Privacy policy

Controller

PulsarSol GmbH, Morgartenstrasse 9, 6003 Lucerne, Switzerland.

Contact for data protection: Maurizio Di Pietro Martinelli, admin@pulsarsol.ch.

Legal basis

The Swiss Federal Act on Data Protection (FADP), in its revised form, applies. The European General Data Protection Regulation (GDPR) is taken into account in addition, where it applies.

The German version of this policy is the one that governs. The other versions are translations provided for readability.

What we process

At registration: e-mail address, name, password, role (student or teacher), the languages you choose, the language of the interface and your time zone. Optionally, in addition: a profile picture, country and region, and a learning goal in your own words.

For two-factor sign-in: either a secret for your authenticator app, stored encrypted, or time-limited codes delivered by e-mail or through Telegram. If you choose Telegram, you connect your chat with our bot; we store the chat number Telegram gives that chat and when it was connected. Plus recovery codes, which are stored only as a checksum.

When you sign in: the time, IP address and browser identification of the session. These are shown to you so you can spot and sign out a device you do not recognise, and they limit failed sign-in attempts.

While you learn: your own words and their notes, your progress, the day a word was learned, and your own pronunciation recordings if you make any.

For lessons: the lessons you book, their time and price, cancellations and their stated reason, a teacher's corrections and remarks on individual words, and the chat messages between student and teacher. Each lesson also has a lesson chat: the texts and pictures the participants send there, and which messages they mark to remember. When a student reviews a lesson: which notes were known, how many words, the rating of the learning goal and one sentence about it.

For feedback: the text from the feedback box at the foot of the pages, with role, time and account. The administration reads it, and it is kept until the administration deletes it as dealt with or the account is deleted.

What for

To run your account and to secure sign-in. To provide what sabayou is for: keeping a vocabulary, practising it, arranging and holding lessons. To detect and prevent abuse.

For administration, we count how many accounts exist, where they are, and how many lessons take place. Those are figures, not profiles of people.

What expressly does not happen

No analytics service, no tracking pixel, no advertising network, no passing data to data brokers. No sale of data, under any circumstances.

No calls to third-party services while you use the application — except for sending sign-in codes through Telegram to those who chose Telegram as their second factor. The dictionary, the pronunciations and the example sentences are files on the same server; none of it is fetched from anywhere at the moment you use it.

Video calls run through a media server on the same machine. Picture and sound pass through no third-party provider and are not recorded. Only what is written or sent as a picture in the lesson chat is stored.

Cookies

sabayou sets two cookies, both strictly necessary: one keeps you signed in, one remembers your chosen interface language.

There are no others, which is why there is no consent banner.

Who sees the data

A teacher sees, of their students, what teaching requires: name, profile picture, the chosen languages, the lessons arranged and, in the language taught, the 100 newest words of the vocabulary with pronunciation, own recordings and open corrections, plus the number of words, so that they can suggest corrections and prepare lessons.

Chat is limited to the two people in it. The application offers no way to read someone else's conversation — not to the administration either.

The lesson chat of a lesson is seen only by its student, its teacher and a substitute who holds that lesson; here too the administration has no access in the application. Pictures are stored anew on the server, without location data or other data of the recording. Do not send pictures there in which other people can be recognised without their consent.

Of the review, the teacher (and a substitute who holds the lesson) sees only the rating of the learning goal, the sentence «What I take away» and which notes were last not known; the other results stay with the student.

Whoever administers the server has technical access to the database. That cannot be defined away in a self-hosted application, and hiding it would be dishonest. Access happens only as far as operation, backup or fault-finding requires.

Processors

Operation and storage take place on a server of Infomaniak Network SA in Switzerland.

E-mails — sign-in codes, acceptances and refusals, notifications — are sent through Infomaniak's mail server.

If you chose Telegram as your second factor, you receive sign-in codes through our Telegram bot. For this, the chat number and the message with the code go to Telegram, a service based outside Switzerland; Telegram is not our processor here but a separate service with its own terms, which you use yourself. There are no other processors or recipients. Apart from this case, the data does not leave Switzerland.

For how long

Account data and the content attached to it remain for as long as the account exists.

When the account is deleted, everything that belongs only to the account is removed at once: credentials, the profile with its picture, the vocabulary with its own recordings, teacher pairings and sessions. Two things remain, without your name and without any link to the account: chat messages stay in the conversation partner's history, and agreed lessons remain as the other side's record — the statutory retention applies to those. Lessons not yet held are cancelled with the deletion. The event record — who booked which lesson when, which status or payment changed — stays as well, under the random account number rather than a name or address; it exists as evidence towards the other party and can no longer be tied to anyone after the deletion.

In the lesson chat, people can write from fifteen minutes before the lesson until seven days after its planned end; after that it stays readable. Its pictures are deleted 24 months after the lesson, the texts remain. When an account is deleted, its own pictures in lesson chats are deleted at once, its own texts stay with the other side without a name. Once both participants have deleted their accounts, the lesson chat is deleted entirely. Reviews belong to the student's account and are deleted with it.

Sessions expire after the configured period; two-factor codes are valid for minutes, a link to connect Telegram for ten minutes; the records used to limit sign-in attempts are cleared continuously. The Telegram chat number is kept while Telegram is your second factor and removed when you switch to another method or delete your account.

Backups of the database are kept encrypted and deleted after ninety days. If you have your account deleted, you are therefore gone from the backups too, up to ninety days later.

Where the law requires retention — accounting records, for instance — the statutory period of up to ten years applies.

Your rights

Access to what is processed about you. Correction, where something is wrong. Deletion. Restriction of processing. A copy of your data in a common format. Objection to processing.

Much of this needs no request: name, picture, languages, time zone and location can be changed in your profile, and words and recordings deleted where they stand.

Access and deletion need no request either: under «Account» in your profile you can download a copy of all your data as a CSV archive, and delete the account there for good. This includes your own messages and pictures from lesson chats.

For anything else, a message to admin@pulsarsol.ch is enough.

Complaints

If you wish to complain, you can turn to the Swiss Federal Data Protection and Information Commissioner (FDPIC) in Bern.

Changes

This policy can change when the application changes. Every version carries a date, and your consent is stored with the date of the version you agreed to. If a change is material, we ask again.