
- How long: until Pro has launched and we have sent the launch e-mail, plus 30 days, or until you ask us to delete it, or 12 months after you signed up if Pro has not launched by then, whichever is earliest.
- How to delete it or withdraw consent: write to [email protected] from the address you signed up with, and we will delete it. You can also complain to your data protection authority.