Elvin
Privacy policy
This is a courtesy translation. In case of discrepancies, the German version prevails.
In short: Elvin is built so that all data stays on the iPhone. There is no Elvin server, no user account, no advertising, no analytics or tracking tools and no crash reports sent to us. We receive no personal data from the app. The only internet connection is the one-time download of the AI model from Hugging Face. This website sets no cookies and embeds no third-party services.
1. Controller
General-Wille-Strasse 96
8706 Feldmeilen, Switzerland
E-mail: info@cubera.ch
Phone: +41 44 554 84 89
Data protection officer: Pascal Hauser. Please send privacy enquiries to info@cubera.ch.
2. Scope and legal basis
This privacy policy applies to the website you are visiting and to the iOS app "Elvin" (bundle ID ch.cubera.elvin). We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and the Data Protection Ordinance (DPO). Where the EU General Data Protection Regulation (GDPR) applies to individual users, the information in section 9 applies in addition.
Where we process personal data, we rely on our legitimate interest in the secure and reliable operation of the website (Art. 31 para. 1 FADP). In the app we do not process any personal data ourselves; the data generated there remains under your sole control on your device.
3. Website
3.1 Server log files
When you visit this website, your browser transmits data to our server for technical reasons. The server may store the following in log files: IP address, date and time of access, file requested, amount of data transferred, referrer URL, browser type and operating system. This data is used solely to ensure operation, troubleshoot problems and defend against attacks. It is not merged with other data and is not used to identify individuals.
The website is hosted by Cubera Solutions AG itself on its own infrastructure in Switzerland; no external hosting provider is involved. Log files are kept only as long as necessary for the purposes stated and are then deleted.
3.2 No cookies, no tracking, no third-party services
This website sets no cookies, uses no web analytics (such as Google Analytics), no advertising networks and no social media plugins. Fonts, images and scripts are loaded exclusively from our own server. No content is loaded from third-party servers.
3.3 Contacting us
If you contact us by e-mail, we process the details you provide (such as e-mail address, name and the content of your message) in order to answer your enquiry. We delete this data once it is no longer needed to respond and no statutory retention obligations apply.
3.4 Links to third parties
The website links to www.cubera.ch, Apple's App Store and the licence pages of open-source projects. The privacy policies of the respective providers apply to those services.
4. The "Elvin" app
4.1 Principle: processing exclusively on the device
Elvin works without a user account and without a server of its own. All functions of the app, namely reading the photographed vocabulary lists, speech recognition, read-aloud, the AI model and the learning logic, run locally on the iPhone. The app does not transmit any content to Cubera Solutions AG or to third parties. We have no access to your vocabulary, photos, recordings or learning progress.
The following overview shows which data is generated in the app, where it is processed and whether it leaves the device.
| Data | Processing | Leaves the device? |
|---|---|---|
| Photos of homework | Text recognition with Apple Vision on the device; the photo is then discarded and not saved | No |
| Vocabulary, sets, learning progress, exam dates | Local database (SQLite) inside the app | No (except via your own iOS backup, see 4.3) |
| Spoken answers | iOS speech recognition, forced to run on the device; no recording is saved | No |
| Words read aloud | iOS speech synthesis on the device | No |
| Reminders | Local notifications scheduled on the device | No |
| AI model (file, about 1 GB) | One-time download from huggingface.co; afterwards used locally only | Only the technical connection data of the download (see 4.4) |
| Settings (languages, reminder time) | Local app storage | No |
4.2 Scanning homework (camera and photo library)
To capture a vocabulary list, you photograph it with the camera or choose an existing photo from your library. The image is read directly on the device using Apple's text recognition (Vision framework); the app also detects the language of each column locally. The photo is neither saved nor transmitted. The app needs the "Camera" or "Photos" permission for this, which you can revoke at any time in the iOS settings.
4.3 Vocabulary and learning progress
Your vocabulary sets, the results of your practice sessions and any exam dates are stored in a database within the app. This data forms part of your iPhone's normal device backup (iCloud backup or backup to a computer) if you have enabled it. Whether and how your device is backed up is controlled by you in the iOS settings; Apple's privacy policy applies to iCloud. We have no access to these backups.
4.4 AI model and download from Hugging Face
Elvin optionally uses a small language model (Qwen2.5-1.5B-Instruct, Apache License 2.0) that runs entirely on the device. It serves only as a fallback for pages that are not a clear table, and to accept answers written differently from the list (e.g. "it's" instead of "it is"). The model is downloaded once, either at first launch or later in the settings (about 986 MB).
The download comes directly from the servers of Hugging Face, Inc., 20 Jay Street, Brooklyn, NY 11201, USA. As with any download, Hugging Face receives the technical connection data of your device, in particular the IP address, the time and the file requested. No content from the app is transmitted, and no Hugging Face account is required. The transfer is encrypted (TLS). Hugging Face is independently responsible for this processing; the Hugging Face privacy policy applies. From a Swiss perspective the USA does not provide a consistently adequate level of data protection; since only technical connection data is transmitted and you choose the time of the download yourself, we consider the risk to be low. You can also use the app without the model (entering words manually) and delete the model again at any time in the settings.
After the download, the model runs exclusively offline on the device. Neither photos nor words nor answers leave the iPhone.
4.5 Speech recognition and speech synthesis
In the "Speak" practice mode, answers can be spoken. Elvin uses iOS speech recognition for this and explicitly requires on-device processing; no recordings are transmitted to Apple or to us, and no recordings are saved. Reading words aloud ("Dictation" mode and replay) is done with iOS speech synthesis, also locally. The app needs the "Microphone" and "Speech recognition" permissions for this.
4.6 Reminders
If you enter an exam date for a vocabulary set and enable the daily reminder, the app schedules local notifications on your device. There is no push server; the app does not use remote notifications. The "Notifications" permission can be revoked at any time in the iOS settings.
4.7 Permissions at a glance
- Camera: photographing the vocabulary homework.
- Photos: choosing an existing photo of the homework.
- Microphone and Speech recognition: answering vocabulary out loud.
- Notifications: daily reminder before an exam.
- Location: not used. The corresponding notice text exists only because the camera component used technically requires it; the app never asks for your location.
4.8 No analytics, advertising or crash reporting services
Elvin contains no software development kits (SDKs) from analytics, advertising or crash reporting services and sends no usage statistics. The only network connection the app establishes is the download of the AI model as described in section 4.4. This is enforced by automated tests in the source code.
4.9 App Store and TestFlight
The app is obtained through Apple's App Store. When downloading, updating and, where applicable, purchasing the app, Apple Inc. or Apple Distribution International Ltd. processes your data as an independent controller in accordance with Apple's privacy policy. If you have allowed sharing of analytics data with app developers in the iOS settings, Apple may provide us with anonymised crash reports and usage statistics; these contain no content from the app.
If you take part in a test version via TestFlight, Apple additionally collects information about your device (model, iOS version), the installation, crash logs and any feedback you actively send. Apple makes this information available to us for troubleshooting. Apple's TestFlight terms apply.
4.10 Deleting data
You can delete individual vocabulary sets in the app. The AI model can be removed in the settings. If you delete the app, all locally stored data is removed with it. Since we hold no copy of your data, deletion on our side is neither necessary nor possible. You manage data in your own iOS backups yourself.
5. Children
Elvin is aimed at school children. For precisely this reason, the app is designed so that it collects no personal data, requires no account and contains no advertising or tracking. We never ask children to provide personal details. Parents and guardians with questions about the app can reach us at info@cubera.ch.
6. Disclosure of data and transfers abroad
We do not disclose personal data to third parties. The only third parties your device communicates with in connection with Elvin are Apple (App Store, iOS services, backups) and Hugging Face (model download). Both act as independent controllers. For Hugging Face, based in the USA, the notes in section 4.4 apply.
7. Data security
Data in the app is protected by the security mechanisms of iOS (sandbox, device encryption). The model download and access to this website are encrypted (TLS/HTTPS). Since no data is transmitted to us, there is no data set on our side that could be compromised.
8. Your rights
Under the FADP you have the right to information about the processing of your personal data (Art. 25 FADP), to rectification (Art. 32 FADP), to erasure and to the release or transfer of your data (Art. 28 FADP). Since we receive no personal data from the app, any data we hold is generally limited to e-mail correspondence with you. Please send requests to info@cubera.ch; we may ask for proof of identity.
You also have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC, Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch).
9. Additional information for persons in the EU/EEA
Where the GDPR applies, we base the processing of this website's log data and of contact enquiries on our legitimate interest (Art. 6 para. 1 lit. f GDPR) or on responding to your request (Art. 6 para. 1 lit. b GDPR). You have the rights of access, rectification, erasure, restriction of processing, data portability and objection (Art. 15–21 GDPR), as well as the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). We have not appointed a representative in the EU under Art. 27 GDPR, as we process data of persons in the EU only occasionally and without special categories of data.
10. Changes
We may amend this privacy policy if the app, the website or the legal requirements change. The version published on this page at the time applies. We also point out material changes affecting the app in the release notes in the App Store. The short version in the app under Settings → Privacy reflects the content of this policy in child-friendly language; this page is authoritative.
11. Contact
Cubera Solutions AG, General-Wille-Strasse 96, 8706 Feldmeilen, Switzerland · info@cubera.ch · +41 44 554 84 89