Privacy Policy

1. Who we are

Crossing: Travel Phrasebook ("Crossing") is made by Inginity LLC ("we", "us"), 1021 Broad St #1017, Shrewsbury, NJ 07702, United States. We decide how and why your personal information is processed, which makes us the controller under the EU and UK General Data Protection Regulation (GDPR), the data fiduciary under India's Digital Personal Data Protection Act, 2023 (DPDPA), the controlador under Brazil's Lei Geral de Proteção de Dados (LGPD), and the business under California law.

Questions or requests about privacy: info@inginity.studio. This address also reaches the person responsible for data protection at Crossing, including for grievances under the DPDPA and as our encarregado contact under the LGPD.

2. Where your information goes

3. What we collect and why

3.1 A random app ID

The first time Crossing connects to the internet, it creates a random identifier using Firebase Anonymous Authentication. The app shows it to you as your Support ID, under Privacy & data in Profile, so you can quote it when you write to us. It isn't linked to your name, email address, phone number, contacts or advertising identifiers. We use it to keep your saves and settings in sync and to connect a Premium subscription to your copy of the app. When the ID is created, and whenever the app renews its sign-in, Google's servers also receive your IP address and basic information about your device and app version, which Firebase uses to provide the service and protect it from abuse.

Legal basis: providing the service you asked for (GDPR Art. 6(1)(b); LGPD Art. 7, V).

3.2 An account, if you create one

Every feature of Crossing works without an account. If you create one, in Profile under Account, it's added to your random app ID, so your saves and settings follow you to a new phone. How you sign in decides what we receive:

• Email and password: your email address and your password. Firebase Authentication keeps the password only in a one-way hashed form, and we never see it. If you ask to reset it, Firebase emails a reset link to that address.
• Sign in with Apple (iPhone): an identifier for your Apple Account and your email address. If you choose Hide My Email, Apple gives us a private relay address that forwards to you instead.
• Sign in with Google: an identifier for your Google Account, your email address, and the name and profile picture your Google Account shares. We don't use your name or picture. Google's sign-in software may also collect information that secures the sign-in, such as device identifiers, your approximate location and, where your Google Account uses one for verification, your phone number. Google processes that information under its own privacy policy.

Firebase Authentication also records when the account was created and when you last signed in. Apple and Google confirm who you are under their own privacy policies. If the sign-in you choose already belongs to a Crossing account, the app asks before switching to it, then deletes the synced copy kept under the random app ID you're leaving. Signing out keeps your account and synced data for when you sign back in. You can delete your account in the app at any time (section 11).

Legal basis: providing the service you asked for (GDPR Art. 6(1)(b); LGPD Art. 7, V).

3.3 Saves, practice progress and settings kept in sync

We store, under your random app ID: the phrases you mark as favorites and the Situations you save, each recorded as the name of a catalog item (never free text) with the time you saved it; your practice progress from Learn, which for each phrase in each language is how many of your answers were right or not, when you last practiced it and when it's next due for review, and for each day you practice, how many phrases you practiced, how many quiz answers you gave and got right, how many quiz sessions you started, and whether a streak saver covered a day you didn't practice; the languages you've chosen to compare; and your theme, script, romanization, pronunciation-guide and audio settings. Saves and practice progress in our health, dietary, emergencies and accessibility categories, and every card, are never included. They stay on your phone (section 4).

Legal basis: providing the service (GDPR Art. 6(1)(b); LGPD Art. 7, V). The database is Google Cloud Firestore, located in the United States.

3.4 Crash and error reports

If Crossing crashes, Firebase Crashlytics sends us a report containing: the technical trace of what went wrong, the app version, device model, operating system version, device state at the time (such as free memory and storage, and screen orientation), installation identifiers, and the time. Each time the app starts, Crashlytics also records a session event with the same kind of device and app details, so we can see how often Crossing runs without crashing. We don't add your saves, searches or anything you type to crash reports, and we don't attach your random app ID to them.

Legal basis: our legitimate interest in keeping Crossing stable and secure (GDPR Art. 6(1)(f); LGPD Art. 7, IX). We keep reports minimal so that this interest doesn't override yours, and you can object at any time by writing to us.

3.5 App integrity checks

To stop automated abuse of our servers, Crossing uses Firebase App Check. Your device obtains a short-lived token from Apple's App Attest (iPhone) or Google Play Integrity (Android) that confirms the request comes from a genuine copy of the app. Apple, Google and Firebase process that check under their own terms. We don't receive your device's hardware identifiers.

Legal basis: our legitimate interest in security and fraud prevention (GDPR Art. 6(1)(f); LGPD Art. 7, IX).

3.6 Premium purchases

Subscriptions are sold and billed by Apple (App Store) or Google (Google Play). They handle your payment details, and we never see your card or bank information. Our subscription service, RevenueCat, receives from the store and your device: your random app ID; the product, price, currency, dates and status of your purchases, trials, renewals, refunds and cancellations; your store country; your device type, operating system and app version; and your IP address, used to process and secure those requests.

Legal basis: providing the service you bought (GDPR Art. 6(1)(b); LGPD Art. 7, V), and keeping financial records the law requires (GDPR Art. 6(1)(c); LGPD Art. 7, II).

3.7 Their reply

Their reply lets someone type an answer in their language so you can read it in English. The text is translated on your phone by Google's ML Kit. Crossing never stores or logs it, and never sends it to us or to a translation server. The first time you use a language, the app downloads a translation model from Google's servers. Like any download, that request reveals your IP address and which language model was requested. ML Kit may also send Google technical and usage information about how the feature runs, such as device model, operating system version, performance statistics, the languages used and an identifier for this installation of the app. Google processes that information under its own terms, and it isn't linked to your random app ID.

Legal basis: providing the feature you chose to use (GDPR Art. 6(1)(b); LGPD Art. 7, V).

3.8 Audio

Crossing reads phrases aloud using your device's built-in text-to-speech engine (from Apple or Google, or another engine you've set up). The phrase text goes to that engine, which may process it under its provider's terms. We receive nothing from it. Crossing doesn't use your microphone.

3.9 When you contact us

If you email us, we receive your email address, what you write, and anything you choose to include, such as your device model or an App Store or Google Play order number. We use it only to answer you and to keep a record of our reply. Please don't send us health or other sensitive information. If you do, we'll use it only to respond and then delete it.

Legal basis: our legitimate interest in answering questions and improving Crossing (GDPR Art. 6(1)(f); LGPD Art. 7, IX), or taking steps you've asked for (GDPR Art. 6(1)(b)).

If you write to ask us to tell you when Crossing launches, we'll send one email when it does and then delete your address. Legal basis: your consent (GDPR Art. 6(1)(a); LGPD Art. 7, I), which you can withdraw at any time by telling us.

3.10 This website

This website sets no cookies, uses no analytics or advertising tools, and loads nothing from third parties. It is delivered by Amazon Web Services, which processes each visitor's IP address, browser type, the page requested and the time, to deliver the site and protect it from attacks. Where access logging is switched on, we keep those logs for no more than 30 days.

Our short link, getcrossing.app, is part of this website: it reads your browser's user agent (the description of your browser and device that every browser sends) only to send you to the App Store, Google Play or this site. It passes on only the link's campaign name (such as "tiktok"), so the stores can count installs per channel, and nothing about you. It sets no cookies and stores nothing; if access logging is switched on, its requests are logged like any other visit and kept for no more than 30 days.

Legal basis: our legitimate interest in running a secure website (GDPR Art. 6(1)(f); LGPD Art. 7, IX).

4. What stays on your phone

We designed Crossing so the following never leave your device and are never collected by us: favorites, saved Situations and practice progress in the health, dietary, emergencies and accessibility categories; every card you save or view; your recently viewed phrases; the form you choose under Phrases about you, where some languages change a word for a man or a woman; the emergency contact you add to the medical cards, a name and a phone number you type in yourself; and your downloaded translation models. They're kept in the app's private storage, and deleting the app deletes them.

The medical cards also show the local emergency number for an ambulance, which is built into the app. When you or someone helping you taps that number or your emergency contact, Crossing hands the number to your phone's dialer, and your phone makes the call. Crossing never reads your phone's contacts, and the number you tap is never sent to us.

What you search for, and anything typed into Their reply along with its translation, isn't saved anywhere, on your phone or by us.

When you sign out of an account, Crossing first checks that your account holds your synced saves, then removes them from this phone. The saves that never leave your phone stay on it.

5. Health and other sensitive information

Some of Crossing's phrases and cards are about allergies, medical conditions, diet or disability, and saving them could reveal something about your health or beliefs. That kind of information receives special protection under GDPR Article 9, LGPD Article 11, California law and other laws. We don't collect it: the app keeps those saves on your device and excludes them from cloud sync. We don't use any information to infer your health, religion or other sensitive characteristics.

6. What we don't do

• We don't sell your personal information, and we don't share it for cross-context behavioral advertising.
• We don't show ads or work with advertising networks or data brokers.
• We don't track you across other companies' apps or websites, and we don't access your device's advertising identifier.
• We don't make decisions about you based solely on automated processing, including profiling, that have legal or similarly significant effects.
• We don't access your location, contacts, photos, camera or microphone.

7. Who we share it with

We use a small number of service providers who process information on our behalf, under contracts that require them to protect it and use it only to provide their service to us:

Apple and Google also run the app stores you download Crossing from and buy Premium through. They act independently under their own privacy policies for payments and app distribution, as does Google for translation model downloads (section 3.7). If you sign in with Apple or Google, they confirm who you are under their own privacy policies too.

We may also disclose information if the law requires it or to answer a valid legal request; to protect the rights, property or safety of our users, the public or us; or to a buyer or successor if our business is reorganized or sold, in which case this policy continues to protect your information and we'll tell you before it becomes subject to a different one.

8. International transfers

Our providers store and process information in the United States and other countries whose laws may differ from yours. Where the law of your country requires a safeguard for these transfers, we rely on the European Commission's Standard Contractual Clauses (with the UK Addendum and Swiss adaptations where relevant), on a recipient's certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions where it has one, on the mechanisms of LGPD Article 33 for transfers from Brazil, and on the DPDPA's rules for transfers from India. You can ask us for a copy of the safeguards we use.

9. How long we keep it

Deleted information may remain in our providers' encrypted backups until those backups are routinely overwritten, and isn't used in the meantime.

10. How we protect it

Information is encrypted in transit with TLS and encrypted at rest by our providers. Database rules let each random app ID read and write only its own saves, progress and settings, and App Check blocks requests that don't come from a genuine copy of the app. Access to our provider accounts is limited to the people who need it and protected with strong authentication. No method of storage or transmission is completely secure. If a breach affects your information, we'll notify you and the relevant authorities as the law requires.

11. Your rights and how to use them

Depending on where you live, you may have the right to: know what personal information we hold about you and get a copy; correct it; delete it; receive it in a portable format; object to or restrict how we use it; withdraw consent you've given; appeal a decision we make about your request; and complain to a data protection authority. We won't treat you differently for using any of these rights.

How to make a request. Email info@inginity.studio and tell us what you'd like us to do. If you have an account, tell us its email address. Otherwise, the information we hold is tied only to a random app ID, so we may need your help to find it. The simplest way is to include your Support ID, which is that random app ID: in the app, open Profile, and copy it from Privacy & data. It isn't a password and it doesn't identify you to anyone else. If you can't reach it and you have Premium, include the order number from your App Store or Google Play receipt instead. Otherwise, tell us roughly when you started using Crossing and on what kind of device. If we can't reliably connect any information to you, we'll explain that, as GDPR Article 11 and similar laws allow. We never ask for more information than we need, and we delete what you send us for verification once we're done.

How quickly we respond. Within one month under the GDPR (extendable by two months for complex requests, with notice), within 45 days under U.S. state laws (extendable once by 45 days, with notice), within 15 days for a full access report under the LGPD, and within the time the DPDPA and its rules set for India.

Deleting data yourself. If you created an account, open Profile, tap Account, then Delete account: after confirming it's you, that deletes your account, your email address and sign-in details, and everything synced to it. Without an account, Crossing can still delete your synced data from inside the app: open Profile, then under Privacy & data tap Delete synced data. That removes your random app ID and everything stored under it — your synced favorites, saved Situations, practice progress, languages and display settings — and the app starts again with a new random ID. Removing a single favorite or saved Situation deletes it from our database too, the next time your phone is online. Deleting Crossing from your phone removes the saves, history and settings the app keeps there, but not what's in our database. Delete your data covers both, what we keep afterwards, and how to ask us to remove the subscription record the app can't reach. Deleting your data doesn't cancel a subscription; cancel Premium in your App Store or Google Play settings.

12. EEA, UK and Switzerland

The legal bases we rely on are set out in section 3: performance of a contract (Art. 6(1)(b)), legal obligation (Art. 6(1)(c)), legitimate interests (Art. 6(1)(f)) and, for launch emails, consent (Art. 6(1)(a)). Where we rely on legitimate interests you may object, and we'll stop unless we have compelling grounds or need the information for legal claims. Providing the information in sections 3.1, 3.3, 3.4 and 3.5 is needed for the app's online features; without it, the app still works offline. You can complain to the data protection authority where you live or work, such as your EU supervisory authority, the UK Information Commissioner's Office, or Switzerland's Federal Data Protection and Information Commissioner, though we'd appreciate the chance to help first.

13. United States

This section applies to residents of California and other states with comprehensive privacy laws, where those laws apply to us. In the last 12 months we collected these categories of personal information, from you and your device and from Apple and Google:

• Identifiers: the random app ID, installation identifiers used for crash reporting and app integrity checks, and IP address; if you create an account, your email address, the account identifier Apple or Google provides, and the name Google shares.
• Commercial information: subscription and transaction records.
• Internet or other electronic network activity: which catalog items you save, your practice progress and your settings, and website request details.
• Device and diagnostic information: device type, operating system and app version, crash reports and app session events.
• Communications: your email address and messages if you contact us.

We use these categories for the purposes in section 3, keep them for the periods in section 9, and disclose them only to the service providers in section 7 for those purposes. We don't sell or share personal information, and we haven't done so in the last 12 months. We don't collect or use sensitive personal information to infer characteristics about you. We don't knowingly sell or share the personal information of consumers under 16.

You have the right to know, access, correct and delete your personal information, and not to be discriminated against for using these rights. Because we don't sell or share personal information or use sensitive personal information beyond what the law permits, there's nothing to opt out of or limit; we also treat Global Privacy Control signals as a valid opt-out request. You may use an authorized agent, who must give us signed permission from you; we may still ask you to confirm your identity. If you live in a state that provides a right to appeal and we decline your request, reply within 45 days with the subject "Appeal" and we'll respond within the time your state's law requires. If you're still not satisfied, you can contact your state attorney general. We don't disclose personal information to third parties for their own direct marketing.

14. Brazil

Under the LGPD, we process personal data on the bases in section 3: performance of a contract (Art. 7, V), compliance with a legal obligation (Art. 7, II), legitimate interest (Art. 7, IX) and consent (Art. 7, I). You have the rights in Article 18, including confirmation that we process your data, access, correction, anonymization, blocking or deletion of unnecessary or excessive data, portability, information about who we share it with, information about the possibility of refusing consent and its consequences, and revocation of consent. Our encarregado can be reached at info@inginity.studio. You may also file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

15. India

Under the DPDPA, we are the data fiduciary for the personal data described in this policy, which we process for the purposes in section 3, retain for the periods in section 9, and share only with the processors in section 7. We process it with your consent, which you give by choosing to use the app's online features and which you can withdraw as easily as you gave it, or for a legitimate use the DPDPA allows. You have the right to access information about your personal data, to correct, complete, update or erase it, to have grievances redressed, and to nominate someone to exercise your rights if you die or become unable to. Our grievance contact is info@inginity.studio. If we don't resolve your grievance, you can complain to the Data Protection Board of India. On request, we'll provide this notice in any language listed in the Eighth Schedule to the Constitution of India. In India, a person under 18 is a child under the DPDPA and may use Crossing's online features only with the verifiable consent of a parent or lawful guardian.

16. Children

Crossing is a general travel app and isn't directed to children. We don't knowingly collect personal information from children under 13, or under the age at which a person can consent to online services where they live, which is higher in some countries (16 in parts of the EU, 18 in India). If you believe a child has given us personal information, write to us and we'll delete it.

17. Changes to this policy

If we change this policy, we'll update the effective date at the top. If a change materially affects how we handle your information, we'll tell you in the app or on this website before it takes effect and, where the law requires, ask for your consent.

18. Contact us

Inginity LLC
1021 Broad St #1017, Shrewsbury, NJ 07702, United States
info@inginity.studio