Privacy Policy

1. Who we are

This Privacy Policy applies to the services provided by KineticLab, including our website kineticlab.app and our mobile applications Test CCSE, DELE A2, DELE B1, DELE B2, DELE C1, DELE, Almanac and Almanac Coach.

For privacy questions, data requests or deletion requests, you can contact us at [email protected].

The legal entity responsible for processing personal data (the data controller) is: KineticLab OÜ.

2. Data we collect

We aim to collect only the data needed to provide, maintain, improve and secure our products. Depending on how you use our services, we may process:

• Contact data: such as your email address if you contact us directly.
• Account data: such as your email address, user identifier and sign-in provider, when you use features that require an account.
• Technical and device data: such as device type, operating system, app version, language, diagnostics and crash information.
• Usage data: such as interactions with app features, learning progress, completed tests, workout records in Almanac and Almanac Coach, or premium access status, depending on the product and features you use.
• Purchase data: information needed to validate in-app purchases, subscriptions, renewals, cancellations, refunds and premium access, such as transaction identifiers, purchased products, renewal status and validity dates.
• Support data: any information you voluntarily submit when requesting help.

We do not knowingly collect national identity numbers, payment card details, health data, biometric data or other sensitive information through Test CCSE.

3. How we use data

We use data for the following purposes:

• To provide and operate our applications and website.
• To unlock premium features following a valid purchase.
• To restore purchases and prevent purchase abuse or fraud.
• To improve product quality, performance and user experience.
• To diagnose errors, crashes and technical issues.
• To respond to support requests and user enquiries.
• To comply with legal, tax, platform and security obligations.

4. Legal bases for processing

Where applicable under the GDPR or similar laws, we rely on the following legal bases:

• Contract: to provide the app, premium features and support you request.
• Legitimate interests: to improve, secure and monitor our services.
• Consent: where required for optional features or communications.
• Legal obligation: where we must retain or process data for compliance purposes.

5. Purchases, subscriptions and RevenueCat

Depending on the product, our applications, including Test CCSE, DELE A2, DELE B1, DELE B2, DELE C1, DELE, Almanac and Almanac Coach, may offer in-app purchases or subscriptions to unlock premium features. Purchases are processed by the relevant store, such as the Apple App Store or Google Play. We do not receive or store your full payment card details.

We use RevenueCat to validate purchases, manage access entitlements, restore purchases and check subscription status. For these purposes, RevenueCat may process app user identifiers, purchase receipts or identifiers, technical device information, and transaction and subscription metadata.

When you access subscription management, the app may check your subscription status or the available management link to open the relevant store’s subscription screen. Cancellation must be completed in the Apple App Store or Google Play; pressing the button in the app does not automatically cancel your subscription.

• DELE A2, DELE B1, DELE B2, DELE C1 and DELE: You can access subscription management from Profile > Account > Manage subscription.
• Almanac and Almanac Coach: You can access subscription management from Settings > Account > Cancel subscription.

Cancelling renewal does not delete your data: Cancellation does not, by itself, delete your account, your progress or other associated data. The processing and retention of that data are governed by this Policy and the rights you may exercise. Premium access conditions and the full cancellation steps are explained in our Terms of Use.

You can learn more about RevenueCat’s privacy practices here: RevenueCat Privacy Policy. To request deletion of data processed by RevenueCat on behalf of KineticLab, you can contact us at [email protected].

6. Third-party services

We may use trusted third-party providers to operate our website and applications, including hosting, analytics, crash reporting, app store distribution, payment validation and support tools.

Depending on the product and platform, these providers may include:

• Google Play and Google services for Android distribution, billing and app management.
• Apple services for iOS distribution and billing, where applicable.
• RevenueCat for purchase management and access entitlement validation.
• Hosting and infrastructure providers used to deliver our website and services.

We only share data with third parties where necessary to provide our services, comply with the law, process purchases, maintain security or improve reliability.

7. Data retention

We retain personal data only for as long as necessary for the purposes described in this Policy. Retention periods may vary depending on the type of data and the reason it is processed.

• Support emails are retained for as long as necessary to respond and maintain service records.
• Purchase records may be retained as needed to restore access, prevent fraud and comply with accounting or platform obligations, where a legal basis permits this.
• Technical and diagnostic logs are generally retained for a limited period unless needed for security or debugging purposes.

Cancelling a subscription does not automatically initiate a data deletion request. If you keep an account to use free features, the data needed to provide that service may continue to be retained in accordance with this Policy. If you request erasure, we will handle your request in accordance with applicable law.

Where a legal obligation or the establishment, exercise or defence of legal claims requires us to retain certain records, retention will be limited to the data and period necessary for that purpose. Having previously held a subscription does not, by itself, justify retaining all your data indefinitely.

8. Data security

We use reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. However, no internet or mobile service can be guaranteed to be completely secure.

9. International transfers

Some service providers may process data outside your country or region, including outside the European Economic Area. Where required, we rely on appropriate safeguards, such as contractual protections or other lawful transfer mechanisms.

10. Your rights

Depending on your location, you may have rights concerning your personal data, including the right to access, rectification, erasure, restriction of processing, objection to processing, data portability or withdrawal of consent where processing is based on consent.

To exercise your rights, contact us at [email protected].

If you are in the European Union or a similar jurisdiction, you may also have the right to lodge a complaint with your local data protection authority.

11. Account deletion and data deletion

In applications that allow you to create an account, you can use the deletion option available in the Account section of your profile or settings, depending on the product. You can also request deletion of your account or associated personal data by contacting us at [email protected].

Test CCSE does not require users to create an account for basic use. If you request deletion of data associated with support messages or app identifiers, we will handle your request in accordance with applicable law.

Accounts shared across applications: The DELE A2, DELE B1, DELE B2 and DELE C1 applications may use a shared account. Deleting that account may affect data and access in other linked DELE applications, as indicated in the confirmation notice. In the DELE application, the deletion option removes data associated with that app, but retains the shared user account and the data of the standalone DELE A2, DELE B1, DELE B2 and DELE C1 applications. If you also wish to request deletion of the shared user account or other personal data, you can write to us at the email address provided.

When handling an erasure request, we may need to verify that you are the person to whom the data relates or the account holder. Deletion will be carried out in accordance with applicable law, taking into account legal exceptions and the retention criteria described in section 7.

Data deletion and subscription cancellation are separate actions: Signing out, uninstalling the app, deleting your account or deleting an app’s data does not cancel subscriptions in the Apple App Store or Google Play. If you do not want future renewals and charges, cancel your subscription in the relevant store before deleting your account or data. You can access subscription management using the buttons described in section 5 or directly through your Apple or Google account. Deleting data from our services also does not automatically delete records that Apple or Google process under their own policies and legal obligations.

12. Children’s privacy

Our services are not directed at children under the age of 13, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so that we can take appropriate action.

13. Cookies and website data

Our website may use cookies or similar technologies for basic functionality, performance, analytics or security. You can control cookies through your browser settings. Disabling cookies may affect some website features.

14. Changes to this Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the “Last updated” date at the top. If the changes are significant, we may provide additional notice where appropriate.

15. Contact

If you have questions about this Privacy Policy or how we handle personal data, contact us at:

KineticLab
Email: [email protected]
Website: https://kineticlab.app/