RUNA — PRIVACY POLICY
Effective date: 6 September 2026 Last updated: 6 September 2026
This policy explains what Runa does with data. It is written to be read.
SUMMARY
Runa has no accounts. Your practice decks, recordings, scores and history are stored on your phone and are never uploaded to us. When you record a practice attempt, the audio passes through our server to Google's transcription service and returns as text; it is not stored at any point along the way. We do not run advertising, we do not track you across other apps, and we do not sell information about you.
WHO WE ARE
KelloSolutions, a company registered in Latvia under registration number [REGISTRATION NUMBER], with its registered office at [REGISTERED ADDRESS], is the data controller for the limited processing described in this policy.
Contact: info@kellosolutions.com
We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 of the GDPR. Privacy enquiries are handled at the address above.
WHAT STAYS ON YOUR DEVICE
The following is stored in an encrypted database on your phone and is never transmitted to us:
(a) Practice decks — built-in decks, and any text you add yourself. (b) Progress — which phrases you have mastered, and your spaced-repetition schedule. (c) Attempt history — scores, per-word results, and derived patterns such as which sounds you frequently miss. (d) Cached audio — reference pronunciations generated for your decks. (e) Settings — target language, daily goal, reminder time and appearance preferences. (f) Streak data — the dates on which you practised.
We cannot access any of this. There is no account to attach it to and no server on which it is held. If you delete the app, it is gone, including from our reach, because it was never within it.
WHAT LEAVES YOUR DEVICE, AND WHY
3.1 Audio recordings, for transcription
When you record a practice attempt, the audio is sent to our server, which immediately forwards it to Google's Gemini transcription service and returns the resulting text to your phone.
The recording is held in memory only for the duration of the request. It is not written to disk, not logged, and not retained by us at any point. The transcribed text is returned to your device and stored only there. We do not associate recordings with any identifier capable of linking them to you across sessions.
Recordings are typically two to five seconds of you saying a practice phrase.
Legal basis: performance of our contract with you (Article 6(1)(b) GDPR). Transcription is the core function of the app you installed.
A note on voice data: voice recordings constitute biometric data under the GDPR only where they are processed for the purpose of uniquely identifying a person. Runa does not do this. We transcribe speech into words. We do not create voiceprints, do not attempt identification, and have no technical means of doing so.
3.2 Text added to decks, processed once
When you add a phrase written in a non-Latin script, a single request is made to generate its romanisation, which is then cached on your device. If you paste longer text into a deck, that text is processed once in order to split it into phrases and generate romanisations. The text is not retained after the request completes.
Legal basis: performance of our contract with you.
3.3 Subscription data
If you subscribe, RevenueCat, Inc. verifies the purchase with Apple or Google. RevenueCat receives an anonymous identifier that it generates itself, together with purchase and device metadata.
We do not send RevenueCat your name, email address, recordings, decks or progress, and we do not set custom attributes on your RevenueCat profile.
We never see or handle your payment card details. Payment is processed by Apple or Google.
Legal basis: performance of our contract with you, and compliance with our legal obligations in respect of transaction records.
3.4 App analytics
We collect a small number of aggregate events in order to understand whether the app is functioning — for example, that a practice session was completed, or that the subscription screen was displayed. These events contain no recordings, no deck content, no phrase text, and no identifier that we are able to link to an individual.
You can switch this off in Settings, under Privacy.
Legal basis: our legitimate interest in maintaining and improving the app (Article 6(1)(f) GDPR), balanced against the minimal and non-identifying nature of the data collected.
3.5 Crash reports
If the app crashes, a diagnostic report may be sent containing the device model, operating system version, app version and a technical stack trace. No content from your decks or recordings is included. You can switch this off in Settings, under Privacy.
WHAT WE DO NOT DO
We do not sell your data. There is nothing to sell, and no arrangement under which it could be sold.
We do not display advertising, and the app contains no advertising SDKs.
We do not track you across other apps or websites. Runa does not request App Tracking Transparency permission, because it has no means of tracking you.
We do not use your recordings, decks or progress to train artificial intelligence models, whether our own or those of any third party.
We do not build a profile of you. Without an account, we have nothing to which a profile could be attached.
PERMISSIONS
Microphone — required, in order to record practice attempts. The app cannot function without it.
Notifications — optional. Used for the daily practice reminder and, if you begin a free trial, a reminder before that trial converts to a paid subscription. All other functionality works without it.
Runa does not request access to your camera, contacts, photos, location, calendar or files. It does not request iOS speech recognition permission, because transcription is performed on our server rather than on the device.
SERVICE PROVIDERS
We use the following processors:
(a) Google LLC and Google Cloud — speech transcription and text processing through the Gemini API. Receives audio of practice attempts and phrase text for romanisation. Processing takes place under Google's paid-tier terms, which exclude submitted content from being used to improve Google's products.
(b) RevenueCat, Inc. — subscription and purchase verification. Receives an anonymous identifier together with purchase and device metadata. Receives no content.
(c) Google Cloud (europe-west1) — hosting for our stateless transcription proxy. Handles audio in transit only, with no storage and no content logging.
(d) Apple Inc. and Google LLC — app distribution and payment processing, governed by their own privacy policies.
We use no other processors. If this changes, this section will be updated and any material change notified within the app.
INTERNATIONAL TRANSFERS
Our transcription proxy operates within the European Union.
Where processing by a provider takes place outside the European Economic Area, that transfer is covered by the European Commission's Standard Contractual Clauses together with the provider's own safeguards.
Details of the transfer mechanisms operated by Google and RevenueCat are available in their respective privacy documentation, linked from https://runa.app/privacy.
RETENTION
Audio recordings are not retained. They exist in memory only for the duration of the transcription request.
Transcribed text, decks, progress and attempt history are stored only on your device, and remain until you delete them or delete the app.
Analytics events are retained for 14 months in aggregate, non-identifying form.
Crash reports are retained for 90 days.
Purchase records are retained for as long as required by tax and accounting law, typically five years, and are held by RevenueCat and by the app stores.
YOUR RIGHTS
Under the GDPR you have the right to access, correct, delete, restrict and object to the processing of your personal data, the right to data portability, and the right to lodge a complaint with a supervisory authority.
In practice, most of these are actions you can take yourself, immediately, without contacting us:
(a) Access and portability — Settings, then Export. This produces a file containing your decks and progress. (b) Deletion — Settings, then Delete all data. Alternatively, delete the app. (c) Objection to analytics — Settings, then Privacy, then switch off.
For anything else, or for data held by RevenueCat in connection with a purchase, contact info@kellosolutions.com. We respond within one month.
One limitation should be stated honestly. Because Runa has no accounts, we are generally unable to identify which data relates to you. If you request data that we hold about you, we may be unable to link any record to you, and Article 11 of the GDPR permits us to say so rather than collect additional information for the sole purpose of identifying you. For purchase-related requests, the App User ID shown in Settings, under About, is the identifier that allows us to locate the relevant record.
You may lodge a complaint with the Latvian Data State Inspectorate (Datu valsts inspekcija) or with the supervisory authority in your country of residence.
CHILDREN
Runa is not directed at children under 13, and you must be 13 or older to use it. Within the European Economic Area, users under 16 require the consent of a parent or guardian.
Because Runa has no accounts and collects no identifying data, we cannot verify age and do not attempt to do so.
If you are a parent or guardian and wish to have your child's data removed, deleting the app from their device removes everything, as nothing is held elsewhere. If a purchase is involved, please contact info@kellosolutions.com.
SECURITY
The local database is encrypted at rest, with the key held in the device Keychain on iOS or Keystore on Android.
All network traffic uses TLS.
Requests to our transcription proxy are attested using App Check, which blocks use of the endpoint from outside the app.
The proxy stores nothing, which means there is no database of user content capable of being breached.
No system is perfectly secure. The principal realistic risk to your data is loss or compromise of your device rather than of our systems, which is why we recommend using a device passcode and exporting your data periodically.
CHANGES TO THIS POLICY
We may update this policy from time to time. Material changes will be notified within the app at least 14 days before they take effect, together with a summary of what has changed.
The current version is always available at https://runa.app/privacy, with the effective date shown at the top.
CONTACT
KelloSolutions [REGISTERED ADDRESS] info@kellosolutions.com