Privacy Policy
1. Controller
Damian Witkowski
Rüttenscheider Str. 323
45131 Essen
Germany
Email: d.witko@icloud.com
2. This website
This website is hosted on ChatGPT Sites by OpenAI Ireland Ltd, the EU contracting entity. For delivery and security, technically necessary data such as IP address, browser data, time and requested URL may be processed. The hosting service may set technically necessary security cookies, such as __cf_bm, for delivery and abuse prevention; we do not use them for our own audience measurement. The legal basis is Art. 6(1)(f) GDPR. Data is processed for as long as necessary for these purposes and then deleted unless legal retention obligations apply. Hosting is international; no specific data residency is guaranteed. Details are in the Data Processing Addendum and ChatGPT Sites Terms.
3. Contact
If you email us, Apple/iCloud processes your message and contact details so we can respond. The legal basis is Art. 6(1)(b) GDPR where the request is necessary before entering into an agreement, otherwise Art. 6(1)(f) GDPR. We retain the correspondence for as long as needed to handle and resolve the matter, then delete it unless legal retention obligations apply.
4. Audience measurement (optional)
Only if you expressly agree through “Analytics settings” do we load Ahrefs Web Analytics from Ahrefs Pte Ltd (Singapore). For privacy-focused, cookie-free statistics, Ahrefs processes information including pages viewed, referrer, browser and language information, screen size, and city and country derived from the IP address. According to Ahrefs, the IP address is not stored and there is no cross-day recognition. The legal basis is your consent under Art. 6(1)(a) GDPR. You can withdraw consent at any time through “Analytics settings”; processing before withdrawal remains lawful. See Ahrefs Web Analytics for details.
5. The OhBonjour app
This section applies to the OhBonjour iOS app (version 1.0 and later). The controller is the person named in section 1.
No account, no ads, no tracking
The app does not require an account. It shows no ads and contains no tracking or analytics SDKs.
Data on your device
Your learning progress, saved words, settings and your own pronunciation recordings are stored only locally on your device. There is no cloud sync, and we have no access to this data. Deleting the app removes it.
AI conversation with Marcel (optional)
Only when you tap “Start conversation” and allow microphone access does the app transmit, for the duration of the conversation:
- your microphone audio,
- a short learning context (current lesson, practised words, your learning goal, app language),
- a randomly generated installation ID, not linked to your name or Apple ID, used only to enforce usage limits.
This data is sent via our server at Cloudflare, Inc. (Cloudflare Workers) to OpenAI (OpenAI Ireland Ltd or OpenAI, L.L.C.; Realtime API for the conversation and text API for correction cards). We store neither audio nor transcripts, and our server does not log conversation content. The installation ID and a daily counter are kept in Cloudflare KV for no more than 48 hours and then deleted automatically.
OpenAI processes API data under its API terms. According to OpenAI, API data is not used for training by default and is retained for up to 30 days for abuse monitoring.
The legal basis is Art. 6(1)(b) GDPR (providing the conversation feature you requested). Data may be transferred to the USA; the providers rely on the EU Standard Contractual Clauses or the EU-US Data Privacy Framework. If you don’t start a conversation, none of this data is transmitted.
OhBonjour Plus subscription
Subscriptions (yearly or monthly) are handled exclusively by Apple through the App Store. We receive no payment data. You can cancel in your Apple ID settings under “Subscriptions”.
Reminders
Reminders (notifications) are optional and scheduled only locally on your device. Nothing is sent to us for this.
6. Your rights
You have rights including access, rectification, erasure, restriction, portability and objection under Articles 15–21 GDPR. You may also complain to a data protection supervisory authority, in particular the North Rhine-Westphalia Commissioner for Data Protection and Freedom of Information. Contact: d.witko@icloud.com
Last updated: 15 October 2026