Privacy Policy

Last updated 8 November 2026 · Effective 8 November 2026

Draft for review by counsel. Text marked like this must be completed before publication.

This policy explains what B2B SaaS Inc. ("Suomi Daily", "we", "us"), [company address], collects when you use the Suomi Daily app for iPhone, iPad and Mac (the "App") and this website (the "Site"), why, who else sees it, and how you can control it. The short version: your learning data stays in your own iCloud; what you type and say goes to two processing providers through our server to be corrected or spoken and is not kept; the leaderboard is opt-in; and the Site has no analytics, advertising or tracking.

1. What we collect

Account

If you use Sign in with Apple, Apple gives us a stable anonymous user identifier and, if you choose to share it, your name. We do not receive your Apple ID password. If you choose "Continue without an account", nothing is sent to us and your data stays on the device.

Profile

Optionally, a first and last name, a city and country, and a profile photo. These are stored in your iCloud private database. Your name, city, country and photo are also shown on the leaderboard unless you turn it off (section 5).

Learning data

Your progress through units, review cards and their scheduling data, streak, minutes practised, words you have saved, errors the tutor has noted, and downloaded lessons. This lives on your devices and, if you are signed in, in your iCloud private database, which Apple encrypts and which we cannot read.

Content you create

Text you type in Write and Speak, and the on-device transcript of what you say. Audio of your voice is processed by Apple's speech recognition on your device or, depending on your device settings, on Apple's servers (see section 4); we receive the text, not the recording. This content is sent to our server and on to the processors in section 3 for the purpose you asked for, and is not stored by us.

Shared content

Photographs, audio clips, glosses and translations for course material are produced once and stored in a shared public CloudKit database so that every learner receives the same assets. These records describe course content, not you.

Subscription

Apple processes your payment. We receive a signed receipt that tells us whether your subscription is active and which plan you have; we do not receive your card number, billing address or Apple ID email.

Technical data

When the App calls our server, the server sees your IP address and the subscription receipt it needs to authorise the request, and keeps a short-lived usage counter per subscription to enforce fair-use limits. The App contains no advertising or analytics SDK. The Site logs the standard web-server data (IP address, user agent, pages requested) kept by our hosting provider for a short period for security.

2. How we use it

We do not sell personal data, we do not use it for advertising, and we do not use your content to train models. Where the GDPR or UK GDPR applies, our legal bases are performance of our contract with you (sections 2.1 to 2.4), your consent (leaderboard, permissions, waitlist), and our legitimate interests in keeping the Service secure and answering you.

3. Who else processes it

ProcessorWhat it receivesWhy
Anthropic, PBC Text you type or dictate in Write and Speak, the words and dialogue of the current unit, and short prompts describing course content. Correcting your Finnish, holding the guided conversation, writing glosses, translations and photo briefs. Sent through our server; not stored by us. Anthropic processes it under its commercial terms.
ElevenLabs, Inc. Finnish text to be spoken: words, examples, dialogue lines and lesson scripts. No text you wrote about yourself is sent unless the tutor reads it back to you. Native Finnish speech for lessons, cards and conversation. Sent through our server; the resulting audio is cached and shared as course content.
Apple Inc. (iCloud and CloudKit, Sign in with Apple, App Store, speech recognition) Your learning data and profile in your private database; shared course assets in the public database; sign-in identifier; subscription receipts; and, when on-device recognition is unavailable, audio for speech recognition. Sync, authentication, payment and speech recognition under Apple's privacy policy.
Our proxy server host ([Railway, Inc.]) The requests described above in transit, your IP address, and per-subscription usage counters. Operating the server that holds our provider keys so that your device never needs them.
Website host and form database ([Vercel, Inc., with Vercel Postgres provided by Neon, Inc.]) Web-server logs, waitlist entries and support messages (section 11). Serving this Site and storing the waitlist and support messages.
Yle (Finnish Broadcasting Company) Your device requests public news feeds directly. Reading material in later phases of the course. No account data is sent.

We may also disclose data if the law requires it, to protect the rights and safety of learners or others, or to a successor if the business is sold, in which case this policy continues to apply.

4. Device permissions

The App asks for each permission only when you reach the feature that needs it, with the reason shown by iOS or macOS. You can change any of them in your device Settings.

5. The leaderboard

The leaderboard is a public table of learners ranked by streak, words in review and minutes practised. Once you have set up a profile you appear on it by default: your display name, city, country, profile photo and those three numbers are published to a shared CloudKit database and shown to everyone who uses the App. You can leave at any time by turning off Show me on the leaderboard in your profile; your entry is removed from the shared database. The leaderboard never shows your email, your Apple identifier, or what you have written or said.

6. Retention and deletion

To delete everything we hold about you, send a message through the support form and choose Privacy or data deletion, or write to [contact email] from the address you used. We will confirm within 30 days. Deleting your App Store subscription is done through Apple (see the Terms).

7. Security

Traffic between the App, our server and our providers is encrypted in transit. Our provider keys are held on the server, never on your device. Requests to the server are authorised with a signed App Store receipt. Your iCloud data is protected by Apple's encryption and your Apple Account security. No system is perfectly secure; if we learn of a breach affecting you we will tell you and the relevant authorities as the law requires.

8. Children

Suomi Daily is not directed at children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child under 13 has given us personal information, tell us through the support form or write to [contact email] and we will delete it. Where local law sets a higher age for consent to data processing, that age applies.

9. International transfers

We are based in [country], and our processors operate in the United States and the European Union. Where data about people in the EU, EEA, UK or Switzerland is transferred to a country without an adequacy decision, we rely on the processors' standard contractual clauses or equivalent safeguards. [Counsel to confirm the transfer mechanism for each processor.]

10. Your rights

Depending on where you live you may have the right to access, correct, delete or export your personal data, to object to or restrict its processing, to withdraw consent, and to complain to a supervisory authority. Most of your data is already in your hands: it lives in your iCloud and in the App's Words, Progress and Settings screens. For anything else, use the support form or write to [contact email]; we answer within 30 days and do not charge for reasonable requests. California residents: we do not sell or share personal information as those terms are defined in the CCPA, and we do not use sensitive personal information to infer characteristics about you.

11. The website, the waitlist and support

The Site sets no cookies and loads no analytics, advertising or third-party scripts. If you join the waitlist we store your email address, the first name and current Finnish level you choose to give, the page you joined from, the date and time, and your browser's user-agent string, which helps us filter automated submissions. We use the list for one purpose: to tell you when a place is ready. We do not add you to a newsletter. To be removed, use the support form, write to [contact email] or reply to the launch email.

If you write to us through the support form we store your email address, the name, topic, device and message you send, the date and time, and your browser's user-agent string. We use them only to answer you, and keep them as described in section 6.

12. Changes to this policy

We will post changes here with a new date at the top. If a change materially affects how we handle your data we will tell you in the App or by email before it takes effect.

13. Contact

B2B SaaS Inc.
[company address]
[contact email]
[If required: name and address of the EU or UK representative, and of the data protection officer.]