MaltaReady – Privacy Policy

MaltaReady is a mobile app that teaches practical Maltese to workers moving to Malta. It is published by Rahul Gupta, New Delhi, India ("we"). This policy explains what the app does with your data. The short version: the app works offline, your voice recordings never leave your phone, and the only information we receive is what is needed to activate the full course.

1. Data we do not collect

• Voice recordings. When you use the pronunciation checker, the recording is processed entirely on your phone by a speech model that runs inside the app. Recordings are not uploaded, not stored on our servers, and are deleted from the phone when you record again or leave the screen.
• Personal details. The app has no account, no sign-up, and does not ask for your name, email, phone number, location or contacts.
• Advertising or analytics. The app contains no advertising and no third-party analytics or tracking.

2. Data we receive

• Activation. If you unlock the full course with an activation code, the app sends the code and a random device identifier generated by the app to our activation server, so that the code can be tied to your device and cannot be shared. We keep the code, the device identifier and the activation date. This identifier is not your phone's serial number or advertising ID and cannot identify you personally.
• In-app purchase. If you unlock the full course through the App Store or Google Play, the purchase is handled by Apple or Google under their own privacy policies. We receive a purchase confirmation and no payment details.
• Speech model download. On first use the app downloads a 71 MB speech-recognition model file from our hosting provider. This is an ordinary file download; we do not collect anything from it beyond standard server logs (IP address, time), which are kept for at most 30 days for security.

3. Permissions

• Microphone – only when you tap Record on the Practice screen, to compare your pronunciation with the native speaker. You can refuse it; the rest of the app works without it.
• Internet – to download the speech model once and to activate a code. All lessons and audio work offline.

4. Data on your phone

Your progress, language choice and activation state are stored only on your device. Deleting the app deletes them.

5. Children

The app is intended for adults preparing to work in Malta and does not knowingly collect data from children.

6. Who processes the data, and where

• Controller. Rahul Gupta, New Delhi, India (contact below). MaltaReady is an independent app and is not affiliated with the Government of Malta.
• Legal basis. Activation data is processed because it is necessary to provide the course you unlocked (performance of a contract, GDPR Art. 6(1)(b)). Server logs for the model download are kept for security (legitimate interest, Art. 6(1)(f)). Nothing is processed on the basis of consent, which is why the app shows no consent banner.
• Processors. Activation records are stored with Supabase Inc. (database hosting). Store purchases are handled by Google Play or the App Store, with purchase verification by RevenueCat Inc. The speech model file is served by Hugging Face. Each acts under a data-processing agreement with standard contractual clauses.
• Location and transfers. The activation database is currently hosted in Mumbai, India. Transfers from the EU rely on the processors' standard contractual clauses. The data concerned is a random identifier, a code and a date; it contains no name, email or payment detail.
• Retention. Activation records are kept for as long as the code is active and for 12 months after it is removed, then deleted. Download server logs are deleted after 30 days.

7. Your rights

Under the GDPR you may ask for access to, correction of, or deletion of the activation data we hold for your device, object to its processing, or ask for a copy of it. Write to the address below and quote your activation code; we reply within 30 days. Deleting the record deactivates the course on that device. You may also complain to your data-protection authority; in Malta this is the Information and Data Protection Commissioner (idpc.org.mt).

8. Changes

If this policy changes, the new version will be published at this address with a new date.

9. Contact

Rahul Gupta · notrahulgupta@gmail.com