Last updated: 2026-08-12

Privacy Policy

Deutsch Fox (deutschfox.com) Operated by Inovo Works LTD Last updated: August 12, 2026

1. Introduction

This Privacy Policy explains how Inovo Works LTD ("we", "us", "our") collects, uses, shares, and protects personal data when you use Deutsch Fox (the "Service") at https://deutschfox.com.

Depending on where you live, the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and other applicable data protection laws may apply to our processing of your personal data.

Data Controller: Inovo Works LTD 1a Jubilee Avenue London Colney St. Albans, England, AL2 1QG United Kingdom Email: contact@deutschfox.com

2. Personal Data We Collect

2.1 Account Data

When you create a Deutsch Fox account, we collect information needed to create and manage your account, including:

Name
Email address

If you sign in using Google, we may also receive from Google:

Your name
Email address
Profile photo URL

We store the profile photo URL where used by the Service, rather than storing a separate copy of the image file ourselves.

2.2 Learning and User Content

When you use Deutsch Fox, we process information generated through your use of the learning features, such as:

Writing submissions
Exercise answers
Saved progress and completion information
Feedback and results generated for your exercises

Deutsch Fox is not intended for processing sensitive or special-category personal data. Please avoid including information about health, political opinions, religion, sexual orientation, financial details, government identifiers, or similarly sensitive matters in exercise submissions unless it is genuinely necessary for the exercise.

If you voluntarily include personal information in a writing submission, that information may be processed as part of providing the requested exercise, evaluation, or AI-generated feedback.

2.3 Support and Communications Data

If you contact us for support or another service-related reason, we may process:

Your name and email address
The content of your message
Information you provide about your account or technical issue
Our correspondence with you

We currently do not send promotional or marketing emails. We may send transactional and service-related communications necessary to operate your account or subscription.

2.4 Technical, Session, and Security Data

When you use the Service, we may process limited technical information necessary for authentication, session management, security, fraud prevention, abuse prevention, and troubleshooting, including:

IP address
Browser user agent
Session and authentication information
Limited request, error, and security information

Session data is deleted or expires according to the technical session lifetime configured for the Service.

2.5 Usage and Cost Metrics

We may record limited operational information needed to monitor reliability and the cost and usage of third-party services, including AI usage metrics such as request counts, model usage, or token/cost information.

We do not intentionally store the content of writing submissions in these internal cost-monitoring logs.

2.6 Analytics Data (Optional)

If you give consent through our cookie or privacy controls, we use Google Analytics to understand how the Service is used. Depending on your device and consent choices, analytics information may include:

Pages and features visited
General usage and interaction information
Device and browser information
Approximate location derived from IP address
Analytics identifiers stored in cookies or similar technologies

Google Analytics is activated only where the required consent has been obtained. You can withdraw analytics consent through our cookie settings. Withdrawing consent does not affect the lawfulness of processing that occurred before consent was withdrawn.

3. How We Use Personal Data

We use personal data for the following purposes:

To create, authenticate, and manage user accounts
To provide listening, writing, and other learning features
To save exercise progress and results
To generate AI-powered feedback and related learning output
To manage Premium access and subscription status
To send account, security, support, and other service-related communications
To respond to customer support requests
To maintain the security and integrity of the Service
To detect and prevent fraud, abuse, scraping, automated misuse, and other prohibited activity
To diagnose technical problems and maintain reliability
To monitor operational and AI-service usage costs
To comply with legal, tax, accounting, regulatory, and dispute-resolution obligations
To understand and improve the Service using consent-based analytics where required

We do not sell personal data.

We do not use user writing submissions to train our own AI models, and we do not authorize our AI providers to use submitted content for model training where their applicable business/API terms provide such controls.

4. Legal Bases for Processing

Where the UK GDPR or EU GDPR applies, we rely on the following legal bases depending on the processing activity:

Processing activity	Main legal basis	Why we process it
Account creation, authentication, and account management	Performance of a contract	Needed to provide your Deutsch Fox account and the Service you request
Storing exercise answers, progress, and results	Performance of a contract	Needed to provide learning functionality and preserve your progress
Sending submissions to AI providers to generate feedback	Performance of a contract	Needed to provide AI-powered feedback requested through the Service
Premium access and subscription administration	Performance of a contract	Needed to provide paid features and recognize subscription status
Transactional and service-related emails	Performance of a contract and, where applicable, legitimate interests	Needed to operate the Service and communicate important account or service information
Customer support	Performance of a contract and legitimate interests	Needed to answer requests and resolve product or account issues
Security, fraud prevention, abuse prevention, and technical logging	Legitimate interests	We have a legitimate interest in protecting users, our systems, and our business from misuse and security threats
Reliability, debugging, and limited operational metrics	Legitimate interests	We have a legitimate interest in maintaining and improving the reliability and efficiency of the Service
Google Analytics and non-essential analytics cookies	Consent	Analytics is activated only after the required consent is obtained
Tax, accounting, legal claims, and regulatory compliance	Legal obligation and/or legitimate interests	Needed to comply with law and establish, exercise, or defend legal claims

Where we rely on legitimate interests, we consider whether our interests are necessary and proportionate and whether they are overridden by your rights and interests.

If we need to use personal data for a materially different purpose, we will assess the appropriate legal basis and provide additional notice where required.

5. AI Processing

Deutsch Fox uses third-party AI services to generate educational feedback and related learning output. Our current AI providers include:

OpenAI
Google Generative AI / Gemini API

When you use a feature that requires AI processing, the information sent to an AI provider may include:

The text or exercise content you submit
Instructions necessary to evaluate or respond to the submission
Limited technical context necessary to process the request

We aim to send only the information reasonably necessary to provide the requested AI feature. We do not intentionally send your account password or full payment card information to AI providers.

Under the applicable API/business terms of our AI providers, submitted API content is not intended to be used to train their general-purpose models where the relevant no-training protections apply. Providers may, however, temporarily retain or process API data for security, abuse-prevention, service operation, legal, or regulatory purposes under their own applicable terms and data-processing arrangements.

For example, under OpenAI's standard API data controls, API content may be retained in abuse-monitoring logs for up to 30 days unless different data-retention controls or legal requirements apply. Google's applicable Gemini API terms provide separate data-use rules for eligible paid/business API services and may permit limited logging for security and abuse monitoring.

We do not use AI processing to make decisions that produce legal effects, or similarly significant effects, about you. AI-generated feedback is educational and may be inaccurate.

6. Payments and Subscriptions

Payments and subscription transactions are handled through Polar Software, Inc. ("Polar"), which acts as the Merchant of Record and authorized reseller for purchases made through its checkout.

When you purchase a subscription, Polar may process information necessary to complete and administer the transaction, such as:

Name and email address
Billing and country/location information
Payment information
Tax information
Product, subscription, and transaction details

Polar processes certain checkout and transaction information under its own terms and privacy policy.

We receive from Polar information reasonably necessary to identify and administer your Deutsch Fox purchase or subscription, which may include customer identifiers, order or subscription identifiers, selected product or plan, subscription status, transaction status, and related billing metadata.

We do not receive or store your full payment card number.

Some payment, tax, transaction, and accounting information may be retained for longer periods where Polar, we, or another party is required to retain it by applicable financial, tax, accounting, fraud-prevention, or legal rules.

7. Service Providers and Data Sharing

We share personal data only where reasonably necessary to operate, secure, support, or provide Deutsch Fox, or where required by law.

Our current categories of service providers include:

Hosting providers – infrastructure and application hosting, with our primary hosting intended to be Europe-based
MongoDB Atlas – database hosting; our application database is configured to use an EU cluster
Resend – transactional email delivery
Google Sign-In / authentication services – authentication where you choose to sign in using Google
Google Analytics – analytics where you have provided the required consent
Google Generative AI / Gemini API – AI-powered learning and feedback features
OpenAI – AI-powered learning and feedback features
Polar – Merchant of Record, checkout, subscription, payment, tax, and transaction administration

These providers process different categories of information depending on the service they provide. We do not give every provider access to every category of personal data.

We may also disclose personal data where reasonably necessary to:

Comply with a legal obligation, court order, or valid governmental request
Protect the rights, security, or safety of users, Deutsch Fox, Inovo Works LTD, or others
Investigate fraud, abuse, security incidents, or violations of our Terms
Establish, exercise, or defend legal claims
Complete a corporate transaction such as a merger, acquisition, restructuring, or sale of assets, subject to applicable data protection requirements

We do not sell personal data or share it with third parties for their independent direct-marketing purposes.

8. International Data Transfers

Inovo Works LTD is established in the United Kingdom. Some of our service providers or their subprocessors may process personal data in countries outside the United Kingdom or European Economic Area, including the United States.

Where data protection law requires a transfer mechanism, we use an appropriate lawful safeguard depending on the countries and parties involved. These may include:

An applicable adequacy decision or adequacy regulation
European Commission Standard Contractual Clauses (SCCs)
The UK International Data Transfer Agreement (IDTA) or UK International Data Transfer Addendum
Another transfer mechanism permitted by applicable data protection law

Where required, we also consider whether additional contractual, organizational, or technical measures are appropriate for the transfer.

You may contact us at contact@deutschfox.com if you would like more information about the safeguards applicable to a particular international transfer or how to obtain a copy of relevant contractual safeguards, subject to permitted redactions for confidential or commercially sensitive information.

9. Data Retention

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

Because different types of data serve different purposes, the retention criteria differ:

Account data: generally retained while your account remains active and removed or anonymized following account deletion, except where continued retention is required for legal, security, fraud-prevention, or dispute purposes.
Writing submissions, exercise answers, progress, and results: generally retained while associated with your active account so that learning history and progress remain available, and deleted or anonymized when the associated account data is deleted, subject to lawful exceptions.
Support communications: retained for as long as reasonably necessary to resolve the request, maintain an appropriate support history, address repeated issues, and establish or defend legal claims.
Session and authentication information: expires or is deleted according to the technical lifetime of the relevant session or authentication mechanism.
Security, error, and technical logs: retained only for as long as reasonably necessary for security, abuse prevention, troubleshooting, reliability, and legal claims, after which they are deleted or anonymized where appropriate.
Operational and AI cost metrics: retained for operational, financial, and service-management purposes. We do not intentionally include writing-submission content in these internal cost-monitoring logs.
Google Analytics data: retained according to the retention controls configured for our Google Analytics property and Google's applicable service rules. Analytics processing occurs only where the required consent has been obtained.
Payment, tax, and transaction records: may be retained for the periods required under applicable tax, accounting, payment, anti-fraud, or other legal requirements. Some of these records are maintained independently by Polar as Merchant of Record.

When data is no longer required, we delete it, anonymize it, or otherwise remove it from active use, unless continued retention is required or permitted by law.

Anonymous or irreversibly anonymized information that can no longer identify you may be retained for statistical, security, product, or operational purposes.

10. When Providing Data Is Required

Some personal data is necessary for us to provide Deutsch Fox:

A name and email address are required to create and manage an account under our current account system.
Exercise content must be provided if you want us to evaluate that content or generate feedback on it.
Information required by Polar must be provided to Polar if you choose to purchase a Premium subscription through its checkout.

If you do not provide data that is necessary to perform the Service or complete a requested transaction, we may be unable to provide the relevant account, feature, feedback, or subscription.

Providing consent for non-essential analytics is not required to use Deutsch Fox.

11. Your Data Protection Rights

Depending on where you live and the law that applies, you may have rights including:

Access – request information about and a copy of personal data we hold about you
Rectification – ask us to correct inaccurate or incomplete personal data
Erasure – ask us to delete personal data in circumstances where the law provides this right
Restriction – ask us to restrict certain processing
Data portability – receive certain personal data in a structured, commonly used, machine-readable format and, where applicable, transmit it to another controller
Withdrawal of consent – withdraw consent at any time where processing is based on consent, including analytics consent
Objection – object to certain processing based on legitimate interests

Your Right to Object

Where we process your personal data on the basis of legitimate interests, you have the right to object to that processing based on your particular situation. We will stop the relevant processing unless we have compelling legitimate grounds to continue or the processing is required for the establishment, exercise, or defence of legal claims.

To exercise your rights, contact us at contact@deutschfox.com.

We may need to verify your identity before fulfilling a request. We will respond within the period required by applicable law, normally within one month under the UK GDPR or EU GDPR, subject to legally permitted extensions for complex or numerous requests.

Some rights are not absolute and may not apply in every situation. If we cannot fully comply with a request, we will explain the reason where required by law.

Complaints

If you have concerns about how we use your personal data, please contact us first so that we can try to resolve them.

You also have the right to complain to a data protection authority:

United Kingdom: Information Commissioner's Office (ICO)
European Economic Area: the competent supervisory authority in your country of residence, place of work, or place of the alleged infringement, as applicable

12. Automated Decision-Making

Deutsch Fox uses automated systems and AI to generate educational feedback, scoring assistance, or related learning output.

We do not currently use your personal data for solely automated decision-making that produces legal effects concerning you or similarly significantly affects you within the meaning of applicable data protection law.

Deutsch Fox feedback does not determine admission to an exam, employment, immigration status, educational qualification, credit, insurance, or another comparable legal or significant decision.

13. Security

We use technical and organizational measures intended to protect personal data against unauthorized access, alteration, disclosure, loss, or destruction. Depending on the system involved, these measures include:

HTTPS/TLS encryption in transit
Access controls and authentication
Secure hosting and infrastructure practices
Database security controls
Limiting access to personal data to those who need it for operational purposes

No internet service can guarantee absolute security. We review and update our measures as the Service evolves and as reasonably appropriate to the risks involved.

14. Cookies and Similar Technologies

Deutsch Fox uses:

Essential cookies or similar technologies required for authentication, security, session management, and core Service functionality
Analytics cookies or similar technologies only where the required consent has been obtained

You can refuse or withdraw consent for non-essential analytics without losing access to the core Service.

For more information about the specific cookies and technologies we use, their purposes, providers, and available controls, see our Cookie Policy and cookie settings.

15. Data Breaches

If a personal-data breach occurs, we will assess it in accordance with applicable data protection law. Where legally required, we will notify the relevant supervisory authority and, where the applicable risk threshold is met, affected individuals.

16. Changes to This Privacy Policy

We may update this Privacy Policy when our Service, providers, legal obligations, or data-processing practices change.

The "Last updated" date at the top of this page shows when the policy was most recently revised. If a change materially affects how we use personal data, we will provide additional notice where required by law and, where required, obtain new consent before beginning the new processing.

17. Contact

For questions, privacy requests, or concerns about this Privacy Policy or our processing of personal data, contact:

Inovo Works LTD 1a Jubilee Avenue London Colney, St. Albans, England, AL2 1QG United Kingdom Email: contact@deutschfox.com