Privacy Policy

App: Sapling | Last updated: 9 September 2026

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 iPhone using Apple's SwiftData framework. If iCloud Backup is enabled for your iPhone and for Sapling, Apple may include this data in the encrypted device backup used when you restore or replace your iPhone. Sapling does not separately sync learning progress through CloudKit, and I cannot access your local or backup data.

Data collected automatically

Purchase and subscription data — subscriptions are processed by Apple through the App Store. I do not receive your Apple ID, name, or payment details.
Product analytics (PostHog) — to understand how the App is used and improve the learning experience, Sapling sends a small set of behavioural events to PostHog. These events include things like app opens, session starts and completions, paywall views, subscription purchases, onboarding completion, and learning milestones (streaks, words learned, levels gained). Each event is tagged with a randomly-generated anonymous identifier (a UUID stored only on your device) together with non-identifying properties such as your selected learning language, current level, and premium status. As with any internet request, your IP address is used to deliver the request to PostHog; Sapling instructs PostHog not to enrich events with IP-derived location. PostHog does not receive your name, email, Apple ID, contacts, device advertising identifier, or any content you type into the App.
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.

Microphone and speech recognition

During speaking exercises, Sapling uses your device's microphone and Apple's on-device Speech Recognition framework to check whether you pronounced the target word correctly. Audio is processed on your device (or, on older devices, by Apple's Speech Recognition service under Apple's privacy policy) solely to produce a pass/fail result for the exercise. I do not record, store, or transmit your voice, and no audio is sent to PostHog or any server I control.

Optional on-device AI explanations

On supported iPhones with Apple Intelligence available, you can request an AI explanation of an exercise. Sapling provides the question, your answer, the expected answer and built-in teaching notes to Apple's on-device Foundation Models framework. Sapling does not send these requests to an external AI service or analytics provider. Generated explanations are labelled as AI advice, may be inaccurate, and do not change answer marking or learning progress. They are not saved to your learning history.

Data I do not collect

Name, email address, or any account credentials
Location data (including IP-derived location)
Contacts or camera data
Stored voice recordings — Sapling does not save recordings; where on-device recognition is unavailable, Apple may process speech under its own privacy policy
Advertising identifiers (IDFA)
Any content you type into the App

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, diagnosing problems, and improving the learning experience using anonymised product-analytics data. I have assessed that this processing is proportionate, has minimal privacy impact (no PII, no tracking across apps or websites), and is what users would reasonably expect from a modern mobile app.

4. Third-Party Services

Apple Inc. processes in-app subscriptions. For details, see Apple's Privacy Policy.

PostHog Inc. provides product analytics. Sapling sends a small set of anonymous behavioural events (see Section 2) to PostHog's EU cloud at eu.i.posthog.com, tagged only with a random UUID generated on your device. PostHog acts as a data processor on my behalf and does not use the data for its own purposes. For details, see PostHog's Privacy Policy and Data Processing Addendum.

Apple, Inc. operates the App Store and payment processing, and provides the on-device Speech Recognition framework used for pronunciation exercises. See Apple's Privacy Policy.

5. Data Retention

Learning data — retained locally until you reset your progress or delete the App. A snapshot may remain in an existing iPhone backup according to Apple's iCloud Backup retention and deletion controls.
Subscription records — retained by Apple as necessary to manage your subscription and comply with financial regulations.
Product analytics events — retained by PostHog for up to 12 months and then automatically deleted. Because events are tied only to a random device-generated UUID, they cannot be linked back to you personally.

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.

9. Contact

Nicholas Cross
knack.sienna.6b@icloud.com
United Kingdom