Spaced Cards Privacy Policy

This policy explains how we collect and handle your information when using Spaced Cards.

Effective Date: March 22, 2025

1. Information We Collect and Legal Bases for Processing

• Account Information: Name and email address. We process this data based on contractual necessity to provide you with an account and access to the App.
• Usage Data: Feature usage, survey answers, and performance metrics. We process this data based on our legitimate interest to improve the App and enhance user experience.
• Device Information: Device type, operating system, app version. We process this data based on our legitimate interest to ensure compatibility and optimize performance.
• Payment Information: Processed by Superwall (third-party). We process this data based on contractual necessity to manage subscriptions and provide paid features.
• User Content: Decks & Flashcards you create. We process this data based on contractual necessity to provide the core functionality of the App.
• Technical Data: IP address. We process this data based on our legitimate interest to maintain security and prevent abuse.
• AI Feature Data: Inputs and generated content when using AI features (we do NOT keep or save the inputs). We process this data based on your contractual necessity when you choose to use these features.
• Authentication Data: When using "Sign in with Apple" or "Google Sign-in," we receive basic profile information from these services (your name and email address, although Apple's email address could be anonymized). We process this data based on your consent (when signing in) and contractual necessity to authenticate your identity.

2. How We Use Your Information

We use your information to:

• Provide and improve the App
• Process payments and manage subscriptions
• Communicate about updates and support
• Comply with legal requirements
• Analyze usage trends to enhance user experience
• Power AI features through Google's Gemini AI

3. Who We Share Your Information With

We do not sell or rent your personal information to third parties. However, we may share information in the following cases:

• Service Providers:
  • Posthog: Analytics (EU-hosted)
  • Supabase: Database services (EU-hosted)
  • Sentry: Error tracking (EU-hosted)
  • PowerSync: Cross-device syncing (EU-hosted)
  • Superwall: Payment processing (EU-hosted)
  • UpStash: Rate limiting (EU-hosted)
  • Apple: For "Sign in with Apple" authentication
  • Google: For "Google Sign-In" authentication and Gemini AI features
• Legal Requirements: When required by law
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

4. Your Rights

You have the right to:

• Access your personal information
• Correct inaccurate information
• Delete your data
• Restrict processing
• Object to processing
• Data portability

California residents have additional rights under applicable law.

5. Data Security

We use encryption and other security measures to protect your data, though no method is 100% secure.

6. Data Retention

We keep your data as long as needed to provide services or as required by law. When you delete your account, we delete your personal information except:

• where legally required to retain it
• analytics data (which you can request to be deleted by contacting us)

7. Children's Privacy

Our App is not intended for children under 13, and we do not knowingly collect data from them.

8. Updates to This Policy

We may update this policy and will notify you of significant changes through the App or website.

9. Contact Us

Questions or concerns? Contact us at [email protected].

Last Updated: March 22, 2025

CCPA Compliance for California Residents

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA). These rights include:

• The right to know what personal information we collect, use, share, or sell about you.
• The right to request that we delete any of your personal information that we have collected from you.
• The right to opt-out of the sale of your personal information (though we do not sell personal information).

To exercise these rights, please contact us at [email protected] or by mail at [address].

We do not sell your personal information to third parties for monetary consideration.

We may share your personal information with our service providers who act as data processors on our behalf, as described in Section 3 above.

Categories of Personal Information Collected

• Identifiers (name, email address)
• Customer records (usage information)
• Device information
• Internet or other similar network activity information
• Geolocation data (from IP address)
• Audio, electronic, visual, or similar information (if applicable)
• Professional or employment-related information (if applicable)
• Education information (if applicable)
• Inferences drawn from any of the above to create a profile or for any other purpose

We collect this information for the purposes described in Section 2 above.

Exercising Your CCPA Rights

To exercise your rights under the CCPA, please submit a request to [email protected] with the subject line "CCPA Request." In your request, please specify which right you are exercising and provide sufficient information to identify yourself and the personal information you are requesting.

We will respond to your request within the timeframes specified by the CCPA, typically within 45 days of receipt of the request.

If you have any questions or need assistance with your request, please contact us at [email protected].

No Discriminatory Practices

We do not discriminate against you for exercising any of your rights under the CCPA. This means we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Opt-Out of Sale

We do not sell your personal information to third parties. Therefore, you do not have the right to opt-out of the sale of your personal information under the CCPA.

Important Note on AI Features

When using AI features in the App, please be aware that your input and the generated content are processed by Google's Gemini AI. Google acts as a separate data controller for this processing. We recommend that you do not input any sensitive or confidential information into the AI features, as this information may be used by Google to improve their AI models.

UpStash for Rate Limiting

We use UpStash to manage rate limiting, which helps prevent abuse of our services. For this purpose, UpStash may collect your IP address and other technical information to track and limit the number of requests from your device. Please refer to UpStash's privacy policy for more information on their data practices (UpStash Privacy).

Do Not Track

Our App does not currently recognize or respond to "Do Not Track" signals from mobile devices. However, we respect your privacy preferences and provide options to manage tracking through your device settings.