Privacy Policy
1. Operator and scope
Reading Lobster is an app for learning languages through reading, listening and word practice. This policy covers the iOS app, its supporting servers, the AI-assistant connector and readinglobster.com.
The controller responsible for personal data is Anastasiia Kirzhanova, trading as Soba Apps, Am Kutscherhaus 6, 12555 Berlin, Germany. Contact: hello@readinglobster.com. This policy calls her “the operator”. The operator’s legal notice is included in the Impressum.
The app is intended for users aged 16 and over.
2. Information processed
Reading Lobster processes the following information:
- Account and profile: an account or guest ID; email address and sign-in information where applicable; information supplied through Apple or Google sign-in; languages, levels, interests, display name and learning preferences; privacy choices and permission records.
- Learning materials: imported texts, photographs and links; prompts and answers submitted to Lobster; generated texts, translations, quizzes and audio; saved words, examples, notes and corrections; learning progress and reading or listening positions.
- Writing history: titles, summaries, character names and selected details of earlier generations, used to help Lobster avoid repetition.
- Purchases: subscription status, product and transaction identifiers, purchase dates, promotional access, credit balances and spending. Apple processes payment details; Reading Lobster receives purchase information through RevenueCat.
- Feedback and requests: comments, ratings, survey responses, the relevant text or card, technical context and an account reference; correspondence; a requested language and the email address supplied for notification.
- Technical information: IP addresses, request and error information, app and device details, usage events and campaign attribution. Notifications and external-assistant connections also require device tokens or authorisation records.
The app stores sign-in credentials, settings, cached materials and pending progress on the device. Uninstalling it does not delete server data; sign-in information in the device’s Keychain may also remain.
3. Purposes and legal bases
| Purpose | GDPR basis |
|---|---|
| Providing accounts, learning features, requested AI processing, purchases and credits; responding to requests about them | Performance of a contract, Article 6(1)(b) |
| Security, preventing abuse and investigating technical problems | Legitimate interests in protecting users and maintaining the app, Article 6(1)(f) |
| Product analytics, campaign measurement and promotional-code administration | Legitimate interests in understanding app use and assessing promotion, Article 6(1)(f) |
| Feedback, general correspondence and the beta review in section 8 | Legitimate interests in responding to users and improving the app, Article 6(1)(f) |
| Email notification about a requested language | Consent, Article 6(1)(a) |
| Compliance with legal duties | Legal obligation, Article 6(1)(c) |
| Establishing, exercising or defending legal claims | Legitimate interests, Article 6(1)(f), or a legal obligation where applicable |
Information necessary for a requested feature is needed for that feature to work. Feedback and language requests are optional. The app does not make solely automated decisions with legal or similarly significant effects on the user.
4. Information chosen by the user
The user chooses what to submit and is responsible for having the right to provide that material, including information about other people. Content submitted for an AI feature is passed to the providers described below.
Only details needed for language practice should be included. Fictional details can be used instead of real health information or other sensitive personal information. The operator remains responsible for the processing carried out under the operator’s control.
5. AI features and dictation
The app requests permission before transferring content to its AI providers. Requests for built-in AI features pass through Reading Lobster’s servers. The relevant content and learning settings are sent to the provider needed for the action. The registration email and account ID are not added to prompts as account identifiers, but submitted content can itself identify a person.
Anthropic processes content for writing, translation, word explanations, quizzes and related learning features, and can process photographs as a fallback for image recognition. Requests can include profile preferences and relevant writing-history entries. Under its commercial API rules, Anthropic does not train on customer content by default. Standard API inputs and outputs are normally deleted within 30 days; safety and legal exceptions can require longer retention. See Anthropic’s training rules and retention rules.
Google Gemini processes photographs to extract text. The whole submitted image is sent, including any personal details visible in it. Reading Lobster uses the paid API. Google’s API terms exclude using paid-API prompts and responses to improve its products. Google’s abuse-monitoring rules provide for 55 days of retention and possible review of flagged content for policy enforcement.
ElevenLabs receives text to generate spoken audio. Model training is disabled for the operator’s account. Text and audio can remain in the provider’s generation history. Deleting a Reading Lobster library entry does not automatically delete this history. ElevenLabs provides deletion tools, while separate moderation, debugging and backup retention can apply. See its retention rules and data-processing terms.
Apple dictation converts speech into text on the device where supported, or through Apple’s speech-recognition infrastructure. The recognised text can be reviewed and edited before submission. These dictation features send Reading Lobster the submitted text rather than the voice recording.
Requests to stop future AI transfers or exercise deletion rights can be sent to hello@readinglobster.com. The operator handles applicable requests using the controls and assistance available from the providers. Retention required for security, legal duties or backup recovery is governed by the relevant rules; immediate deletion of every provider copy is not guaranteed.
6. Analytics, diagnostics and website use
Reading Lobster uses PostHog to understand app usage and measure Apple Ads campaigns. Events can include the feature used, language and level, app and device details, subscription status and credit balance. They can be associated with an account or guest identifier. Campaign attribution can include campaign identifiers and country or region.
Product analytics can be disabled in Profile without losing app features. The choice is synchronised with the server. The operator can also be contacted about previously collected information.
Product-event fields are designed to exclude texts, prompts and photographs. Error messages may contain details from a failed operation. Session recordings and screenshots are disabled.
Sentry and server logs help investigate failures and protect the app. Sentry reports from the iOS app are configured without the Reading Lobster account identifier. Reports can contain app and device information, navigation context and technical errors. Server logs can contain IP addresses, request information and diagnostic details. These diagnostics operate separately from the product-analytics setting.
Website hosting and content-delivery providers receive the IP address and technical request information needed to deliver pages and their resources. Promotional links can record aggregate campaign clicks. Importing a web link causes the Reading Lobster server to request that address from the relevant website; a personalised URL may itself contain identifying information.
7. Recipients and international processing
In addition to the AI, analytics and diagnostics providers identified above, the operator uses providers of hosting, authentication, databases, file storage, purchase administration, email delivery and support or feedback tools. These providers receive information needed for the relevant function. Feedback tools can hold submitted comments, ratings, the related text title or card and an account reference.
Apple processes information for App Store purchases, sign-in, push notifications, TestFlight, dictation and campaign attribution. Apple and external sign-in providers also process information under their own privacy policies.
Providers processing information on the operator’s instructions act as processors under data-processing terms. Providers may separately act as controllers for their own billing, security or legal purposes. Information may also be disclosed where required by law or necessary to address a legal claim.
The operator can access data when needed for support, operation, security, legal requests and the beta review described below.
External AI assistants
When the user authorises a connection, an external assistant can receive profile and learning settings, display name, interests, remaining credits, basic library information and selected saved vocabulary. It can also add prepared learning materials. Reading Lobster receives the material included in connector requests.
The assistant’s provider handles received information under its own terms. Profile → Connect your AI allows the user to disconnect it. Disconnecting stops further access through that connection; existing copies remain subject to that provider’s retention rules.
International transfers
The main database and application server are hosted in Germany. Some providers and support teams process information outside the European Economic Area, including in the United States.
For transfers requiring contractual safeguards, the operator relies on the European Commission’s Standard Contractual Clauses provided through the suppliers’ data-processing terms. Details of the applicable safeguards, including a copy, can be requested from hello@readinglobster.com, subject to necessary redactions.
8. TestFlight beta testing
This section applies to TestFlight beta programmes before or after the app’s public release.
During beta participation, the operator has access to and may read all texts generated through Lobster, including personal templates and free topics, together with the prompts and answers used to create them. This human review is used to assess generation quality, investigate problems and improve the AI writer. Imported texts and materials supplied through an external assistant are outside this routine beta review.
The operator also reads feedback and survey responses. Apple handles TestFlight feedback and diagnostics under its own terms. The user can object to processing based on legitimate interests as described in section 10.
9. Retention and deletion
Account information and learning materials are generally kept while the account exists. Individual materials and accounts can be deleted through the app.
Deleting a library text does not automatically delete saved word cards and their example sentences, writing-history entries, or separate card and export audio. These are removed with the account or handled through a separate deletion request.
A guest profile without active Plus access is eligible for deletion after 730 consecutive days without activity, including its library, progress and remaining credits. Registering an account avoids this guest-inactivity rule.
| Information | Retention period or criterion |
|---|---|
| Temporary import files | Removed after a successful import; abandoned files are cleaned up after 30 days |
| Analytics and attribution | Up to 24 months |
| Sentry reports | Up to 90 days |
| Language-notification requests | Until the notification purpose ends or consent is withdrawn, and no longer than 24 months |
| Feedback | Up to 24 months in active feedback systems, followed by the provider’s deletion and backup cycle |
| Correspondence | While needed to deal with the request or a related legal claim |
| Operational logs | Normally rotated over 14 days, with copies in routine server backups for up to a further week |
| Backup copies | Until replaced or deleted through the backup cycle; kept for recovery rather than ordinary use |
Account deletion removes active personal account and learning records and starts cleanup of stored files and associated purchase-management and analytics records. External cleanup can take additional time. Correspondence, feedback copies, provider records and backups follow their respective retention rules and remain subject to applicable deletion rights. Records required for a legal obligation or claim are kept for that purpose.
The AI providers’ retention rules are described in section 5. Apple and connected-assistant providers control their own independent records. Files exported by the user follow the settings of the chosen device or destination.
An Apple subscription must be cancelled separately from account deletion.
10. Rights and contact
Subject to the conditions in the GDPR, the user can request access, correction, deletion, restriction of processing and a portable copy of qualifying data.
Consent can be withdrawn at any time for future processing. The user can object to processing based on legitimate interests because of the user’s particular situation. The operator assesses the objection and stops the processing unless the law permits it to continue.
The app provides Profile → Delete account for registered accounts and Profile → Delete your data for guests. Other privacy requests can be sent to hello@readinglobster.com. Identity verification may be needed. Requests are normally answered within one month; any legally permitted extension is explained within that period.
A complaint can be made to a data-protection authority, including the Berlin Commissioner for Data Protection and Freedom of Information.
11. Changes
The current policy is available at readinglobster.com/privacy. Material changes are communicated through the app or another appropriate channel. Where new processing requires consent, it is requested before that processing starts.