Privacy Policy

Pico Picks: Vocab Learning · Last updated: 6 August 2026

This Privacy Policy explains what personal data the Pico Picks iOS app and the rougegorge.app website collect, why they collect it, and what rights you have over your data under the EU General Data Protection Regulation (GDPR) and the French Data Protection Act (Loi Informatique et Libertés).

1. Who is responsible for your data

The data controller is:

• Tudual Lucas Huon, sole proprietor (auto-entrepreneur)
• 21 Dom Morice, 35000 Rennes, France
• SIREN: 999 501 703
• Contact: contact@rougegorge.app

2. What we collect

On your device. The iOS app stores the following locally using Apple's SwiftData framework. This data does not leave your device unless you explicitly share it, or unless it is synced through your own iCloud account as described below:

• The first name or nickname you entered during onboarding
• Your confirmation that you are at least 13 years old (stored as a single yes/no toggle — no date of birth is collected)
• Your home language (as an ISO code, e.g. fr, es)
• Your declared CEFR level (A1 to C2) and learning preferences
• The vocabulary words you save, review or add to your library
• Your learning history, spaced-repetition stats and daily streaks
• Temporary audio recordings made during pronunciation exercises (see §3)

Synced through your own iCloud account. If you are signed in to iCloud, your learning data (saved words and lists, progress, learning history) is synchronised between your Apple devices through your own private iCloud database — a private CloudKit container that belongs to your Apple Account. This data is stored by Apple in your iCloud account, encrypted in transit and at rest, and is not accessible to us: we cannot read it, export it or delete it. Because it lives in iCloud and not only on the device, it survives uninstalling the app: it comes back if you reinstall Pico Picks while signed in to the same Apple Account, and it remains in your iCloud account until you delete it. You can delete or export it at any time from within the app (Settings › “Delete my data” / “Export my data”), and you can remove the app's iCloud data from iOS Settings › your name › iCloud › Manage Account Storage.

Sent to our backend server (rougegorge.app). When you look up a word, request a definition, submit a pronunciation, or report AI-generated content, the app sends the following to our server:

• The word or short phrase you looked up
• Your CEFR level and home language (as context for the AI model to generate a level-appropriate definition)
• For pronunciation: a short audio sample and the target word
• For reports: the AI output you flagged, the reason you picked, and any optional free-form note (limited to 500 characters)

We do not send your name, your learning history, or the contents of your iCloud library, and the words you look up are not attached to a user account. These requests carry a shared application API key, not a user identifier.

One exception, for lesson downloads. When the app fetches downloadable lesson content, it calls a single endpoint, /v1/content/auth, and sends an installation identifier: a random UUID generated on your device at first launch. It is not the Apple advertising identifier, it is not linked to your name, your email or your Apple Account, and it changes if you uninstall and reinstall the app. We use it only to rate-limit access to lesson content and to prevent abuse. It is never attached to the words you look up, to your pronunciation recordings, or to any of the AI requests described above.

Technical metadata. Like any web server, our backend logs standard connection metadata (IP address, user-agent, timestamp) when you make a request. These logs are retained for up to 30 days for security and debugging, then rotated out.

3. Third parties we share data with

To provide the AI features of Pico Picks, we relay certain requests to the following sub-processors. No other third parties receive your data.

• Apple Inc. (United States) — distributes the App through the App Store and, if you subscribe, processes the subscription via StoreKit. Receives a transaction identifier and your App Store account locale; we do not receive your payment card details. Apple also operates iCloud and the private CloudKit database in which your learning data is synced (see §2); that data belongs to your Apple Account and is governed by Apple's own privacy policy.
• OpenAI, LLC (United States) — generates vocabulary definitions and translations via GPT models. Receives only the word and the context outlined above.
• Anthropic, PBC (United States) — generates vocabulary definitions, enrichments and translations via the Claude Sonnet model, including as a fallback provider. Receives only the word and the context outlined above.
• Mistral AI (France / European Union) — generates the spoken audio of lesson dialogues. Receives only the dialogue text to voice.
• Microsoft Azure AI Speech (European Union region) — evaluates pronunciation quality when you record yourself saying a target word. Receives the audio sample and the target word. Audio is processed and discarded; it is not stored by Microsoft for training.
• Cloudflare, Inc. (United States, edge data centers worldwide) — relays and caches the AI requests above through our backend (Cloudflare Workers and the Workers KV response cache). Acts as a technical intermediary. Cache entries are keyed by an SHA-256 hash of the search term, your CEFR level and your home language only — they contain no user identifier. Transfers covered by the Standard Contractual Clauses (Decision 2021/914) under the Cloudflare Customer Data Processing Addendum.
• Hostinger International Ltd (Cyprus / European Union) — hosts the rougegorge.app server (pronunciation, content reports). Acts as a technical provider and does not otherwise access the data.

Apple, OpenAI, Anthropic and Cloudflare are located in the United States. Transfers outside the European Economic Area are covered by the European Commission's Standard Contractual Clauses (SCC) as published in Decision 2021/914. Mistral AI is located in the European Union.

4. How long we keep data

• On-device data: stored until you delete it from within Settings or uninstall the app. We have no access to it.
• Data synced to your iCloud account: kept in your private iCloud database for as long as you leave it there. Uninstalling the app does not delete it, and neither do we — we have no access to it. Delete it from within the app (Settings) or from your iOS iCloud settings.
• Backend cache of definitions: up to 90 days from last use, then evicted. The cache is keyed by an SHA-256 hash of the lookup (search term + CEFR level + home language) and is not tied to individual users.
• Installation identifier: kept on your device until you uninstall the app. On our side it is used only to rate-limit lesson downloads and is not attached to a user profile or to your lookups.
• Content reports: up to 90 days, then deleted. Used only to improve AI output quality.
• Access logs: up to 30 days for security and debugging.
• Pronunciation audio: deleted immediately after the score is returned to the app. Not persisted.

5. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• rectify inaccurate data;
• request the deletion of your data (data held only on your device is removed when you delete it in Settings or uninstall the app; data synced to iCloud must be deleted from within the app or from your iCloud settings, since we cannot reach it; for backend data, write to us);
• restrict or object to processing;
• obtain a portable copy of your data (the app can export your library and progress);
• withdraw any consent you previously gave (e.g. the consent screen shown during onboarding);
• lodge a complaint with the French supervisory authority, the CNIL (www.cnil.fr).

To exercise any of these rights, write to contact@rougegorge.app. We respond within one month.

6. Legal basis for processing

• On-device storage of your profile, vocabulary and learning history: execution of the contract to provide you with the app.
• Synchronisation to your private iCloud database: execution of the contract to provide you with the app across your devices.
• Backend relay to OpenAI / Anthropic / Mistral / Microsoft: execution of the contract and your explicit consent obtained during onboarding.
• Installation identifier sent to /v1/content/auth: our legitimate interest in rate-limiting the service and preventing abuse.
• Content reports you choose to send: your consent at the moment of sending.
• Security logs: our legitimate interest in protecting the service.

7. Children

Pico Picks is not intended for children under 13. During onboarding we ask you to confirm you are 13 or older with a single yes/no toggle; we do not collect or store a date of birth. If you believe a child under 13 has used the app, write to us and we will delete any associated data.

8. Security

All traffic between the app and the backend is encrypted over HTTPS using TLS 1.2 or 1.3, with the standard system certificate validation provided by iOS. On-device data is protected by iOS sandboxing and benefits from Apple's hardware-backed encryption when your device is locked. Data synced to iCloud is encrypted by Apple in transit and at rest within your private CloudKit container.

9. Changes to this policy

If we change this policy we will update the date at the top and, for material changes, notify you in the app on next launch. Continuing to use Pico Picks after a material change means you accept the new policy.

10. Contact

Questions about this policy or your data: contact@rougegorge.app.

Pico Picks: Vocab Learning · Tudual Lucas Huon, auto-entrepreneur · 21 Dom Morice, 35000 Rennes, France · SIREN 999 501 703