Privacy Policy for AirTranslator

Controller (Art. 4(7) GDPR)

Dr. Alper Beser, Dr.-Golm-Str. 24, 27232 Sulingen, Germany
Email: AirTranslatorApp<at>gmail.com
No Data Protection Officer has been appointed; please direct privacy inquiries to the email above.

AirTranslator (hereafter also referred to as "app" or "Service") is a freemium translation app that is intended for use as is. The app is offered by the Service provider (hereafter also referred to as "we") at no cost in its free form. It offers paid in-app purchases for enhanced functionality.

This page is used to inform visitors regarding our policies with the collection, use, and disclosure of personal data if anyone decided to use our Service. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us (AirTranslatorApp<at>gmail.com).

If you choose to use our Service, we will process your personal data only as described in this Privacy Policy and in accordance with applicable law. The personal data that we collect is used for providing and improving the Service. We will not use or share your personal data with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms of Use, which is accessible at Terms of Use unless otherwise defined in this Privacy Policy.

What is Personal Data?

"Personal data" refers to any information that can be used to identify an individual, either directly or indirectly. This includes, but is not limited to:

Under the GDPR, personal data means any information relating to an identified or identifiable natural person.

Consents & Settings

For analytics and attribution SDKs that store or access information on your device (e.g., IDFA/installation IDs), we obtain your prior consent in the app (GDPR Art. 6(1)(a) in conjunction with § 25 TTDSG; App Tracking Transparency on iOS). You can withdraw consent at any time (see Opt-out options below); withdrawal does not affect the lawfulness of processing before withdrawal and does not impair essential app functions.

Information Collection and Use

As the Service does not require a registration for accessing its features, it does not collect private information such as names and Email addresses. For a better experience, the Service may collect certain personally identifiable information, including but not limited to a unique device ID and Internet Protocol ("IP") address. These statistics are used for improving the Service quality, e.g., for improving the stability or performing A/B tests. To accomplish this, the app uses third party services for device reports that may collect information used to identify you.

Links to the Privacy Policies of third party service providers used by the app:

The Service uses the built-in speech recognizer functionality of iOS and iPadOS provided by Apple. For recognizing your speech, your voice data is sent to Apple's servers and may be cached locally on your device. The voice data is not sent to our servers or any other third party. The transcription the app receives from Apple's servers is then translated using Google's AI services. To provide the translation, the text is transmitted to Google for processing. Depending on the specific Google service used, Google may act either as our processor (Firebase/Vertex AI under data processing terms) or as an independent controller under its own terms. We configure available settings to disable training/logging where possible; we do not store translations on our own servers.

AI Translation (Firebase AI / Google Gemini)

When you use translation features, the app sends the text to be translated ("strings") to Google services (Firebase AI / Google Gemini) for processing. Depending on your location, this processing may occur on servers in the United States. We do not store these strings on our own servers; they are transmitted to Google solely to provide the translation and returned to your device.

Please avoid including sensitive personal data in text you submit for translation. Processing by Google is governed by Google's terms and privacy notices. For details, see Firebase Privacy and Security and the Google Privacy Policy. We configure available settings to prevent use of submitted content for model training and disable logging where possible.

Legal basis (GDPR): Contract performance (Art. 6(1)(b)) to provide translations you request; and our legitimate interests (Art. 6(1)(f)) in operating and securing our services.

If you contact us via Email, we may save your Email, name, and other information you provided in your Email. This data is saved by us to contact and respond to your inquiries, questions, bug reports, or feature requests. Legal basis (GDPR): Art. 6(1)(b) if your inquiry is contractual/pre‑contractual; otherwise our legitimate interests (Art. 6(1)(f)) in efficiently handling your request. You have the right to request that we delete this information after finishing the processing of inquiries included in your Email. Please see the "GDPR Data Protection Rights" section for further details.

Log Data

We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your device called Log Data. This Log Data may include information such as your device Internet Protocol ("IP") address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics related to the usage of the Service. Legal basis (GDPR): our legitimate interests (Art. 6(1)(f)) in ensuring technical security, stability, and debugging.

Access to or storage of information on your device that is not strictly necessary occurs only with your prior consent (§ 25 TTDSG).

SDKs and Tracking Technologies

Our mobile app uses Software Development Kits (SDKs) such as Firebase and AppsFlyer. These technologies may access or store identifiers on your device (e.g., installation IDs, IDFA/IDFV) to provide analytics, crash reporting, or attribution.

We only use non-essential SDKs (analytics/attribution) with your prior consent (Art. 6(1)(a) GDPR, § 25 TTDSG). You can grant or withdraw consent (see Opt-out options below). Essential technologies required to provide the service may be used without consent.

Analytics and Advertising

We use Google Analytics for Firebase and other analytics tools (please see links above) to understand how our app is used and to improve our services. This helps us analyze usage patterns, identify bugs, and optimize performance.

Data collected for analytics includes:

Where supported, we enable IP anonymization or truncation and collect location only at the country/region level.

Opt-out options:

We do not display third‑party ads in the app. If we run marketing campaigns, we may use AppsFlyer solely for install attribution and engagement measurement. See AppsFlyer Services Privacy Policy and opt‑out options at AppsFlyer Opt‑Out. Legal basis (GDPR/TTDSG): your consent (Art. 6(1)(a) GDPR; § 25 TTDSG). Fraud prevention may also rely on our legitimate interests (Art. 6(1)(f)). You can withdraw consent at any time in the app settings.

AppsFlyer Attribution and Measurement

We use AppsFlyer to attribute app installs and measure campaign performance. AppsFlyer may collect device identifiers (e.g., IDFA), IP address, device/OS information, and in‑app event data to understand how users discover and engage with the app, detect fraud, and improve app performance. Processing by AppsFlyer is described in its Services Privacy Policy. You can manage tracking permissions via iOS App Tracking Transparency and review AppsFlyer's opt‑out page: https://www.appsflyer.com/legal/opt-out/.

Legal basis (GDPR/TTDSG): your consent (Art. 6(1)(a) GDPR; § 25 TTDSG) for analytics/attribution identifiers and processing; fraud prevention may additionally rely on legitimate interests (Art. 6(1)(f)).

Legal Basis for Processing

We process your personal information based on the following legal grounds under GDPR Article 6:

Where we rely on legitimate interests, we have conducted a balancing test (Legitimate Interests Assessment). A summary can be provided upon request.

All processing is necessary for the purposes stated and we strive to minimize data collection to what is strictly required.

Service Providers

We may employ third-party companies and individuals (please see links above) due to the following reasons:

We use third-party providers to deliver our services. Depending on the service, these providers act either as processors (Art. 28 GDPR) under our instructions or as independent controllers under their own responsibility. Where a provider acts as our processor, we have entered into data processing agreements and require appropriate security measures. Where a provider acts as an independent controller (e.g., Apple Speech), processing is governed by that provider’s privacy notices.

Processing Overview

Speech recognition (Apple Speech Recognizer)
Purpose: convert speech to text in the app.
Data: audio content, device/OS data, IP address.
Legal basis: Contract performance (Art. 6(1)(b)).
Recipient/role: Apple – independent controller for speech processing per Apple policies.
Retention: no storage by us; Apple processes per its policies.

Translation (Google Gemini/Firebase AI)
Purpose: translation of user-provided text strings.
Data: text strings; technical metadata (IP/identifier).
Legal basis: Contract performance (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f)) for service operation/security.
Recipient/role: Google – processor when using Firebase/Vertex AI under data processing terms; independent controller where Google provides the AI service under its own consumer terms. Model training/logging disabled where available.
Retention: no storage by us; Google retains only for necessary short periods as per its policies.

Crash and performance (Firebase Crashlytics/Analytics)
Purpose: stability, error diagnosis, product improvement.
Data: crash dumps, device type, OS/app version, IP/identifiers (with consent for non-essential identifiers).
Legal basis: Consent for analytics/identifiers (Art. 6(1)(a), § 25 TTDSG); without consent only strictly necessary measurements.
Recipient/role: Google – processor (Firebase) under data processing terms.
Retention: crash data typically up to 90 days; analytics up to 14 months (configurable; default ≤ 14 months).

Attribution (AppsFlyer)
Purpose: campaign measurement and fraud prevention.
Data: IDFA/IDFV (if granted), IP, device data, in‑app events.
Legal basis: Consent (Art. 6(1)(a), § 25 TTDSG); fraud prevention may rely on legitimate interests (Art. 6(1)(f)).
Recipient/role: AppsFlyer – processor under data processing terms.
Retention: up to 24 months (configurable). Shorter periods may apply where configured.

Support contact
Purpose: respond to inquiries and support requests.
Data: email address, message content, metadata.
Legal basis: Art. 6(1)(b) (contractual/pre‑contractual) or our legitimate interests (Art. 6(1)(f)).
Retention: 6 months after ticket closure unless legal obligations require longer.

Provision of Data

Providing audio or text for translation is necessary to use core features of the app. We do not store your audio or text on our servers. Granting consent for analytics and attribution is optional; if you withhold or withdraw consent, these features remain disabled and the app’s core translation functions continue to work.

Source of Data

We collect personal data directly from you and your device during app use (via the app and integrated SDKs). We do not obtain data from third‑party data brokers.

Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence. In particular, data sent to Google (translation), Apple (speech recognition), and AppsFlyer (attribution) may be processed in the United States.

Where the recipient participates in the EU–US Data Privacy Framework (DPF), transfers rely on the adequacy decision under Art. 45 GDPR. Otherwise, we use Standard Contractual Clauses (Art. 46 GDPR) and conduct transfer impact assessments with supplementary measures where appropriate. Such transfers may carry a residual risk of government access in third countries.

Data Retention

We retain personal data only for as long as necessary for the purposes described above or as required by law. Unless stated otherwise: support emails are deleted 6 months after ticket closure; crash data is retained up to 90 days; analytics data up to 14 months (configurable; default ≤ 14 months); attribution data up to 24 months (configurable). Shorter periods may apply where configured. You may request deletion as described under "GDPR Data Protection Rights" below.

Backups may retain technical copies for a limited period; these are automatically overwritten and are not used for active processing.

Data Breach Notification

In the event of a data breach that poses a risk to your personal information, we will notify affected users and relevant authorities as required by applicable law. This includes:

If you suspect a data breach has occurred, please contact us immediately at AirTranslatorApp<at>gmail.com.

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights according to the GDPR. Every user is entitled to the following rights:

The right to access (Article 15): You have the right to request copies of your personal data. We may charge you a small fee for this service if your request is manifestly unfounded or excessive.

The right to rectification (Article 16): You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure ("right to be forgotten") (Article 17): You have the right to request that we erase your personal data, under certain conditions such as when the data is no longer necessary for the purposes for which it was collected.

The right to restrict processing (Article 18): You have the right to request that we restrict the processing of your personal data, under certain conditions such as when you contest the accuracy of the data or when processing is unlawful.

The right to object to processing (Article 21): You have the right to object to our processing of your personal data, under certain conditions, particularly when processing is based on legitimate interests or for direct marketing purposes.

The right to data portability (Article 20): You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

To exercise any of these rights: Please contact us at AirTranslatorApp<at>gmail.com with your request. We have one month to respond to you from receipt of your request. In some cases, we may need to verify your identity before processing your request. If your request is complex or you have made multiple requests, the response time may be extended by up to two additional months. You may withdraw consent at any time, and you may object to processing based on legitimate interests (Art. 21 GDPR).

You also have the right to lodge a complaint with a supervisory authority if you believe that your data protection rights have been violated. Our competent authority is: Die Landesbeauftragte für den Datenschutz Niedersachsen, Prinzenstraße 5, 30159 Hannover, Germany, Phone: +49 511 120-4500, Email: poststelle@lfd.niedersachsen.de.

Security

We value your trust in providing us your personal data, and we strive to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

We implement technical and organizational measures including TLS encryption in transit, access controls (least privilege), logging and monitoring, regular deletion schedules, and data processing agreements with our processors.

In‑App Purchases

Payments are processed by Apple (App Store). We do not receive or store your payment card details. We process purchase receipts and anonymous transaction metadata to provide the service and for fraud prevention (Art. 6(1)(b)/(f) GDPR).

Children's Privacy

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

This Service is not directed to children under the age of 16 in the EEA. We do not knowingly collect personally identifiable information from children under 16. In the case we discover that a child under 16 has provided us with personal information, we will promptly delete it. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we can take appropriate action.

Automated Decision‑Making

We do not engage in automated decision‑making, including profiling, that produces legal effects concerning you or similarly significantly affects you within the meaning of Art. 22 GDPR. Analytics and attribution may create usage profiles for measurement purposes only and are not used for individual decisions.

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the corresponding privacy policies of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Language

If we provide this policy in multiple languages, the German version prevails for users in Germany and the EEA.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. For material changes, we will provide advance notice in‑app or by email at least 7 days before the new policy takes effect. This policy is effective as of 19 October 2025

Imprint

Dr. Alper Beser
Dr.-Golm-Str. 24
27232 Sulingen, Germany

Contact Us

If you have any questions or suggestions about this Privacy Policy, contact us at AirTranslatorApp<at>gmail.com.