This privacy policy applies to the FlashCards app for iOS (App ID: app.flash.card.learning), together with any related services operated by Dzmitry Dzemidziuk (collectively, the "Application"). Dzmitry Dzemidziuk is hereby referred to as the "Service Provider".

The following describes the categories of data processed by the Application:

• Flashcard content (words, translations, categories) — created by you and stored locally on your device using an on-device database. This data is never transmitted to the Service Provider's servers.
• On-device translation — when you use the translation feature, your text is processed entirely on your device using Google ML Kit Translation. Your words and translations are not sent to any remote server. Language model files are downloaded from Google servers once per language pair and then used locally.
• Purchases and subscription status — processed by RevenueCat on your behalf to manage your subscription.
• Analytics and crash reports — collected via Google Analytics for Firebase and Firebase Crashlytics to help the Service Provider improve the Application.
• Device and usage data — including device IP address, pages visited within the Application, time and date of visits, time spent in the Application, and mobile operating system.

The Application collects information when you download and use it. This information may include:

• Your device's Internet Protocol address
• The pages of the Application that you visit, the time and date of your visit, the time spent on those pages
• The time spent on the Application
• The mobile operating system you use

The Application or its third-party SDKs may use cookies, SDKs, pixels, and similar technologies to support functionality, analytics, or service delivery. Where required by applicable law, the Service Provider will obtain consent before using non-essential tracking technologies.

This Application does not track you across other companies' apps or websites and does not use the Advertising Identifier (IDFA). No App Tracking Transparency prompt is shown because the Application does not engage in cross-app tracking as defined by Apple's App Store guidelines.

If you are located in the European Economic Area (EEA), the Service Provider processes your personal data on the following legal bases:

• Contract performance — processing necessary to provide the Application's features and subscription services.
• Legitimate interests — processing for crash reporting and analytics to improve Application quality, where these interests are not overridden by your rights.
• Consent — where you have affirmatively opted in to a specific feature or processing activity. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
• Legal obligation — where processing is necessary to comply with applicable law.

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of access — to obtain a copy of your personal data
• Right to rectification — to correct inaccurate data
• Right to erasure — to request deletion of your personal data
• Right to restriction of processing
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object to processing based on legitimate interests

To exercise these rights, or to withdraw consent where processing is based on consent, contact the Service Provider at dimadyuk.dev@gmail.com.

If you are a California resident, you have the right to know what personal information is collected, the right to delete personal information, the right to opt out of the sale or sharing of personal information, and the right to non-discrimination for exercising these rights. To exercise your CCPA/CPRA rights, contact the Service Provider at dimadyuk.dev@gmail.com.

The Service Provider may use the information you provide to send important information, required notices, and, where permitted by law, marketing communications.

Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application. The Service Provider may share your information with third parties in the ways described in this privacy statement.

Please note that the Application utilizes third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:

• Google Analytics for Firebase
• Firebase Crashlytics
• Google ML Kit (on-device translation)
• RevenueCat

The Service Provider or its third-party service providers may transfer personal data to countries outside your country of residence, including outside the European Economic Area (EEA). Where applicable law requires safeguards for international transfers, the Service Provider will use appropriate mechanisms:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions or other legally recognized transfer mechanisms
• Your consent, where required and legally permitted

You can stop further collection of information from your mobile device by uninstalling the Application. Uninstalling will stop the Application from collecting data from your device, but it does not automatically delete information that has already been transmitted to the Service Provider or to third parties.

To request deletion of your personal data, to withdraw consent, or to exercise any of your rights, contact the Service Provider at dimadyuk.dev@gmail.com.

The Service Provider retains personal data based on its necessity for the stated purposes:

• User Provided Data: Retained for the duration of your use of the Application plus 12 months thereafter, unless longer retention is required by law
• Automatically Collected Data: Retained for up to 24 months from collection, unless longer retention is required for legal compliance
• Aggregated and Anonymized Data: Retained indefinitely as it no longer identifies you
• Data required for legal compliance: Retained as long as required by applicable law

You may request deletion of your personal data, subject to any legal obligation to retain it. Contact the Service Provider at dimadyuk.dev@gmail.com.

The Application is not intended for children under 16 years of age, or such higher age as required by applicable law. The Service Provider does not knowingly solicit data from or market the Application to children. If you are a parent or guardian and you are aware that your child has provided the Service Provider with personal information, please contact dimadyuk.dev@gmail.com so that the necessary actions can be taken.

The Service Provider is concerned about safeguarding the confidentiality of your information. The Service Provider provides physical, electronic, and procedural safeguards to protect information the Service Provider processes and maintains.

If a data breach occurs that affects your personal data, the Service Provider will notify you in accordance with applicable legal requirements, including, where required, providing information about the nature of the breach and the steps being taken to address it.

The Service Provider may update this Privacy Policy from time to time. The Service Provider will notify you of material changes by posting the updated Privacy Policy with a new effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect.

Previous versions of this Privacy Policy will be maintained and made available upon request by contacting the Service Provider at dimadyuk.dev@gmail.com.

This privacy policy is effective as of 2026-06-09

Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action. You may withdraw consent at any time without affecting processing carried out before withdrawal. Processing based on other lawful bases is carried out as described above.

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at dimadyuk.dev@gmail.com.