Privacy Policy

1. Scope

This Privacy Policy explains how Polar Origin AS collects, uses, stores, shares, and protects personal data when you use Doomy.

It applies to the Doomy iOS app, getdoomy.com, Doomy support, subscriptions, accounts and sign-in, chats and calls with AI characters, and analytics. It does not apply to third-party websites, apps, products, or services that we do not own or control, even if they link to or from Doomy.

2. Controller and contact

Doomy is provided by Polar Origin AS, organisation number 936 893 864, c/o Burghard Riechel, Svenneviktoppen 23, 4521 Lindesnes, Norway.

For data protection laws such as the GDPR, Polar Origin AS is the controller of the personal data described in this Privacy Policy, unless this Privacy Policy says otherwise.

You can contact us about privacy, support, account deletion, or legal questions at support@getdoomy.com.

3. The basics

Doomy is an iOS app for learning languages. You see a pretend phone that belongs to a donkey, with pretend apps on it: short videos and posts in the language you are learning, flashcards for the words you pick, text chats with cartoon characters, and voice calls with such characters.

The videos and posts are made by us, not by users. The characters in the chats and calls are played by an AI.

Doomy does not include public profiles or contact between users. Nothing you write, say, or save in Doomy is shown to other users.

Doomy shows no advertising. We do not sell personal data. We use no advertising or attribution SDKs, and we do not track you across other companies' apps.

Doomy uses Apple, Supabase, Fly.io, Anthropic, ElevenLabs, PostHog, RevenueCat, Cloudflare, and Vercel as described in this Privacy Policy.

Some information is kept on your iPhone and some is stored on our server. Accounts and their data are stored with Supabase and served by Fly.io, both in the European Union. Your conversations with the characters are kept on your iPhone; our server has what was said only as described in Section 9.

4. Age and children

Doomy is not directed at children under 13, or under 14 in South Korea, and we do not knowingly collect their personal data.

Users aged 13 to 17 may use Doomy only with a parent or legal guardian's consent where that consent is required by law. If the law where you live requires a higher age, or a different form of consent, you must meet that requirement before using Doomy.

Doomy asks for your age during onboarding to confirm eligibility. We use this only to determine whether you may use Doomy. We do not store your age or a date of birth. Only that the question was answered is kept, and only on your iPhone.

If we become aware that a child under 13 has provided personal data to Doomy, we will take reasonable steps to delete it. Parents or guardians may contact us at support@getdoomy.com if they believe this has happened.

5. Personal data we collect

We collect different categories of personal data depending on how you use Doomy.

Account and sign-in data. When you first open Doomy, the app creates an account for you without any sign-in. You can add Sign in with Apple to keep your cards on other devices; we then process the Apple identifier and the email address that Apple passes on to us. We also store the confirmation of the age question described in Section 4.

Learning data. We store the words you save and your flashcards, your review history and schedule, your study settings, and your streak and activity days.

Onboarding answers. We store the answers you give when you set up the app: the language you are learning, your own language, your reasons for learning, how you heard of Doomy, your daily goal in minutes, and your reminder choice.

Subscription data. Purchases are made through Apple. RevenueCat manages subscription status using your account's ID and Apple's transaction information. We store your subscription status: whether it is active, when it expires, and whether it renews. We never receive your card details.

Chats and calls with AI characters. If you give permission, what you write to a character, and what you say in a call after tapping to speak, is processed as described in Section 9. Our server keeps which character you talked to and when, what kind of situation it was and the character's side of what it was about, your level, how a call felt to you (too easy, just right, or too hard), and the counts needed for daily limits.

Analytics data. We record a limited set of events about how the app is used, as described in Section 10.

Content statistics and reports. For each video or post we count views, watch time, finished views, and saves per day, without recording who watched. If you report a piece of content, we store the report: the reason you give and any text you add.

Anki decks. Anki decks that you import or export are converted on our server and are not kept there.

Reminders and widget. Reminders are local notifications on your iPhone. The Home Screen widget works on your device.

Technical data. When the app or the website contacts our servers or the providers named in this Privacy Policy, the technical data needed to answer the request, such as the IP address, is processed.

Support communications. If you contact us, we collect the content of your message, your email address, and any information needed to respond.

6. How we collect data

We collect data directly from you when you answer the onboarding questions, save words, review flashcards, change settings, add Sign in with Apple, chat with or call a character, report a piece of content, or contact support.

We collect data automatically from the app as you use it, such as your review history, your streak and activity days, and the analytics events described in Section 10.

We receive limited sign-in and subscription information from Apple and RevenueCat.

Speech recognition, reminders, and the Home Screen widget work on your iPhone through Apple's platform features, as described in this Privacy Policy.

7. How we use personal data

We use personal data to provide Doomy: to create and keep your account, keep your cards on your other devices when you sign in with Apple, schedule your reviews, keep your streak, run the chats and calls with the characters and the feedback on them, apply daily limits, manage subscriptions, and respond to support requests.

We use analytics events, content statistics, and content reports to understand how Doomy is used and to maintain and improve the app and its content.

We use personal data where needed to comply with legal obligations, enforce our Terms of Service, protect our rights and users, process account deletion requests, handle disputes, and respond to safety, security, or legal issues.

We do not use personal data for advertising, and we do not sell it.

8. Legal bases for processing

If GDPR, UK GDPR, or similar law applies, we rely on the following legal bases.

Contract. We process account, learning, onboarding, and subscription data to provide Doomy and perform our agreement with you.

Consent. What you write and say to the AI characters is processed only after you give permission in the app. You can withdraw that permission at any time in the app's Settings.

Legitimate interests. We process limited data for analytics, content statistics, security, abuse prevention, service reliability, support, and product improvement, provided those interests are not overridden by your rights. You can switch analytics off in the app's Settings.

Legal obligations. We process data when needed to comply with law, tax, accounting, consumer-protection, App Store, safety, security, or dispute obligations.

9. AI chats and calls

The characters you chat with and call in Doomy are played by an AI. Before anything is sent, the app asks for your permission. You can turn this off again in the app's Settings.

What you write to a character, and what you say in a call after tapping to speak, is sent to our server and on to Anthropic, whose AI writes the characters' answers and the feedback. A few of the words you saved lately are sent along so that a chat or call can be about what you are learning.

In a call, your speech is turned into text on your iPhone by Apple's speech recognition, which may send your speech to Apple. We receive only the text. We never receive or store your voice.

What a character says is turned into its voice by ElevenLabs. ElevenLabs receives only the character's text.

Anthropic keeps what is sent to its API for up to 30 days and does not use it to train its models. We do not use what you write or say to train AI models either.

Your conversations are kept on your iPhone so that you can read them again. Our server has what was said only while a chat or call is going on, and deletes it once your iPhone has it, or after thirty days.

The characters do not remember what you told them about yourself. Our server keeps which character you talked to and when, what kind of situation it was and the character's side of what it was about, your level, how a call felt (too easy, just right, or too hard), and the counts needed for daily limits.

What the characters say, and the feedback you get, can be wrong. The characters are not people and do not give professional advice.

Do not share personal data about another person in a chat or call unless you have the right and permission to do so.

10. Analytics and content statistics

We use PostHog, hosted in the European Union, for analytics. IP addresses are anonymised. We do not use session recording or automatic capture.

The events we record are: onboarding steps viewed and completed, paywall views, checkout started, subscription started, a word saved (with the pretend app it was saved in, the language, and the count), a streak day completed, and the time spent in each pretend app.

You can switch analytics off in the app's Settings ("Share analytics").

We use no advertising or attribution SDKs, and we do not track you across other companies' apps.

Separately, we count views, watch time, finished views, and saves per video or post per day. These counts are made without recording who watched.

11. The website

getdoomy.com is hosted by Vercel. The website sets no cookies and has no analytics.

12. Sharing personal data

We share personal data only as needed to provide, operate, and secure Doomy, or where required by law. We require service providers that receive personal data from us to process it only for authorised purposes, protect it using appropriate safeguards, and comply with applicable law.

Apple. We use Apple services for Sign in with Apple, App Store distribution, in-app purchases and subscription management, and speech recognition on the iPhone.

Supabase. We use Supabase for the database and for sign-in. The data is stored in the European Union.

Fly.io. Our servers run at Fly.io, in the European Union.

Anthropic. Anthropic's AI writes the characters' answers and the feedback in chats and calls, as described in Section 9.

ElevenLabs. ElevenLabs turns the characters' text into their voices.

PostHog. We use PostHog, hosted in the European Union, for the analytics described in Section 10.

RevenueCat. RevenueCat manages subscription status using your account's ID and Apple's transaction information.

Cloudflare. The videos and pictures in the app are delivered through Cloudflare.

Vercel. Vercel hosts getdoomy.com.

Legal and safety disclosures. We may disclose information if required by law, legal process, regulators, courts, law enforcement, or if disclosure is needed to protect rights, safety, security, or service integrity.

Corporate transactions. If Polar Origin AS is involved in a merger, acquisition, financing, reorganisation, sale of assets, or similar transaction, personal data may be transferred as part of that transaction, subject to appropriate protections.

We do not sell personal data, and we do not share it with advertising networks.

13. International transfers

Polar Origin AS is based in Norway. Accounts and their data are stored in the European Union. Some of the providers named in this Privacy Policy may process the data they receive in the United States and other countries where they operate.

Where required by data protection law, we use safeguards such as data processing agreements, Standard Contractual Clauses, adequacy decisions, and other legally recognised transfer mechanisms.

14. Retention and deletion

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing Doomy, maintaining security, complying with law, resolving disputes, and enforcing agreements.

While your account exists, we keep the account data needed to provide the service.

What is said in a chat or call is on our server only while the chat or call is going on. It is deleted once your iPhone has it, or after thirty days. Anthropic keeps what is sent to its API for up to 30 days.

Anki decks that you import or export are not kept on our server after they are converted.

The chats and calls kept on your iPhone are removed from it when you delete your account in the app, or when you delete the app.

When you delete your account in the app (Settings, Account, Delete account), we delete the account's data on our server, its RevenueCat customer record, and its PostHog person with its events, and we revoke the Apple sign-in token.

Apple may retain App Store purchase, billing, refund, and subscription records under Apple's own policies.

Deleting your Doomy account does not automatically cancel an Apple subscription; a subscription is cancelled in the iPhone's Settings under your Apple Account, Subscriptions.

15. Your privacy rights

Depending on where you live, you may have rights to access, correct, delete, restrict, object to, or receive a copy of your personal data. You may also have the right to withdraw consent where processing is based on consent.

You can delete your account in the app (Settings, Account, Delete account). In the app's Settings you can also turn off sharing your chats and calls with the AI, and switch off analytics.

You can contact us at support@getdoomy.com to request access, correction, deletion, portability, restriction, objection, withdrawal of consent, or other privacy assistance.

We may need to verify your identity before responding to a privacy request. We will respond within the period required by applicable law.

If you are in the EEA, UK, or Switzerland, you may lodge a complaint with your local data protection authority. In Norway, the supervisory authority is Datatilsynet.

16. Account deletion

Doomy provides account deletion in the app: Settings, Account, Delete account.

Deleting the account deletes the account's data on our server, its RevenueCat customer record, and its PostHog person with its events, and revokes the Apple sign-in token.

Account deletion is separate from subscription cancellation. To stop future subscription charges, cancel the subscription in the iPhone's Settings under your Apple Account, Subscriptions.

17. Security

We use administrative, technical, and organisational safeguards designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

No app, website, database, provider, or internet transmission is completely secure. You are responsible for protecting your device, your Apple Account, and your account access.

18. California and similar privacy laws

To the extent California privacy law or similar law applies, the categories of personal information we may collect include identifiers, contact information, commercial information such as subscription status, internet or electronic network activity such as analytics events, and the content you provide through Doomy features.

We use these categories for the purposes described in this Privacy Policy, including app functionality, account management, subscriptions, analytics, security, support, product improvement, legal compliance, and dispute handling.

We do not sell personal information, and we do not share it for cross-context behavioural advertising.

You may contact us at support@getdoomy.com to exercise applicable rights, including access, deletion, correction, and portability, where those rights apply.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will take reasonable steps to notify users, such as updating the app, website, or policy date, or providing an in-app notice where appropriate.

The updated Privacy Policy applies from the Last updated date shown at the top unless a different date is stated.

20. Contact

Polar Origin AS

Organisation number: 936 893 864

Address: c/o Burghard Riechel, Svenneviktoppen 23, 4521 Lindesnes, Norway

Email: support@getdoomy.com