Privacy policy
Last updated
Rotea is a flashcard app for learning languages. This page says what personal data it keeps about you, why, who else receives it, for how long, and what you can do about it. The rules for using Rotea are in the Terms of service.
Who is responsible
Rotea is run by DENIS ERMAKOV PR BEOGRAD, a sole trader (preduzetnik) registered in Serbia, who is the controller of your personal data. Rotea's servers are with Kamatera in London, in the United Kingdom. Serbia's Law on Personal Data Protection (ZZPL), the EU General Data Protection Regulation (GDPR) and the UK GDPR apply. Rotea has no establishment in the EU or the UK, and no representative is appointed there (GDPR and UK GDPR Art. 27).
Web plans are sold by Individual entrepreneur Denis Ermakov, an individual entrepreneur registered in Russia (INN 631607753130, OGRNIP 312632008900090, PO Box 6061, Tolyatti, 445044, Russia, hello@rotea.app), who is the controller of the data of web plans and their payments, and of the personal-data consent asked for on the Russian pages. For that data Russia's Federal Law No. 152-FZ on Personal Data also applies, as the policy in Russian sets out.
- Controller
- DENIS ERMAKOV PR BEOGRAD
- Address
- Vojvode Vlahovića 55, 11040 Beograd-Voždovac, Serbia
- Registration number
- 66764834
- Tax ID (PIB)
- 113356500
- Phone
- +381 61 135 2938
- hello@rotea.app
What we collect
- Your account: received from Google or Apple when you sign in with them, or link Apple in your account settings: the id that account has, its email address and name. If you sign up with your email instead: that address, the name you give (if any), and your password, kept only as a hash. With Apple, Rotea also keeps, encrypted, the token Apple issues for your sign-in, only so that deleting your account can end Rotea's access to your Apple account; and Apple tells Rotea when you stop using your Apple account with Rotea or delete it, and whether it forwards email to the address it hides yours behind.
- Your cards: the text you write on both sides, the cards you add from collections, and their recordings. Recordings are made by text-to-speech from the card's text; Rotea never records your voice.
- Your training: your answers, rounds, time spent, streaks, goals and progress.
- Your settings: the languages you learn, your preferences, and your time zone (so that days start at your midnight).
- Your credits: your balance, what used it and what added to it. Payments on iPhone are taken by Apple, and on the web by YooKassa; we never see your card number.
- Your iPhone subscription: if you subscribe in the iPhone app, Apple takes the payment, and Apple's signed record of each purchase and renewal reaches Rotea, so your account gets its credit: the app passes it on, and Apple's servers also send it to Rotea's server directly, with each refund, renewal or lapse of the subscription, even when you do not open the app. The record holds the transaction numbers, which subscription (monthly or yearly), its dates, whether it is the free trial, and whether Apple refunded or withdrew it. Rotea receives no payment details. So that the record names your account, the app gives Apple a number Rotea makes for it, not your email or name. Rotea also keeps what the record says of the subscription now (whether it renews, a problem with a payment, when it ended, an offer code's campaign) and a history of what happened to it, each event kept 18 months. Administrators can see them, and can move a subscription that reached the wrong account to the right one when asked.
- Your web plan: if you start one, your plan and its period, its trial, auto-renewal and promo codes redeemed; YooKassa's reference to the bank card you saved there and the card's label (such as “Mir •• 4444”), never its number, which you type on YooKassa's page only; the payments and refunds, with their YooKassa numbers, amounts, dates and statuses; and the auto-renewal consent you ticked, its text, version and time. If you sign up from the Russian pages, the version and time of the personal-data consent you ticked there.
- Your devices: for each phone signed in, its id, its name and when it was last used; the API tokens you create; the time of your last web sign-in.
- Your messages to us: when you write through the Contact page, the email to reply to, the topic and your message, and, if you leave the box ticked, your browser, system and the app's version. Sent while signed in, the message is linked to your account.
- Server logs: your IP address, the time, the address requested, your browser's details and the page you came from (an administrator's search of learners may appear in them too); and the app's own logs, which hold account and card numbers and error details. These are designed not to contain your email or name, though an error may occasionally capture a fragment of a card's text.
Your account details and the text of your cards are needed to use Rotea: without them there is no account to sign in to and nothing to learn from. Everything else comes from using Rotea.
Rotea uses no analytics, advertising or tracking, and sells no data. The only emails it sends you of its own are notices about your account, to your account's email, from our own mail server: a security notice when Sign in with Apple is linked to or unlinked from your account, or moved to another account; and a deletion notice when you ask for your account to be deleted, with the date it will be erased, and another once it has been erased. With a web plan, it also emails you about the plan: auto-renewal turned on, with the consent you gave; when the trial is ending, 24 hours before each charge, a failed payment, auto-renewal turned off, a refund, the plan ending, and, once, the web becoming paid. YooKassa emails the receipt of each payment and refund. A message you write through the Contact page is emailed to our support mailbox, on that same mail server, with no email service in between, and a reply is written to you by a person, from the support address.
Why we use it
| Purpose | Legal basis |
|---|---|
| Your account, cards, recordings, training, settings, credits, iPhone subscription and devices | Performance of a contract with you (Art. 6(1)(b)) |
| Your web plan: its trial, payments, auto-renewal, refunds and promo codes, and the emails about it | Performance of a contract with you (Art. 6(1)(b)) |
| Receipts and accounting records of web-plan payments and refunds | A legal obligation (Art. 6(1)(c)): Russian law on receipts (54-FZ) and accounting (402-FZ) |
| Sending your cards' text to the speech and labelling services | Performance of a contract with you (Art. 6(1)(b)) |
| Server logs, limits on repeated sign-in attempts, investigating faults and abuse, and emailing you when a sign-in identity is linked to or unlinked from your account | Our legitimate interest in keeping Rotea secure and working (Art. 6(1)(f)) |
| Administrators' support, and checking the content learners share | Our legitimate interest in a working, accurate service (Art. 6(1)(f)) |
| Answering a message you send us, and fixing what it reports; limits on repeated messages | Our legitimate interest in helping you and keeping Rotea working (Art. 6(1)(f)) |
| Answering a request about your rights (access, erasure and the others) | A legal obligation (Art. 6(1)(c)) |
| Emailing you when you ask for your account's deletion, with the date, and when it is done | Our legitimate interest in telling you what happens to your account, so a deletion you did not ask for can be stopped (Art. 6(1)(f)) |
| Recording that an account was erased (its number and date only) | Our legitimate interest in showing, and re-applying after a restore, that it was (Art. 6(1)(f)) |
Rotea does not rely on your consent for any of this under the GDPR. Signing up from the Russian pages also asks for your consent under Russian law (152-FZ), which you can withdraw as the consent says, by deleting your account or writing to us. You may object at any time to what rests on our legitimate interests; we then stop, unless keeping Rotea secure requires it.
A language model labels your cards with their level and grammar. It judges the text, not you; Rotea makes no decisions about you by automated means.
Who else receives it
You give your data to Rotea directly from wherever you are; the controller is in Serbia, which has no EU or UK adequacy decision. Collecting data directly from you is not a transfer under the GDPR (EDPB Guidelines 05/2021). Rotea then shares it with the recipients below, each with what covers the transfer.
Please do not put personal information about yourself or others in your cards: their text is sent to the speech and labelling services.
Kamatera Inc. (1560 Broadway #1111, New York, NY 10036, USA), our hosting provider · United Kingdom (London)
Everything Rotea stores: the database, the recordings, database copies, server logs and mail.
Only as part of hosting Rotea, on our instructions.
Transfer: The EU's adequacy decision for the United Kingdom (renewed in December 2025).
YooKassa (NBCO YooMoney LLC, ООО НКО «ЮMoney») · Russia
If you start a web plan: your account's email for the receipt, the amount and the plan, and your Rotea account's number with each payment. You type your card's details on YooKassa's page, so they go to YooKassa, never to Rotea. YooKassa takes the payments and auto-renewals, makes refunds and sends the receipts.
Under YooKassa's own terms and Russian law: YooKassa is also a controller of the payment.
Transfer: No adequacy decision covers Russia. The transfer is needed to perform the contract you ask for when you pay for a web plan (Art. 49(1)(b)).
Rotea's administrators · within Rotea
Administrators of Rotea can see learners' accounts, cards and recordings, to give support and to check the content learners share, such as collections and labels.
Nothing of their own: they work in Rotea itself.
Transfer: Part of Rotea; no other company is involved.
OpenAI · United States
The text of your cards, to make their recordings (every language but Russian) and to label them with their language level and grammar. Nothing that identifies you is sent with it.
OpenAI says data sent to its API is not used to train its models, and is kept up to 30 days for abuse monitoring, unless a longer retention is required by law.
Transfer: No adequacy decision covers it: OpenAI is not certified under the Data Privacy Framework (checked 15 October 2026). Write to us to ask which safeguard is in place.
Google Cloud Text-to-Speech (Gemini voices) · not stated: Google's global endpoint
The text of your Russian cards, to make their recordings. Nothing that identifies you.
Google says Cloud Text-to-Speech does not log the text or audio. The Gemini models behind these voices may cache a request for up to 24 hours and may log it for abuse monitoring; Google does not say for how long.
Transfer: Google LLC is certified under the EU-US Data Privacy Framework and its UK Extension (checked 15 October 2026).
Yandex SpeechKit (Yandex Cloud) · Russia
The text of your Russian cards, used only when Google cannot make the recording. Nothing that identifies you.
Yandex says it does not store what is sent to it unless asked to, and Rotea does not ask it to.
Transfer: No adequacy decision or other safeguard covers this transfer. It is a fallback for Russian voices only, and can be turned off; Russian cards then get their recordings from Google alone.
Google sign-in · United States
You sign in with Google, which tells Rotea your Google account's id, email and name. When you delete your account from the web, Rotea asks Google to withdraw its access.
Under Google's own privacy policy: Google is your account provider.
Transfer: Google LLC is certified under the EU-US Data Privacy Framework and its UK Extension (checked 15 October 2026).
Apple: Sign in with Apple and the App Store · United States
On the iPhone you can sign in with Apple, which tells Rotea your Apple account's id and the email you chose to share. On the web you can link your Apple account in the account settings, which tells Rotea the same; that page then loads Apple's sign-in from Apple. If you subscribe in the iPhone app, Apple takes the payment and tells Rotea of each purchase and renewal, through the app and directly from Apple's servers, which also tell Rotea of a refund or a lapse; the app gives Apple a number Rotea makes for your account, so the purchase reaches it. Apple's servers also tell Rotea when you stop using your Apple account with Rotea, delete it, or turn email forwarding to your hidden address off or on. Rotea sends Apple only Apple's own codes and tokens for your sign-in: to receive the token it keeps, and to end Rotea's access when you delete your account.
Under Apple's own privacy policy: Apple is your account provider.
Transfer: You exchange your data with Apple directly. Apple Inc. is not on the Data Privacy Framework list (checked 15 October 2026).
How long we keep it
Your account and everything in it are kept for as long as you have the account.
When you ask to delete your account, you are signed out on every device at once, your devices and API tokens stop working, and nothing more is done with your data. It is erased about 14 days later: your email, name and sign-in identities (Rotea's access to your Apple account is ended at Apple when you ask, and the token it kept for it is erased); your cards, their recordings and what you typed; your training history, settings and credits, with your iPhone subscription's records; your devices and tokens; the messages you sent us while signed in. Signing in before then cancels the deletion. We send the date it will be erased to your account's email, and write again once it has been erased.
A web plan: YooKassa's reference to your saved card is deleted when auto-renewal is turned off, the plan ends or your account is erased, whichever comes first. Records of payments and refunds are kept 5 years after the end of the payment's year, as accounting and tax law requires; when your account is erased they stay, unlinked from your email and name. The auto-renewal consent you ticked is kept while the plan runs and 3 years after it ends, and the personal-data consent of the Russian pages while it stands and 3 years after it is withdrawn or the account erased, so either can be shown in a dispute.
Messages you send us through the Contact page are kept for 12 months after you send them, then deleted. One sent while signed in is deleted with your account, if that comes first; one sent signed out is not linked to an account, and keeps its 12 months. Each message is also emailed to our support mailbox, on our own mail server. The operator deletes that copy, with our reply, within 12 months after the conversation ends, or sooner if you ask. Deleting your account does not delete it: ask us, and we will.
What stays after that: the collections you added cards from (they are not yours); a record that an account with your number was erased, and when, with nothing else about you; in records of shared content, the bare number of your account; and, if you subscribed on iPhone, the purchase reference Apple issued for it, linked to no one, for 18 months, so that the same offer code can't be claimed twice. Apple could match that reference to your Apple Account; we can't. We keep no record that identifies you: a new account starts afresh, though an offer code already used stays used.
Copies outside the live database last as follows, and your data stays in them until they go:
- Web server logs: up to 60 days.
- Our mail server's log of the emails Rotea sends you (your address and when): up to 60 days, after your account is erased too.
- The app's logs: a copy is kept up to 14 days; the running server's own log is removed with each release, typically within weeks.
- Copies of the database an operator makes before maintenance: kept up to 360 days.
- Backups: there are no scheduled backups.
- Answers kept so that a phone can safely repeat a request: 24 hours.
- Sign-in checks: up to one hour; counts of sign-in attempts by address, and of messages sent to us by address and by account: up to one day.
- The services that receive your card text keep it as described under Who else receives it.
- What your browser stores: until you clear it (see Cookies and storage, below).
Your rights
You may ask for access to your data; to have it corrected; to have it erased; to restrict it; to object to how it is used; and for data portability, a copy of the data you gave us in a machine-readable form you can take elsewhere. Write to the controller (above), or choose “Privacy request” on the Contact page, for any of these; the law gives us one month to answer, and we first check that the account is yours.
Deleting your account you can do yourself: on the web in Account settings, or in the iPhone app's settings. Signing in on the web is with Google or with your email: if you signed up with Apple, delete your account from the iPhone app, or write to us. What happens then is under How long we keep it.
You may also complain to a data protection authority:
- in Serbia, the Commissioner for Information of Public Importance and Personal Data Protection;
- in the UK, the Information Commissioner's Office (ICO);
- in the EU, the supervisory authority of the country you live or work in.
Children
Rotea is not meant for anyone under 16. If you are under 16, please do not create an account. If you believe a child under 16 has one, write to us and we will delete it.
Changes to this policy
When this policy changes, this page is updated and the date at the top says when. The version on this page is the one that applies.