Last updated: June 2, 2026
The controller within the meaning of the General Data Protection Regulation (GDPR) is:
Nordic App Studio
Owner: Ferdinand Drobik
Bordeauxgade 4, 2.th
2150 Copenhagen
CVR: 45328120
Denmark
Email: info@nordicappstudio.dk
A data protection officer is not required by law.
The KLUG app is designed as an offline-first application.
The developer:
App data is stored only on the user's device. Where Apple Intelligence is used, chat requests are processed on device and, in certain cases, via Apple Private Cloud Compute, as described in section 5.
To provide app functionality, certain information is stored locally on the user's device only.
This may include:
These data are not transmitted to the developer and not stored on external servers.
The data remain on the device until they are:
Legal basis: Art. 6(1)(b) GDPR (provision of app functionality).
The app may request access to the device microphone in order to enable pronunciation exercises.
Processing takes place exclusively on the user's device. No audio recordings are transmitted to external servers.
Legal basis: Art. 6(1)(a) GDPR (consent).
The app may display reminders generated locally on the device. No push notifications are sent through external servers.
Widgets access locally stored data through Apple App Groups. No data are transmitted to external servers.
The app includes a chat feature for practicing the German language. This feature uses Apple Foundation Models provided as part of Apple Intelligence.
During a chat session, the following information may be processed:
Processing is generally performed directly on the user's device using Apple's on-device models. The developer does not transmit chat data to their own servers.
In certain cases, Apple Intelligence may use Private Cloud Compute (PCC) infrastructure to process requests.
According to Apple, the following privacy principles apply:
Further information: apple.com/privacy
Apple may act as an independent data controller in this context.
In-app purchases are processed through the Apple App Store. Payment processing is handled entirely by Apple. The developer does not receive payment or billing information.
Information about Apple's data processing practices: apple.com/legal/privacy
The app does not use:
Since the developer does not store or process personal data, no data are stored on developer-controlled servers.
Locally stored data remain on the user's device until they are:
Under the GDPR, users generally have the following rights:
However, since the developer does not store or process personal data, these rights in practice apply only to data stored locally on the user's device.
Such data can be deleted at any time by:
Contact for privacy inquiries: info@nordicappstudio.dk
You have the right to lodge a complaint with a data protection supervisory authority.
Responsible authority:
Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Denmark
datatilsynet.dk
The developer reserves the right to update this privacy policy if legal requirements or app features change.
The current version is always available within the app.
The policy above describes the app and its on-device data handling. This policy is itself published as a page on nordicappstudio.dk, which is hosted by Simply.com A/S on servers within the EU. As with any website, viewing this page generates standard server access logs (for example your IP address, browser type, and time of access) for the secure operation of the site, on the basis of legitimate interest (Art. 6(1)(f) GDPR). This applies only to viewing this web page and does not affect how the app works. Full details and your rights are in our Website Privacy Policy.