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Privacy Policy – LexiLock

Last Updated: February 12, 2026

1. Responsible Party

Empressia d.o.o – Branch Office Germany
Diemshoff 38, 48282 Emsdetten, Germany
E-Mail: lexilock.app@gmail.com

Website: lexilock.com

Register Entry:
Registered in the Commercial Register of the Commercial Court of Split (Croatia)
Registration number: (HR) 060305839

Responsible for content according to § 55 Abs. 2 RStV:
Marvin Vrdoljak, Diemshoff 38, 48282 Emsdetten

2. Overview: What LexiLock Does (and Doesn't Do)

LexiLock is designed so that learning content and usage data for vocabulary queries are generally stored locally on your device. We do not receive vocabulary answers, learning progress, or content you edit in the app on our own servers.

However, there are two technical areas where data may be transmitted to service providers:

  • Tracking/Analytics via Vexo (for usage statistics)
  • Subscription/Purchase Management via RevenueCat (for assignment of In-App purchases/subscriptions)

3. Local Data Processing on Your Device

The app stores in particular (depending on usage) locally:

  • Selected decks / settings
  • Learning progress / history (e.g. which vocabulary items have already been seen)

This data remains on your device and can be deleted by uninstalling the app or via the system settings.

4. Tracking & Usage Analytics (Vexo)

We use Vexo Analytics (vexo.co) to statistically evaluate the use of the app in default settings (e.g. number of active users/installations).

What data can be processed?
This depends on the specific integration. According to Vexo privacy notices, usage data such as IP address, device/browser information, unique device identifiers and diagnostic data can be processed in particular. The Vexo documentation also provides that apps can optionally link devices with an identifier – or remain anonymous (e.g. identifyDevice(null)).

Purpose: Reach measurement, stability/quality, product improvement.

Legal basis: Art. 6 Para. 1 lit. f GDPR (legitimate interest in app optimization) or – if required by design/integration – consent according to Art. 6 Para. 1 lit. a GDPR in connection with § 25 TTDSG.
Note: Whether consent is required depends among other things on whether/which identifiers are used and whether access to device information goes beyond the "technically necessary".

Recipient: Vexo (service provider).
Third country transfer: Vexo lists Delaware/USA as its company headquarters.

Objection/Opt-out:
If you do not wish to be tracked, please contact us at lexilock.app@gmail.com. (Technically, an anonymized configuration is basically provided according to Vexo documentation.)

5. Subscriptions & In-App Purchases (RevenueCat)

We use RevenueCat to manage subscriptions.

What data is processed?

  • An (by default) anonymous App User ID / Customer ID for subscription recognition
  • Store information (Apple App Store / Google Play) and subscription status (e.g. active/cancelled)
  • Country/Region: RevenueCat shows "Country" based on the last determined IP country, with IP not being permanently stored according to documentation.
  • Payment data: Payment processing is handled via Apple/Google. We do not receive complete payment data (e.g. credit card numbers).

Purpose: Contract performance, subscription status, entitlements/unlocks.
Legal basis: Art. 6 Para. 1 lit. b GDPR (contract performance).

6. Permissions (Screen Time & Push)

LexiLock may (optionally) request permissions:

  • Screen Time / Usage Restrictions: only required if you use the blocking/focus function.
  • Push Notifications: only if you enable reminders/notifications.

You can revoke permissions at any time in your device settings. Without permissions, the app remains basically usable, but individual features may be limited.

7. Website (lexilock.com) & Hosting

The website is hosted with Hostinger. When you access a website, server log data is technically generated (e.g. IP address, time, requested page, user agent) to ensure operation and security.

Cookies/Tracking on the website: You indicate that no tracking tools are used and no cookies are set for analytics/marketing purposes.

Legal basis: Art. 6 Para. 1 lit. f GDPR (legitimate interest in secure operation of the website).

8. Data Sharing

Data is only shared to the extent necessary for the described purposes, in particular to:

  • Vexo (Analytics)
  • RevenueCat (Subscription management)
  • Apple / Google (App Store, purchase processing)

9. Storage Duration

  • Local app data: Until deletion by you (e.g. app uninstallation).
  • Analytics data: According to the service provider's storage policies or as long as required.
  • Subscription data: As long as required for contract processing/documentation (RevenueCat/Stores).

10. Rights of Data Subjects

You have the right at any time to:

  • Access (Art. 15 GDPR)
  • Rectification (Art. 16 GDPR)
  • Erasure (Art. 17 GDPR)
  • Restriction (Art. 18 GDPR)
  • Data Portability (Art. 20 GDPR)
  • Objection (Art. 21 GDPR)

Contact: lexilock.app@gmail.com

11. Child Data Protection

LexiLock can be used by children. If processing must be based on consent (e.g. depending on tracking configuration), parental consent may be required in certain cases.

12. Changes

We may modify this Privacy Policy (e.g. due to feature changes or new service providers). The current version will be made available in the app or on the website.