Smartinga privacy statement

Want to delete your account or your data? Here is how, also without the app

Version 1.8, effective 16 October 2026.

This is a translation of the Dutch privacy statement (smartinga.com/privacy). If the two differ, the Dutch text prevails.

1. Who are we?

Smartinga is an app for learning to read and do maths, for children aged about 4 to 12. Adults learning Dutch can use the app too, once the app offers it: they then choose "Ik leer zelf Nederlands" (I am learning Dutch myself) and a level (§3.4). A separate part for adults is on its way.

How the content is made. The stories and texts are written with the help of AI (Claude, by Anthropic) and are checked with an automatic language check and proofread by people. The pictures are made with AI (Gemini, by Google). The voice is a computer voice (Google's text-to-speech); the sound files are made in advance and come with the app, so no data of yours or your child's goes to Google for the reading aloud.

Smartinga belongs to Developly B.V.

• Address: Lumierestraat 36, 1087 KH Amsterdam, the Netherlands
• Chamber of Commerce no.: 42070503
• Email: info@smartinga.com

We are responsible for the data Smartinga processes (the "controller" under the privacy law, the GDPR).

2. In short

• Without an account, everything stays on your device. Your child's progress and settings do not reach us.
• With an account we keep your email address (and your first name, if you fill it in) and, for each child, a nickname, the progress and the settings. This is stored in the European Union (Frankfurt, Germany).
• Payments go through Stripe, and in the app through Google Play (Android) or, once the app is there, the App Store. We never see your bank or card details.
• Anonymous counting of which stories, cards and games are used: without a name, without a number for your device, without keeping track of who did what. For a child it is off by default; you can switch it on. For an adult learning Dutch it is on; you can switch it off. The website also counts anonymously how many visitors come each day and where they came from, without cookies.
• Your password is stored unreadably encrypted (hashed). Nobody at Smartinga can read it.
• No advertising, no tracking, no advertising profiles, nothing sold. We do not use the microphone or the camera. Your child's voice is never recorded.
• We do not ask for a real name, date of birth, school, place of residence, nationality or residence status.

3. What data, by situation

3.1 You use Smartinga without an account

Your child can use Smartinga without you creating an account. The app then keeps everything only on your device (in the browser's storage):

• the nickname you choose for your child, and the picture (an animal);
• the reading and maths level, and whether the reader is a child or an adult;
• the progress: which stories and texts were read, which words were tapped or saved, the flash cards, the maths cards (per card a rating and how often a kind of mistake happened lately, as a small count; not the individual answers), the practice tests (date and score, and the answers of a test still in progress), on which days your child read (the last 60 days), and per game and maths card how often your child began it, up to 3 times (after that the hand no longer points by itself);
• a maths round or a Begrijpend lezen (reading comprehension) text your child left halfway: which question your child is at, and for each question whether it went right (not the answers your child chose or typed), so your child can carry on there. This is kept until the round or the text is finished;
• the settings: text size, colours, English translation on or off, whether your child reads the stories or has them read aloud, whether anonymous counting is on (and whether you chose that yourself), and the language of the parents' area (Dutch or English).

This data does not reach us. You can delete it yourself: "Ouders → Alle gegevens wissen" (Parents → Delete all data). It also disappears when you clear the website's data in your browser.

The English translation of words and sentences is part of the app itself. Tapping a word or showing the translation sends nothing to us or to a translation service. Only when anonymous counting is on does the app count which word was tapped, without knowing by whom (§12).

What does leave the device:

• Anonymous counters (see §12): for example "story X was finished 12 times today", or on the website "12 visitors came through Google today". Without a name, without a number, without a time (only the day).
• Technical data when the app loads. To send the app, its pictures and sounds to your device, our hosting provider Vercel sees your device's internet address (IP address), the page address and the browser type. Vercel keeps this briefly in log files (1 day, see §9). We use it only to find errors and prevent abuse.

3.2 You create an account

An account is for you as a parent or carer (or for yourself as an adult learning Dutch). Children never create an account themselves and never sign in.

Do you have to provide this data? No: without an account you can use the free part (§3.1). But without an email address we cannot create an account, so we keep no progress in an account and you cannot take a subscription.

We then keep:

• About you: your email address and your password (unreadably encrypted, hashed; we cannot read it). If you sign in with Google, we keep from Google only your email address and a number belonging to your Google account. Google also passes on your name and the link to your profile photo; we do not keep them, the database removes them at once. And the parents' PIN, so it works on every device you sign in on: not as readable digits, but made unrecognisable with a slow hash, and in your account also encrypted with a key that only our server knows.
• Your first name, if you fill it in: at "Ouders → Account → Profiel" (Parents → Account → Profile) you can fill in your first name. You do not have to. We use it only to greet you in the parents' area ("Hoi Anna"). You change it or empty it there, and it goes when your account goes. The language you choose for the parents' area is kept there too.
• About each child (at most 6): the same data as in §3.1: nickname, picture, levels, progress and settings. We do not ask for a real name, date of birth, school, photo or place of residence. If you enter your child's real first name as the nickname, we keep it as the nickname.
• Sign-in data: when you signed in, and technical data such as the IP address and the browser at sign-in, to secure your account (how long: see §9).
• Emails we send you about the account: a link if you have forgotten your password, a code if you have forgotten the parents' PIN, a code when you change your email address (to the new address, and as a check to the old one), a code when you delete your account without a password (for example because you sign in with Google), and an email before we delete an unused account (§9).

The app on your device keeps a copy and puts changes into your account a few seconds later. That way the progress can be seen on a second device too, and is not lost if a tablet breaks.

3.3 You take a subscription (including the free trial)

For subscriptions we work with Stripe. You enter your details on Stripe's payment page. Stripe asks for:

• your email address, and your country and address only if the payment method requires it (VAT is 21% for everyone and included in the price);
• if you add payment details: the details of your card, iDEAL, Apple Pay, Google Pay or Bancontact, and for a direct debit your name and IBAN.

We never see your card or bank details. From Stripe we receive and keep only:

• a Stripe customer number and subscription number;
• which subscription you have (1 child or family, monthly or yearly), the amount, the status (trial, active, cancelled, payment failed, stopped) and the date of the next payment or the end;
• whether there are payment details (yes or no, not which);
• which children can use everything if you have more children than the subscription has places, and when you chose that.

Stripe makes the invoices and may email you about your payments, for example when a payment failed.

A subscription in the app (App Store or Google Play). In the app on an Android device you take the subscription in Google Play; in the app for iPhone and iPad, once it is there, in Apple's App Store. Google or Apple then sells you the subscription and handles the payment; the store has your card or bank details, we never see them. Which account has which subscription is tracked for us by RevenueCat. The app gives RevenueCat only your account number with us, no email address or name. From RevenueCat we receive and keep only:

• in which store you took the subscription (App Store or Google Play);
• which subscription you have (1 child or family, monthly or yearly), the amount, the status (trial, active, cancelled, payment failed, stopped), when it started and the date of the next payment or the end;
• whether it was a test purchase.

3.4 You are learning Dutch yourself

Once the app offers it, an adult learning Dutch chooses "Ik leer zelf Nederlands" in the app. The app then keeps, on the device and, with an account, also in your account: the name you enter (it may stay empty), your level, whether you want explanations in English, and your progress with stories and words. We do not ask about nationality, residence status, religion, political views, health or employer. For you, anonymous counting is on; you switch it off in the settings (§12). Because that is different for a child, the choice "Ik leer zelf Nederlands" is behind the parents' lock: the app first asks the PIN (on a device without a PIN first a sum and then a new PIN), so that a child does not make that choice.

3.5 You email us

If you email us (info@smartinga.com, privacy@smartinga.com or support@smartinga.com: it is one mailbox), we keep your email address, your message and our reply, in order to help you (how long: see §9). The mailbox is at Google Workspace (§7). Please do not put details of your child in an email that we do not need.

4. Why do we use this data, and is that allowed?

The GDPR says we need a good reason (a "legal basis") for every use.

Where we rely on a legitimate interest, we have weighed that our interest does not outweigh your privacy. You can object to it (§10.1).

We do not use the data for advertising, for profiles for advertising or for selling anything, and we sell it to nobody. We use no personal data to make stories, drawings and exercises, also not with the AI we make them with (§1).

4.1 Personal recommendations (profiling)

Smartinga chooses which story, exercise or level fits best with what was practised. The GDPR calls this profiling. An example: if telling the time goes wrong a few times, a clock exercise comes back later; if it goes well, the next step is a little harder. This is done only for practising, mostly on the device itself. No decisions with legal or other significant effects for you or your child are made (Art. 22 GDPR), and we do not use it for advertising. You can always choose the level yourself in the settings.

5. Children

Smartinga is made for children, so we are extra careful:

• The parent decides. Only a parent or carer creates an account, takes a subscription and can reach the settings, the payment and the account (behind the parents' lock, with a PIN). When you create an account for your children, you confirm that you are their parent or carer.
• As little as possible. We ask only for a nickname, a picture and a level. No real name, age, school or photo.
• No advertising, no chat, no in-app purchases. Children never see prices or payment buttons.
• No profiles for advertising, no tracking, and the data does not go to advertisers.
• Privacy-friendly settings. Without an account everything stays on the device, and anonymous counting is off by default for a child.
• No microphone and no camera. The app even blocks them in the browser. Reading aloud is something for you and your child together: the app records nothing.
• We follow the Dutch "Code voor Kinderrechten" (Children's Rights Code, 2021) in the design of Smartinga.

Are you a child reading this? At the very bottom there is a short explanation for you.

6. What is stored on your device

The app keeps this in your browser's storage (local storage, session storage and the app's cache). There are no cookies of ours on your device, and no cookies or scripts of others, except Cloudflare's security check on the parents' sign-in screens (§12).

All of this is needed for the app you open yourself to work, and is only for your device. No consent is needed for it (Art. 11.7a(3)(b) "Telecommunicatiewet").

Reading aloud. Smartinga reads aloud with sound files that come with the app (§1). The app never reads your child's nickname aloud, and never sends it anywhere to be read aloud. If a sound file is not there yet, or cannot be loaded for a moment (for example without internet), a Dutch voice on your device reads a fixed sentence of the app, but only a voice that works on the device itself. A voice that has the text spoken over the internet (such as the "Google" voices in the Chrome browser) is never used. If your device has no Dutch voice of its own, the app stays silent.

7. Who receives data?

We give data only to companies we need to make Smartinga work. With the companies that work for us ("processors") we have a data processing agreement; they may use the data only for us.

Our domain name smartinga.com is registered at Namecheap. Namecheap only handles the addresses (DNS): your email and your data do not pass through it.

To make the content we use AI by Anthropic (Claude) and Google (Gemini, and text-to-speech) (§1). For this they receive only our own instructions and texts, never data of yours or your child's.

We give data to others only if the law requires it (for example the Dutch tax authority) or if it is needed to defend our rights.

8. Data outside the European Union

Smartinga's database is in the EU (Frankfurt), and the app's servers at Vercel run in Frankfurt too. Still, data may leave the EU: the parties below are (also) American companies and may process data in the United States, for example for administration, support or to process payments. For each party one of the safeguards the GDPR requires applies: the EU-US Data Privacy Framework (the European Commission's decision of 10 July 2023) if the company has joined it, and otherwise the European Commission's standard contractual clauses in the data processing agreement.

We checked this on 15 October 2026 in the official Data Privacy Framework list (dataprivacyframework.gov). Want to know exactly which safeguards apply? Email us.

9. How long do we keep data?

10. Your rights

Want to delete your account or your data? Here is how, also without the app

You have these rights over your data and your children's data:

• Access: you may know what data we have. You see most of it yourself under "Ouders" (Parents), and you download all of it at once: "Ouders → Privacy → Mijn gegevens downloaden" (without an account: "Ouders → Mijn gegevens downloaden", which gives you what is on this device). What Stripe keeps about you (invoices, payment details) you see at "Ouders → Abonnement → Facturen bekijken". A copy of anything else (for example the sign-in data or your emails to us) you request by email.
• Correction: you change the nickname, the level and the settings yourself under "Ouders". You change your first name and your email address yourself at "Ouders → Account → Profiel".
• Deletion: delete a child or your whole account yourself in the app, or ask us. Other devices where you were signed in with the account delete your children's data as soon as they notice the account is gone (the next time they connect, at the latest after an hour). To delete the account the app asks for your password; if you have none (for example because you sign in with Google), you ask for a code by email there.
• Portability: you get the data you gave us, and your children's progress, in an ordinary computer file (JSON) with "Mijn gegevens downloaden" (see above). The file contains your account, each child in your account, your subscription with us and what is on this device; never your password or your sign-in session.
• Restriction and objection: you may ask us to restrict the use, and object to use based on our legitimate interest (§10.1).
• Withdrawing consent: if you gave consent (anonymous counting for your child), you can always withdraw it: "Ouders → Privacy → Anoniem meetellen", per child "Uit". What was already counted stays counted. Also when your browser sends "Global Privacy Control" or "Do Not Track", Smartinga counts nothing.

Parents and carers exercise these rights for their children.

Email your request to privacy@smartinga.com (or info@smartinga.com). We answer within one month. We may ask you to show that it is about your account (for example by emailing from the account's email address). It costs nothing.

A complaint? Email us first; we are happy to sort it out together. You may also always file a complaint with the Dutch Data Protection Authority, the "Autoriteit Persoonsgegevens": https://www.autoriteitpersoonsgegevens.nl (or with the supervisory authority in the country where you live).

10.1 Right to object

You can always object to use based on our legitimate interest (§4): the log files and the security log, the security check on the sign-in screens, the note after an account is deleted, the fact that your account already had a trial, the internal overviews with totals, and answering your email. Email us: privacy@smartinga.com. We then stop, unless there are compelling reasons that weigh more heavily, such as preventing abuse of your account. Anonymous counting is not part of this: it is not personal data, and you switch it off yourself (§12).

11. Security

We protect the data as well as is reasonably possible, among other things like this:

• all connections are encrypted (https), and the app allows only its own scripts;
• the database is stored encrypted (AES-256), so your email address and the progress are too;
• in the database a parent sees only their own children; the database itself checks this on every request;
• passwords are stored unreadably encrypted (hashed); for a new password the app asks for your current password, and to delete an account for your password again (or, without a password, a code by email);
• the sign-in screens are protected against password guessing (§12);
• the parents' lock (a PIN) keeps children away from the settings, the payment and the account. The PIN is nowhere stored as readable digits: only made unrecognisable with a slow hash, and in your account also encrypted with a key that only our server knows. After 5 wrong PINs the app waits a minute;
• payment details never reach our servers;
• we assessed in advance what the risks of Smartinga are for children and parents, and which measures they need (a data protection impact assessment, DPIA); we do it again when something important changes.

If something does go wrong with your data (a "data breach"), we report it within 72 hours to the Dutch Data Protection Authority where required, and as soon as possible to you if the risk to you or your child is high.

12. Cookies, storage on your device and the anonymous counters

Cookies. Smartinga sets no cookies for advertising or tracking, and loads no scripts, fonts or counters from other companies. What the app stores on your device is in §6. Stripe may use cookies on its own payment page; Stripe's policy applies to those. One exception: on the parents' sign-in screens the app loads Cloudflare's security check Turnstile (§7), to prevent password guessing. It looks at technical browser data and, according to Cloudflare, sets no cookies for advertising or tracking. It is never loaded on your child's screens.

The anonymous counters. To know which stories, cards, exercises and games are used, which words are tapped and which sums are hard, Smartinga counts. It works like this:

• The app counts in memory, for example "maths card clock, step set the hour: right". Every 10 seconds and on closing, the counts go to our server. Nothing is stored on your device for this.
• No name, nickname, account number, device number, session number, time or typed answer is sent. The server keeps only: the day, what happened, with which story or card, and how often. We do not keep your IP address.
• So we cannot see what one child does, nor the order of what a child did.
• For a child it is off by default. Only if you switch it on ("Ouders → Privacy → Anoniem meetellen", per child "Aan"; without an account on the Ouders page itself) does the app count; you can always switch it off in the same place: "Uit".
• For an adult learning Dutch it is on; you switch it off with "Anoniem meetellen → Uit".
• If your browser sends "Global Privacy Control" or "Do Not Track", Smartinga counts nothing, even when it is on.

Visitors of the website. On smartinga.com the website counts per day how often each page was viewed and where visitors came from: through a search engine (for example Google), through a social site (for example Instagram), through a link from one of our campaigns, or directly. This happens without cookies and without storing anything on your device. No name, number, time or web address is sent, only the short name of the source and of the page; we do not keep your IP address. So we see totals only, for example "on Tuesday 12 visitors came through Google". This happens on the website only, not in the app and never on your child's screens. If your browser sends "Global Privacy Control" or "Do Not Track", the website counts nothing.

Signed in, on the website. If you are signed in to the app on this device, the website shows it: the first letter of your e-mail address, with a menu (Go to the app, For parents, Sign out). To do so the website asks the app on the same device only whether you are signed in and that one letter. It stays in your browser: nothing goes to a server and no cookie is added.

Because the counters identify nobody, they are not personal data. For a child we still count only with the parent's consent; for an adult and on the website the measuring falls under the exemption for measuring with no or little impact on privacy (Art. 11.7a(3)(b) "Telecommunicatiewet", §4).

13. What Smartinga does not do

• No advertising and no ad networks.
• No tracking across websites or apps, and no "fingerprint" of your device to follow you or for advertising. Only the security check on the parents' sign-in screens looks at technical data of your browser, to stop computer programs (§12).
• No profiles for advertising or for selling anything.
• No selling of data.
• No microphone, camera or location.
• No chat and nothing children share with each other.
• No decisions about your child made only by a computer that have effects outside the app.

14. Changes

If Smartinga changes, this statement may change too. The date at the top shows which version applies. If something important changes (for example new data or a new party), we let you know in advance in the app and, if you have an account, by email.

15. Contact

Developly B.V. Lumierestraat 36, 1087 KH Amsterdam, the Netherlands Chamber of Commerce no. 42070503 info@smartinga.com (questions about privacy: privacy@smartinga.com)

Developly B.V. has no data protection officer; one is not required for us.

For children: what does Smartinga know about you?

Hi! Smartinga helps you with reading and maths. Here you can read what Smartinga knows about you.

What does Smartinga know?

• Your nickname and the animal you choose.
• Which stories you read and which sums you do.
• How well it is going, so you get exercises that suit you.

What does Smartinga not know?

• Your real name, how old you are or where you live.
• Which school you go to.
• What you look like or what your voice sounds like. Smartinga uses no camera and no microphone.

What does Smartinga not do?

• Smartinga shows no advertising.
• You cannot chat with other children.
• You cannot buy anything.
• Smartinga tells other children nothing about you.

Who decides? Your father, mother or carer. Want to know something or have something removed? Ask them. They can always email us.

Changes

What changed in the latest versions:

v1.6 (14 October 2026): the progress counts per game and maths card how often your child began it, up to 3 times, so the pointing hand then only comes when your child is stuck (§3.1). No answers, no times. A maths round or a Begrijpend lezen text your child left halfway is kept until it is finished, so your child can carry on there: which question, and for each question whether it went right; not the answers (§3.1, §4).

v1.7 (15 October 2026): after a privacy review: how the stories, pictures and the voice are made, with AI (§1); our mailbox is at Google Workspace (§7); per party which safeguard applies for the United States (§8); we keep the security log for 90 days, and the 7 years of the accounts start on 1 January after the year of the subscription's last change (§9); we no longer keep the name and the profile photo from Google, and without a password you delete your account with a code by email (§3.2, §10); the PIN is better protected (§3.2, §11); "Ik leer zelf Nederlands" is behind the parents' lock (§3.4); your device's voice reads aloud only if it works on the device itself (§6); the English translation is part of the app (§3.1); and the reasons and the right to object are aligned (§4, §10.1, §13).

v1.8 (16 October 2026): the app remembers per child whether they read the stories themselves or have them read aloud (§3.1).

v1.5 (10 October 2026): you can fill in your first name (you do not have to); we use it only to greet you, and it goes when your account goes (§3.2). You change your email address yourself, with a code (§3.2, §10). In "Ouders", Account and Privacy now each have their own page, and you switch anonymous counting on or off per child (§10, §12).

v1.4 (10 October 2026): if you are signed in to the app, the website shows the first letter of your e-mail address with a menu; to do so the website asks the app on the same device only whether you are signed in, without a server and without a cookie (§12).

v1.3 (8 October 2026): the website counts anonymously how many visitors come each day and where they came from, without cookies (§12); and we make internal overviews with totals only of accounts and subscriptions (§4).

v1.2 (8 October 2026): a language change in the Dutch text only (it now addresses you with the informal "je"), and the parent button is now the parents' lock, with a PIN. No other change in content.

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