1. Data Controller
Responsible for data processing:
SCAFA INVESTMENTS LLC
9830 Bahama Dr
Cutler Bay, FL 33189-1568
United States
Developer contact: j.scafarti@scafa.de
Email: info@scafa-investments.com
Phone: +49 170 322 0161
2. Core Principle: Privacy by Design
DopaSpeak follows a strict privacy-by-design approach:
- There is no user account. The App works fully without registration or sign-in.
- There is no tracking, no analytics and no advertising SDK in the App.
- Your learning progress is stored on your device. We keep no accounts and do not transmit your progress to us.
- You decide how decoding works: on-device with a locally downloaded model, or in cloud mode with an AI provider of your choice and your own access key.
- Your access key is stored encrypted on the device (AES-256-GCM) and is never sent to us.
3. Data Processing in the App
3.1 What stays on your device
- Learning progress: vocabulary state, repetition intervals, points and statistics are stored on your device only.
- Imported content: your own texts and anything else you add stay on your device.
- Your AI access key: encrypted in the App's protected storage (AES-256-GCM), excluded from device backup.
- Decoding in on-device mode: once you have downloaded the local model, texts are processed on the device and are not sent to an AI provider.
3.2 Network connections
DopaSpeak connects to the following destinations:
- Our own server (dopaspeak.com): the game section of the App is served by us and loads when you open it. Your IP address is involved, as with any website request. It is stored in our host's server logs and is not used for profiling.
- Your chosen AI provider, in cloud mode only: the text you want decoded is sent to that provider under your own access key. Which text and how often is determined by what you decode. This is the default path until you download the local model.
- Lyrics services: when you look up song lyrics, the search term is sent to the lyrics service.
Pronunciation analysis always runs on the device. Microphone audio is never transmitted.
4. Data Processing on the Website
4.1 Hosting
When you visit dopaspeak.com, the hosting provider automatically collects standard server log data transmitted by your browser (anonymized IP address, date/time, page visited, browser type, operating system). This data is used solely for technical delivery of the website and is not merged with other data sources.
4.2 Cookies
The website dopaspeak.com uses no cookies and deploys no tracking tools (no Google Analytics, no Meta Pixel, no Hotjar, etc.).
4.3 Google Fonts
The website uses Google Fonts for consistent typography. When loading the page, your browser connects to Google servers. Your IP address may be transmitted to Google LLC (USA). More information: Google Privacy Policy.
5. Third-Party Data Sharing
DopaSpeak does not share any personal data with third parties for advertising or marketing purposes. There are no analytics services, no social media integrations and no data brokers.
The only transfers to third parties happen in cloud mode, when the text you want decoded goes to the AI provider you chose under your own access key, and when a lyrics search sends your search term to the lyrics service. There is no sign-in and no payment, so neither can transfer anything.
6. Your Rights
For EU/EEA Residents (GDPR)
You have the right to access, rectify, erase, restrict processing, data portability, and object to processing of your personal data. Since DopaSpeak does not collect personal data, there is practically no data to access, delete, or transfer. For inquiries: info@scafa-investments.com
For California Residents (CCPA)
Under the CCPA, you have the right to know what personal information is collected, request deletion, and opt out of the sale of personal information. DopaSpeak does not sell personal information and does not collect personal data beyond what is described in this policy.
7. Data Deletion
All locally stored data (learning progress, vocabulary) can be deleted at any time by uninstalling the app or clearing the app data through your device settings.
There is no account to delete. Everything the App keeps about you sits on your device, and clearing the app data removes it. If you want to reach us anyway, write to us at any time by emailing info@scafa-investments.com.
8. Children's Privacy
DopaSpeak does not knowingly collect data from children under 13 (or under 16 in the EU). Since the app does not collect personal data at all, this applies by design.
9. Changes to This Policy
We may update this privacy policy to reflect changes in our practices or legal requirements. The current version is always available at this URL.
Last updated: 26 August 2026