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Privacy Policy — Sha'ar

Last updated: 18 August 2026

1. Who is responsible for your data

The controller of the personal data described here — the party legally responsible for it under the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") — is the publisher of Sha'ar:

SmartZonesIndicators
Contact: support@smart-zones-indicators.com

The publisher is established in France. French and European data protection law applies, and the French supervisory authority (the CNIL) is competent.

The organisation identifier used in the app's bundle is com.smartzonesindicators. That is a technical identifier chosen for the App Store, not a statement of who the legal entity is; the legal name is the one given above.

2. What stays on your iPhone

Sha'ar saves the state of your learning locally, using the standard iOS storage for app preferences (UserDefaults). This includes:

• the act you have reached and whether you have finished the prologue;
• your mastery of each letter, and which opening gates you have already played;
• the words you have discovered;
• your best score and the result of your last daily trial;
• your settings: sound on or off, colour tinting, and how the divine Name is displayed;
• the Hebrew name you may write in the Codex, if you choose to write one.

None of this is sent anywhere. It is not uploaded to us, not synchronised to iCloud by the app, and not shared with any third party. It exists only in the app's own storage on your device.

The Hebrew name in particular — which you type yourself, and which the app never guesses from anywhere — is a piece of text held on your device. We never see it.

Deleting Sha'ar from your iPhone deletes all of it, permanently and immediately. That is also the simplest way to exercise your right to erasure over this data: it is in your hands, not ours.

Storing this information on your device is strictly necessary to provide the service you asked for — an app that remembers where you are in it. Under Article 82 of the French Data Protection Act, storage of this kind does not require your prior consent.

3. What leaves your iPhone

Only one thing does: buying and restoring the full version of the app. Everything else — the lessons, the 126 recorded pronunciations, the whole corpus of words — is contained in the app itself and needs no network at all.

3.1 Apple

The purchase itself is handled entirely by Apple, through the App Store and its In-App Purchase system. You pay Apple, using the payment method already on your Apple Account.

We never see your card number, your name, your billing address, or your Apple Account. Apple does not pass them to us. What we later receive from Apple is aggregated sales reporting, which does not identify individual buyers.

Apple's own handling of your data is governed by Apple's privacy policy, which we do not control.

3.2 RevenueCat

Sha'ar uses the RevenueCat SDK (version 5.83.2) to register that purchase and to know whether the full version is unlocked on this device. It is the only third-party code in the app, and the only route by which anything at all leaves your iPhone.

RevenueCat, Inc. acts as our processor: it handles this data on our instructions and for no purpose of its own beyond providing and securing the service. There are two reasons we use it. A purchase you made once should still be restorable years later, on a new iPhone, from a receipt checked on a server rather than only on the device. And the publisher reads the sales of all its apps in one dashboard rather than one per app.

When the app checks the state of your purchase, or when you buy or restore, this is what is sent to RevenueCat's servers:

• An anonymous app-user identifier generated on your device — a random value of the form $RCAnonymousID:…. It attaches a purchase to an installation without saying who you are. It is drawn at random on your device; it is derived from no name, no e-mail and no Apple Account. The app never calls RevenueCat's log-in function, so it is never replaced by an identifier of ours — there is no account here to replace it with.
• The purchase and the App Store receipt — which product was bought, when, and whether this device still owns it. This is what lets the receipt be validated, fraud be turned away, and the content you paid for be unlocked, including on a new device when you tap “Restore purchases”.
• The technical information carried by every request — the SDK version, your iOS version, your device model, the app's version, build number and bundle identifier, your App Store country, and up to three of your preferred languages. The SDK puts these in the headers of each request, so that RevenueCat reads the receipt correctly and answers for the right store.
• The vendor identifier (IDFV) that iOS assigns to our apps on your device. The SDK sends it in a request header. It belongs to us as a developer — it cannot be cross-referenced with another company's apps — and it is reset when you delete all of our apps from the device.
• The IP address the request comes from — unavoidably visible to any server that receives a request from the internet.

What is not sent: no name, no e-mail address, no telephone number, no advertising identifier (IDFA), no location, no contacts, no health data, no browsing history, and no identifier we would have chosen. The app uses none of RevenueCat's identification, attribution or customer-attribute features, and never calls the functions that would collect an advertising identifier.

The privacy manifest RevenueCat publishes with the code we use declares one single category of collected data — purchase history — marked as not linked to your identity and not used for tracking.

Nothing about your learning is sent to RevenueCat. Your progress, your score, the words you have found and the Hebrew name you wrote never leave the device.

RevenueCat's answer — whether the unlock is active — is kept in the app's own storage on your iPhone, so that the full version stays open when you have no network.

RevenueCat's own handling of data is described in its privacy policy.

4. What Sha'ar does not do

• No advertising. None, of any kind, from anyone.
• No analytics of your learning. There is no measurement SDK in the app. We do not know which screens you open, how long you play, or whether you finish an act. What the publisher can read is how many copies were sold — a figure that names nobody.
• No tracking across apps or websites. The app does not use the App Tracking Transparency framework, because it has nothing to ask you for.
• No account, no sign-up, no password. The app never asks who you are.
• No system permissions. Sha'ar does not request access to your contacts, photos, location, microphone, camera, calendar, or notifications.
• No server of ours. We operate no backend. The only server the app ever addresses is RevenueCat's, and only about the purchase — described in section 3.2.
• No streaming. The 126 spoken words are audio files inside the app. Playing one makes no network request.
• No cookies. The app contains no web browser and no web pages. This page you are reading sets no cookie and loads nothing from any other server.
• No sale or sharing of personal data. We have no personal data to sell, and we would not.

5. Legal bases

• Unlocking and restoring the full version on your device — performance of the contract between you and us (GDPR, Article 6(1)(b)). The purchase is registered with RevenueCat and read back from it; without that there is no way to give you what you paid for, nor to give it back to you on another iPhone.
• Reading the publisher's own sales figures — our legitimate interest in knowing what our apps sell (GDPR, Article 6(1)(f)). What we read are counts and totals in the RevenueCat dashboard. Nothing in them names you, and the balance is straightforward: the interest is ours, the data is a receipt with no person attached to it.

There is no consent to collect and none to withdraw, because there is nothing here that would require it: no advertising, no analytics of your learning, no profiling, no marketing e-mail, no newsletter.

6. How long data is kept

• On your device: until you delete it in the app or delete the app. We set no expiry and we cannot reach it.
• At RevenueCat: the purchase attached to the anonymous identifier is kept for as long as the record exists in our RevenueCat dashboard, so that a purchase stays restorable years later — which is precisely what a lifetime unlock is for. RevenueCat's own privacy policy states that it keeps personal data for as long as the customer relationship lasts, and for six years after that, to identify issues and resolve legal proceedings. We can ask RevenueCat to erase a record: see section 8.
• At Apple: Apple keeps its own record of the transaction, under its own policy and its own legal obligations, for accounting and tax purposes. We do not control that retention.

7. Transfers outside the European Union

RevenueCat, Inc. is established in the United States and states that it hosts its customers' data on Amazon Web Services infrastructure in the United States. Registering and restoring a purchase therefore involves a transfer of data outside the European Union.

RevenueCat's data processing addendum incorporates the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914), module two — controller to processor — for transfers from the EEA, together with the UK International Data Transfer Addendum published by the Information Commissioner's Office on 21 March 2022, and amendments covering Swiss transfers.

The data concerned by that transfer is the data listed in section 3.2: an anonymous identifier, the purchase, and the technical information carried by the request. Your progress, your name in Hebrew and everything else are transferred nowhere, because they never leave your iPhone.

Apple's own transfers, for the payment itself, are governed by Apple's policy, which we do not control.

8. Your rights

Under the GDPR you have the right of access to your personal data, and the rights to rectification, erasure, restriction of processing, data portability, and to object to processing based on legitimate interest.

In practice:

• For everything held on your device — that is, almost everything — you already have complete control. You can change your settings and your Hebrew name in the app at any time, and deleting the app erases the whole record. We hold no copy.
• For your purchase data at RevenueCat, write to support@smart-zones-indicators.com. Because the record is attached to an anonymous identifier and not to your identity, we may need the App Store receipt or the transaction identifier of your purchase in order to find the right record rather than somebody else's. If what you send us does not identify it, we will tell you so rather than guess.
• Note that erasing your purchase data takes away your ability to restore that purchase on another device.

We answer requests within one month, as the GDPR requires.

If you believe your rights have not been respected, you may lodge a complaint with the French supervisory authority:

Commission Nationale de l'Informatique et des Libertés (CNIL)
3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France
www.cnil.fr

If you live in another EU or EEA country, you may also complain to your own national authority.

9. Children

Sha'ar is rated 4+ on the App Store. It contains nothing unsuitable for children, no advertising, no external links, no chat, and no way for one user to contact another.

The app asks for nothing that identifies anyone, whatever their age. There is no account to create, no name or e-mail to give, no address book to read. The Hebrew name a child might write in the Codex stays on the device and is never transmitted. The purchase data described in section 3.2 carries no name and no age: it is a receipt attached to a random identifier. Because nothing identifying is collected, the question of parental consent for the processing of a child's data does not arise.

Buying the full version happens through the App Store, under whatever Family Sharing and Ask to Buy rules the parent has configured on the Apple Account.

10. Where you live

Sha'ar is available in several countries, and the protections described here are applied to everyone who uses it, not only to users in the European Union. Depending on where you live, your national law may give you further rights — for example under Brazil's Lei Geral de Proteção de Dados or under Israeli privacy law. If you wish to exercise a right that is not listed above, write to us and say which law you are relying on.

11. Changes to this policy

If the app changes in a way that affects what happens to your data, this page is updated and the date at the top changes with it. Significant changes will also be announced in the app's App Store release notes.

12. Contact