Privacy notice

Who is responsible

Email: info@cincomil.com

The short version

• There is no account: no name, no email address, no password.
• The site sets one cookie of its own, and only once it has something of yours to remember: a test result or your reviews.
• Google Analytics 4 and Ahrefs Web Analytics measure how the site is used. Google Analytics sets cookies; Ahrefs does not.
• Messages sent through the contact form are stored so they can be read and answered.

Visiting the site

When your browser asks for a page, the server receives your IP address, the address of the page, the time, the page you came from and your browser’s user-agent string. The web server writes these to an access log. The log is used to keep the site running and secure, to find faults and fend off abuse, and for nothing else. It is not used to build profiles and is not combined with anything below.

The server is hosted by WholeSale Internet, Inc., Kansas City, Missouri, USA.

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

Your learning progress

The first time the site needs to remember something for you (when you finish the vocabulary test, open your progress page or review a word), it sets a cookie called cm. It holds a random id and a signature that stops it being forged. It cannot be read by scripts on the page, and it expires one year after it is set.

Against that id, the site’s database stores:

• your test results: the estimated vocabulary size, its range, the level and the date;
• for each word you review: whether you knew it, how often you have seen and missed it, and when it is next due;
• how many reviews you did each day, which is what the streak counts;
• your daily goal, if you set one.

Nothing links the id to your name, your email address or your IP address. Reading a word list or a word page does not set this cookie.

The cookie is needed to give you what you asked for, so the site does not ask for consent to set it (Art. 6(1)(b) GDPR; § 25(2) no. 2 TDDDG).

Your progress page can show you a recovery code, made when you first ask for it. Entering it on another device makes that device continue from your record. The code is stored with the record. Whoever has it can see and continue your progress, so it is yours to keep private.

Clearing your cookies ends the link between your browser and the record. The record itself is not currently deleted automatically. To have it removed, write to info@cincomil.com with your recovery code, or with the value of your cm cookie. Because the record carries no name, those are the only ways to find it.

The contact form

If you write through the contact form, the site stores the topic you chose, the word you named, your message, the language of the page and the time, plus your email address if you give one. The address is optional and is used only to reply. Messages are not passed on to anyone.

A message is kept for as long as it takes to deal with it and any correction it leads to. You can ask for yours to be deleted at any time.

Legal basis: answering your enquiry (Art. 6(1)(b) and (f) GDPR).

Google Analytics 4

Every page loads Google Analytics 4, a web analytics service provided in the EEA and Switzerland by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and elsewhere by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

It records which pages are viewed and for how long, the page you came from, your device, browser, screen and language, and an approximate location derived from your IP address. According to Google, Google Analytics 4 does not log or store IP addresses. The site also reports one event of its own: the start of a vocabulary test, with the language of the site.

It sets the cookies _ga and _ga_W6110P2VW4, which last up to two years unless your browser shortens that. Google may process the data in the United States. Google LLC participates in the EU–US Data Privacy Framework.

Google Analytics is loaded without asking first. The site relies on its legitimate interest in understanding how it is used, so it can improve the lists and the test (Art. 6(1)(f) GDPR). You can object at any time. Block cookies for cincomil.com, use a content blocker, or install Google’s opt-out browser add-on.

Google’s own terms: Google Privacy Policy.

Ahrefs Web Analytics

Every page also loads Ahrefs Web Analytics, provided by Ahrefs Pte. Ltd., Singapore. It counts page views, the pages visitors come from, browser and device types, and countries. It sets no cookies. Your browser loads its script from analytics.ahrefs.com and reports the page view there, so Ahrefs receives your IP address with those requests.

Legal basis: our legitimate interest in knowing how the site is used (Art. 6(1)(f) GDPR). Details: Ahrefs privacy policy.

Fonts and pronunciation

The fonts are served from cincomil.com itself; no font service is contacted.

The pronunciation button uses your browser’s own speech synthesis, and the site sends the word nowhere. Some browsers use an online voice for this, such as the Google voices in Chrome. If yours does, your browser sends the word to that voice service under your browser provider’s terms.

Where the data is processed

The site is run from the United States and the server is located there. What you send to this site is processed in the United States.

Your rights

You have the right to access the data held about you, to have it corrected or deleted, to restrict its processing, to receive it in a portable format, and to object to processing based on legitimate interests (Art. 15–21 GDPR). Write to the address above.

You also have the right to complain to a data protection supervisory authority, in particular the one where you live.