Privacy policy

Last updated: 2026-10-27

This policy explains what personal data Rinava processes, why we process it, who else is involved, and what you can ask us to do. It is written to meet the General Data Protection Regulation (GDPR).

This policy covers the Rinava app on Apple devices and on Android. Where the two versions work differently, this policy says so.

We do not show advertising, we do not sell personal data, and we do not track you across other apps or websites.

1. Who is responsible

The controller for the processing described here is:

Little Whale Holding B.V.
Jeroen Boschplantsoen 150
1318 HJ Almere
Netherlands
Chamber of Commerce (KvK) number: 75064642
VAT (BTW) number: NL860127515B01
support@littlewhale.io

2. What data we process

Account data

You can sign in with Sign in with Apple or with Google Sign-In. From that sign-in we receive a stable identifier for your account and your email address. Sign in with Apple lets you hide your email address; in that case we receive Apple’s private relay address instead of your own. We do not ask Apple for your name, and we do not keep the name or profile picture that Google includes in its sign-in. The Android app offers only Google Sign-In.

App and device details

The app sends our server some details about the app and your device with its requests. When you are signed in, we store these details with your sign-in on that device, so they are linked to your account. We update them when you sign in, when you open the app and when you come back to it. The details are:

whether you use the app on an Apple device or on Android;
the app version and build number, and the version of iOS or Android;
the type of device: phone, tablet, Mac or other;
where the app came from: the App Store, TestFlight, Google Play, another source, or one of our own test builds;
the language of the app’s interface;
the last time you opened the app or came back to it;
on Apple devices only, the country or region of your App Store account;
on Android only, whether the app runs on one of Google’s automated test devices (Firebase Test Lab).

These details do not include advertising or device identifiers, the exact device model or your location, and we do not use your IP address for them. We use them to keep the app working on the versions and devices that people use, to tell real use apart from tests, to count how many people use the app, and to see in which countries and languages people use it. When you use the app as a guest, we do not store these details.

Learning data

This is the data the app needs in order to be useful to you: the languages you chose, your progress, your practice records and roleplay history, and your favourites. When you are signed in, this data is synced to our server so it survives a new device. When you use the app as a guest, it stays on your device and is not sent to us.

Learning plan

Members can let Rinava plan their learning. When you set up a plan, we store your answers: the days you want to learn, or that you have no fixed days; how many minutes you want to learn each day, or each week when your days are flexible; the reminder time you chose; and your time zone. We also store the topics you want to start with, the order of the themes in your route, and the themes and steps that you mark as already known.

While you learn, we store the kind of lesson planned for a given day (a new lesson, a review lesson, a theme recap or a rest day), whether you skipped the warm-up, the result of each theme recap (for each scene, solid or needs practice, with the reasons), and the scenes that the plan marks as mastered. We also record when you have listened to most of a scene's audio explanation, so the plan can tick off that step. If you choose to stop for the day, we store that choice for up to 7 days.

We use this data to plan your lessons, show your progress and schedule the reminders you chose. It is stored with your account and synced like your other learning data. Our server works out your plan from this data by fixed rules; planning uses no AI model. The steps of a lesson are the app's existing features, so a roleplay step uses AI as described in section 4. The reminder time is stored with your plan, and the app schedules the reminders on your device. We keep the other data until you delete your account, including after your membership ends.

Content you submit to the AI features

Conversation practice text and requests for help with an expression are processed to produce the response you asked for. Section 4 describes how that works.

Feedback you send in the app

When you are signed in, you can send us feedback in the app under Me → Feedback and suggestions and read our replies there. This works the same in the app on Apple devices and on Android. We receive what you write, the category if you choose one, and any screenshots you choose to attach (up to 3 per message). The app also sends the technical details that the form lists, and you can check them before you send: the app version, device model, iOS or Android version, the languages you chose, the screen you were on, recent failed requests and the identifiers of error reports, network and sync status, display and accessibility settings (for example dark mode, text size and whether a screen reader is on), sound settings on Apple devices, and the time and time zone. We store your feedback with your account.

Feedback can be linked to one roleplay. When you send feedback from a roleplay screen, it is linked to that roleplay. This includes a temporary roleplay that you have not ended yet. When you send feedback from Me, it is linked to your most recent saved roleplay that ended in the last 10 minutes, if there is one. A temporary roleplay that has ended is never linked. The form shows the link, and you can remove it before you send.

When a roleplay is linked, we store a copy of that conversation with your feedback: the partner’s lines, the sentences you wrote or said, their subtitles, and the scene they belong to. The copy stays with your feedback when the roleplay ends or is deleted, and also when you delete your roleplay history. It is deleted only when you delete your account.

When you take a screenshot, the app may ask whether you want to send feedback with it. That screenshot stays on your device and is discarded unless you send it. You can turn off Ask about feedback after a screenshot in Settings.

When you use the app as a guest, the feedback option opens your own email app with a message to support@littlewhale.io. The message contains the technical details above, and the screenshot if you started from one. You can change or remove them before you send. The app itself sends nothing to our server, and we handle the email as support email.

We use your feedback to answer you, to find and fix the problem you report, and to improve the app. Our team reads and answers it, with help from AI assistants by Anthropic and OpenAI (see section 5). The notification email that tells us about new feedback does not contain your text, your screenshots or the copy of a roleplay.

Voice input

When you speak instead of typing, in roleplay practice, when you ask for help with an expression or when you write feedback, Apple’s speech recognition turns your speech into text that you can read and correct. The app does not require this to happen on your device, so Apple may process the audio on its servers. We never receive the audio; only the text you send reaches us. When you practise repeating sentences, you can also record yourself; that recording stays only on your device, is replaced when you record again, is deleted when you move to the next sentence or leave the practice, and is never sent to us.

In the Android app you can also speak instead of typing: in roleplay practice, when you ask for help with an expression and when you write feedback. The speech recognition service on your phone turns your speech into text that you can read and correct. Normally this is your phone’s default speech recognition service; on many phones this is Google’s. Where the phone supports it, recognition can run on the device itself; otherwise the provider of that service may process the audio on its servers. If your phone’s default service cannot recognise Dutch and Google’s speech recognition service is installed, you can turn on Use Google speech recognition for Dutch in Me → Settings → Pronunciation and voices. Only then, and only for Dutch that your phone’s default service cannot recognise, does the app use Google’s speech recognition service instead of the default service. Google may then process the audio on its servers. You can turn this off at any time. We never receive the audio; only the text you send reaches us. Practice recordings in the Android app also stay only on your device and are never sent to us.

Crash and diagnostic reports

The app sends crash reports and a limited set of diagnostic events to an error-monitoring service, so we can find and fix faults. A report contains the device model, the operating system and app version, error details, timings and error codes. The service’s privacy filtering is enabled and the option to attach personal data by default is switched off. Our server reports its own errors to the same service, without the content of your requests.

Video usage records

Some expressions in Daily discovery have a short video. When you are signed in, the app sends our server a record each time one of these things happens:

the video row is shown (at most once a day for each expression on each screen), or you open or start the video;
playback reaches 25, 50 or 75 percent or the end, or you play the video again;
you open Usage and examples from the video, or you close the player;
you open a video that is already saved on your device;
the video cannot play because you are offline, the network fails or the file cannot be decoded.

Each record names the expression and the video, the app language you chose, whether you started from the card or from the Usage and examples page, and the time. Some records also say how far into the video you were, in steps of 10 percent. A record contains no text that you write and no details of your device. We store the records with your account. We use them only as totals and rates for each video and language: how often people open a video, watch it to the end or cannot play it. These numbers help us decide whether to make more videos and video features. We do not use the records to assess you or to contact you. You can object to these records at any time by writing to support@littlewhale.io. We then stop storing these records for your account and delete the ones we already have. Guests do not see videos, so the app sends no records for them.

Purchases

In the app on Apple devices, membership subscriptions, lifetime membership and practice packs are sold and charged by Apple through the App Store. Apple sends us signed details of each purchase: the product, transaction identifiers, purchase and expiry dates, renewal status and any refund. We link them to your account with a random identifier created for that purpose, and we count your roleplay starts to apply your allowance. We never receive your payment card details.

In the Android app, the same purchases are sold and charged by Google through Google Play. After you buy, our server asks Google Play for the details of the purchase and checks them: the product, the purchase token and order ID, the purchase and expiry dates, the purchase and renewal status, and any cancellation or refund. Google Play also tells our server when a purchase changes, for example when it renews or is refunded. We link the purchase to your account with the same random identifier and apply your allowance in the same way. We never receive your payment card or bank details.

3. Why we process it, and on what legal basis

Providing your account, sync and the learning features: Performance of our agreement with you (Article 6(1)(b) GDPR).
Producing AI notes, roleplay replies and language feedback: Performance of our agreement with you (Article 6(1)(b) GDPR).
Handling purchases and membership access: Performance of our agreement with you (Article 6(1)(b) GDPR).
Keeping purchase records after an account is deleted, so that a purchase cannot be claimed twice: Our legitimate interest in preventing misuse of purchases (Article 6(1)(f) GDPR).
Keeping the service secure and working, and fixing crashes: Our legitimate interest in a service that is reliable and not abused (Article 6(1)(f) GDPR).
Measuring how discovery videos are used, to decide whether to make more videos and video features: Our legitimate interest in improving the app and deciding what to build (Article 6(1)(f) GDPR).
Handling your feedback and support email: Performance of our agreement with you, or our legitimate interest in answering people who contact us and improving the app (Article 6(1)(b) and (f) GDPR).
Keeping the app working on the versions and devices people use, telling real use apart from tests, counting how many people use the app, and seeing in which countries and languages they use it: Our legitimate interest in a reliable app and in planning its development (Article 6(1)(f) GDPR).
Meeting legal obligations, for example in accounting and tax: Compliance with a legal obligation (Article 6(1)(c) GDPR).

4. AI features in detail

The text you write in conversation practice and the expressions you ask about are sent to OpenAI’s API to generate the requested response; in roleplay practice this includes language feedback on each sentence you write or say.

Roleplay practice also uses TypeSafe’s API in two ways. For each sentence you write or say, your sentence and the conversation so far are sent to TypeSafe to help choose the partner’s next line from the lines our editors wrote for that scene. After an authored roleplay ends, its practice transcript is sent to TypeSafe to evaluate the practice and generate feedback. These requests contain the practice text and the scene’s authored lines; they do not contain your name, email address, account identifier or device details. TypeSafe processes this data in the United States.

OpenAI and TypeSafe process this material on our instructions. By default they do not use it to train models. They may retain records as needed to operate and secure their services, prevent abuse and meet legal obligations; we do not promise zero retention.

AI-generated notes can be wrong. Do not rely on them for medical, legal or financial decisions.

5. Who else processes data for us

We use a small number of service providers. Those that process data on our behalf act only on our instructions; Apple and Google provide their services under their own terms.

OpenAI — generates AI notes, roleplay replies and language feedback, and provides an AI assistant that helps our team read and answer the feedback you send in the app; processes data in the United States.
Anthropic — provides an AI assistant that helps our team read and answer the feedback you send in the app; processes data in the United States.
TypeSafe — helps choose the roleplay partner’s next line and evaluates completed roleplays; processes data in the United States under its Master Customer Agreement and Data Processing Addendum.
Apple — App Store and TestFlight distribution, purchases, Sign in with Apple and speech recognition; may process data outside the European Economic Area.
Google — Google Play distribution, purchases and in-app ratings in the Android app, Google Sign-In, and speech recognition when Google’s service turns your speech into text (see Voice input); may process data outside the European Economic Area. When you rate the app through Google Play, we do not receive your rating.
An error-monitoring service — crash and diagnostic reports; EU data region.
A cloud hosting provider — our API and database; Frankfurt, Germany.
Resend — delivers the emails our server sends: sign-in codes, and the notifications that tell our team about new feedback. A sign-in code email contains your email address and the code. A feedback notification goes only to our team and does not contain your text, your screenshots, your email address or the copy of a roleplay. Resend sends the email from Ireland and may process data in the United States.

We may also disclose data where the law requires it. On request, we will tell you the name of every recipient of your data.

6. International transfers

Your account and learning data are stored in the European Union: our API and database run in Frankfurt, Germany, and crash reports are held in an EU data region. Some of the providers listed above are established outside the European Economic Area or may process data there. When our team reads and answers feedback with the help of the AI assistants of Anthropic or OpenAI, that feedback is processed in the United States. TypeSafe processes the roleplay data described in section 4 in the United States; its Data Processing Addendum incorporates the EU Standard Contractual Clauses (controller-to-processor Module 2, and Module 3 where applicable). Where other providers transfer data outside the European Economic Area, the transfer relies on the EU–US Data Privacy Framework if the provider is certified under it, and otherwise on the European Commission’s Standard Contractual Clauses in our agreement with that provider. You can ask us for a copy of these safeguards.

7. How long we keep data

Account and learning data, including your learning plan — until you delete your account. A stop-for-today choice is kept for up to 7 days. See account deletion.
App and device details — until you delete your account. Signing out, or a sign-in that expires, does not delete them.
Temporary roleplays — a roleplay conversation that is not saved to your history is deleted when you end it. If you do not end it, it is kept so that you can come back to it, and it is deleted automatically 7 days after you started it or last continued it. If you linked it to feedback, the copy stored with that feedback is kept as described under “Feedback sent in the app”.
Review records of AI-generated lines — when the roleplay partner’s line is generated by AI on the spot instead of being chosen from the authored lines, we record that line, its subtitles, the results of its checks and the sentence you wrote or said just before it, to review its language quality. Your sentence is deleted after 30 days, or earlier when that conversation is deleted. The rest of the record is kept until you delete your account.
Feedback sent in the app — your messages and screenshots, the technical details sent with them, the copy of a linked roleplay and our replies are kept until you delete your account. Deleting a roleplay or your roleplay history does not delete a copy that is stored with feedback.
Video usage records — until you delete your account.
Purchase records — while your account exists. When you delete your account, we keep the Apple transaction identifiers, product, dates and refund status of each purchase, no longer linked to your account, so that the same purchase cannot be claimed by another account. For a Google Play purchase, we keep in the same way its order ID, purchase token, product, dates and refund status; for a Google Play subscription, we keep only a one-way hash of its purchase token. These records are kept without an end date.
Deletion records — a record that an account was deleted, holding the account’s random internal ID, one-way hashes of its sign-in identifiers and the deletion dates, but no learning data or email address, so that the deletion can be completed and an old sign-in cannot recreate the account. These records are kept without an end date.
Crash and diagnostic reports — 30 days, after which they are deleted automatically.
Backups of our database — up to 30 days, after which they are deleted. Data from a deleted account disappears from the backups when they expire.
Support email — for as long as needed to handle your request and any follow-up.
Records we must keep by law — for the statutory period.

8. Your rights

Under the GDPR you can ask us to give you access to your personal data, to correct it, to erase it, to restrict or object to its processing, and to give you a copy in a portable form. Where processing is based on your consent, you can withdraw that consent at any time, which does not affect processing that already took place.

Write to support@littlewhale.io and we will answer. You can delete your account yourself in the app at any time.

If you believe we handle your data incorrectly, you can complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or to the supervisory authority in the country where you live.

9. Children

Rinava is made for adults and older learners settling into life in the Netherlands. You must be at least 16 years old to use it. We do not knowingly collect data from anyone under 16. If you believe a child has given us personal data, write to us and we will delete it.

10. Deleting your account

On Apple devices, you can delete your account in the app: Settings → Account → Delete account. In the Android app, choose Me → Settings → Account → Delete account. This removes from our server the account, the personal learning data linked to it and the feedback you sent in the app, including the copies of linked roleplays, and removes the account content on that device. It also deletes your video usage records. It does not cancel an Apple or Google Play subscription. The purchase and deletion records described in section 7 are kept. The account deletion page describes the steps.

11. Changes to this policy

If we change how we process personal data, we will update this page and change the date at the top. Significant changes will also be announced in the app.

12. Contact

Little Whale Holding B.V., Netherlands — support@littlewhale.io.