Privacy Policy
Effective date: February 9, 2026 Last updated: February 19, 2026
Native (“the App”) is operated by LM Digital, a sole proprietorship (eenmanszaak) by Leo Mangold (“we”, “us”, “our”). This privacy policy explains what data we collect, why, and how we handle it.
LM Digital Molstraat 46 A, 2611 EN Delft, the Netherlands KVK: 96100567 Email: [email protected] Website: native.leomangold.com
What Data We Collect
Account Information
When you sign in with Google or Apple, we receive your name and email address from your authentication provider. We do not receive or store your password.
Translation Data
We store the phrases you request, the translations generated, and your conversation history. This data is tied to your account so you can access it across sessions.
Usage & Analytics
We collect anonymized usage data to understand how the App is used and to identify issues. This includes:
- Feature usage (which screens you visit, actions you take)
- Error and crash reports
- Device type and operating system version
- App version
We use PostHog for analytics, which is hosted in the European Union.
Language Preferences
We store your saved language profiles (language, proficiency level, tone preferences, etc.) to provide personalized translations.
Legal Basis for Processing
Under the GDPR, we process your personal data based on the following legal grounds:
| Processing activity | Legal basis | GDPR Article |
|---|---|---|
| Account creation and authentication | Performance of contract — necessary to provide the service you signed up for | Art. 6(1)(b) |
| Generating translations from your input | Performance of contract — the core service you use the App for | Art. 6(1)(b) |
| Storing your language profiles and conversation history | Performance of contract — necessary for the App to function as expected | Art. 6(1)(b) |
| Analytics and error tracking (PostHog) | Legitimate interest — understanding usage patterns and fixing bugs to improve the service | Art. 6(1)(f) |
| Responding to support requests | Performance of contract and legitimate interest | Art. 6(1)(b), Art. 6(1)(f) |
| Notifying you of important changes | Legitimate interest — keeping you informed about changes that affect your use of the service | Art. 6(1)(f) |
Where we rely on legitimate interest, we have assessed that our interests do not override your rights and freedoms. You may object to processing based on legitimate interest at any time (see Your Rights below).
How We Use Your Data
- Provide the service: Generate contextual translations based on your input and preferences.
- Improve the app: Understand usage patterns, fix bugs, and prioritize features.
- Communicate with you: Respond to support requests or notify you of important changes.
We do not use your data for profiling, automated decision-making, or any purpose other than those listed above.
Third-Party Services
We use the following third-party services to operate the App:
| Service | Purpose | Data shared |
|---|---|---|
| Google Sign-In / Apple Sign-In | Authentication | Email, name (provided by your auth provider) |
| Vercel AI Gateway (Vercel Inc.) | Routes translation requests to various AI language model providers | The text you submit for translation and your language settings |
| PostHog (EU-hosted) | Analytics and error tracking | Anonymized usage events, device info |
When you submit text for translation, your input is sent through the Vercel AI Gateway, which routes it to an AI language model provider for processing. No account identifiers (name, email) are sent to AI providers — only the text you submit and your language settings.
The specific AI models and providers we use may change over time as we improve the service. Providers may be located in the United States, the EU, or other regions. We will update this policy to reflect significant changes.
International Data Transfers
Your account data and translation history are stored in the European Union.
However, when you request a translation, your input text and language settings are routed through the Vercel AI Gateway to AI language model providers, which may be located outside the EU/EEA (including the United States and other regions). These transfers are protected by:
- Vercel’s Data Processing Addendum (DPA), which includes Standard Contractual Clauses (SCCs) approved by the European Commission
- No account identifiers (name, email) are sent to AI providers — only the text you submit and your language settings
If you have questions about specific transfer safeguards, contact us at [email protected].
We Never Sell Your Data
We do not sell, rent, or trade your personal data to anyone. We only share data with the third-party services listed above, strictly to operate the App.
Where Your Data Is Stored
Your data is stored on servers in the European Union. Our analytics provider (PostHog) is also hosted in the EU. See International Data Transfers above for details on data sent to AI providers.
How Long We Keep Your Data
- Account and translation data: Retained for as long as your account exists. If you delete your account, we delete all associated data within 30 days.
- Analytics data: Anonymized usage data is retained for up to 12 months, after which it is automatically deleted.
- Error and crash reports: Retained for up to 12 months for debugging purposes.
Cookies and Tracking Technologies
Website (native.leomangold.com): We do not use cookies or tracking technologies on our website.
Mobile App: The App uses PostHog for analytics, which may use device identifiers to track anonymized usage events. No advertising trackers or third-party tracking SDKs are used.
Your Rights
Under the GDPR, you have the following rights regarding your personal data:
- Access — Request a copy of the data we hold about you.
- Rectification — Request correction of inaccurate data.
- Erasure — Delete your account and all associated data.
- Restriction — Request that we restrict processing of your data in certain circumstances.
- Data portability — Receive your data in a structured, commonly used, machine-readable format.
- Object — Object to processing based on legitimate interest (e.g., analytics).
- Withdraw consent — Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.
- Lodge a complaint — You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at https://autoriteitpersoonsgegevens.nl.
To exercise any of these rights, email us at [email protected]. We will respond within 30 days.
Automated Decision-Making
The App uses AI language models to generate translations based on your input. This processing is automated but does not constitute automated decision-making or profiling that produces legal effects or similarly significant effects on you, as defined under GDPR Article 22. The translations are informational and provided for your personal use.
Children’s Privacy
The App is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.
Beta Disclaimer
The App is currently in a testing phase. During this period, features may change, and in rare cases, data may be reset. We will notify you in advance if a data reset is necessary.
Changes to This Policy
If we make significant changes to this policy, we will notify you through the App or by email. Minor updates (clarifications, formatting) may be made without notice. The “Last updated” date at the top of this page will always reflect the most recent revision.
Contact
If you have questions about this privacy policy or your data, reach out to us:
LM Digital Molstraat 46 A, 2611 EN Delft, the Netherlands KVK: 96100567 Email: [email protected]