Privacy Policy

Controller and contact

Yurii Pylyponiuk, based in the Netherlands, is the controller of the personal information described in this policy. Privacy requests can be sent to support@memoraft.io.

If you are in the EEA, UK, or Switzerland, you may also complain to the data protection authority where you live or work. We will add any legally required local representative or data protection contact here if our operations make one necessary.

Information that stays on your device

Decks, cards, study history, progress, streaks, quests, energy state, notification preferences, language, theme, and other settings are stored locally. We do not require an account for the core app.

If you enable usage analytics, limited activity summaries, such as screen visits and study counts, leave your device as described below. This does not upload your decks, card content or full study history. Your analytics consent choice, its date and policy version, and an analytics identifier are stored locally.

Learning data remains until you reset it in the app, uninstall the app, or erase the device. Reset all data keeps your selected language and completed-onboarding preference. Device backups, including Apple or Android backups where enabled, may retain app data according to your platform and device settings.

Information we process

• AI deck creation: images you select, image metadata needed to decode the files, extracted study content, prompts, and generated cards.
• Subscriptions and quotas: a pseudonymous RevenueCat app user identifier, product and entitlement status, purchase history, and a monthly AI-usage counter. If you redeem a complimentary access code, we also process the code to validate it and retain pseudonymous redemption and anti-abuse counters.
• Advertising and consent: consent choices, device or advertising identifiers where permitted, coarse location derived from network information, ad interactions, advertising data, and performance or crash diagnostics.
• Optional iOS and Android usage analytics: app opens or returns from the background, visits to selected app screens, study-session starts and completions, numbers of cards studied and marked learned, mistaken or difficult, event timestamps, app version, platform, analytics-library version, and randomly generated installation/device and session identifiers. These are pseudonymous identifiers, not your name or an advertising identifier.
• Network and security data: IP address, request time, app or device details sent by network protocols, and limited service logs used for security, abuse prevention, and reliability.
• Support: your email address and any information, screenshots, or diagnostic details you choose to send us.

How we use information and our legal bases

• Provide requested app features, AI deck generation, subscriptions, purchase restoration, and support (performance of our contract).
• Protect the app, enforce quotas, prevent abuse, troubleshoot failures, and maintain service reliability (our legitimate interests and, where applicable, legal obligations).
• Serve and measure ads, store consent choices, and access advertising identifiers where required (consent). You may withdraw consent without affecting earlier lawful processing.
• Understand which app screens are useful, whether study sessions are completed, and how usability changes affect repeat use (your separate, optional usage-analytics consent). Declining or withdrawing this consent does not restrict learning or purchased Pro features.
• Comply with tax, consumer-protection, law-enforcement, and other legal requirements (legal obligation).

AI deck creation

Images are uploaded only after you choose the AI deck feature. Our backend processes them in memory and sends them to OpenAI to generate flashcards. We configure the OpenAI Responses API not to store response application state. OpenAI may retain limited abuse-monitoring logs for up to 30 days unless law or an approved zero-data-retention arrangement requires otherwise.

We do not use your images or generated cards to train our own models. OpenAI states that API business data is not used to train its models by default. Do not upload confidential, regulated, or third-party material unless you have permission to process it.

Purchases and subscriptions

Apple processes App Store payments on iOS, and Google processes Google Play payments on Android. RevenueCat helps validate purchases and provide Pro entitlements. We do not receive your full payment-card details. Complimentary access codes, when available, activate an entitlement without starting a paid subscription.

Our backend temporarily caches Pro status for about five minutes and retains a pseudonymous monthly AI-usage counter for about 35 days. Apple, Google, and RevenueCat retain transaction records under their own legal obligations and policies.

Advertising, tracking, and consent

Free users may choose to watch rewarded ads supplied by Google AdMob. The app uses Google User Messaging Platform to request consent where required and provides an in-app Ad Privacy Choices control. On iOS, Apple App Tracking Transparency controls access to the advertising identifier for tracking.

Google Mobile Ads SDK disclosures describe collection of device identifiers, advertising data, app interactions, coarse location derived from IP addresses, crash data, performance data, and other diagnostics. Some data may be linked to a device and used for third-party advertising or measurement. Your available choices depend on region, consent, device settings, platform, and the ad-serving mode. On Android, advertising-identifier controls are also available in your device's privacy or ads settings.

Optional usage analytics and your choices

In enabled iOS or Android builds, we use PostHog Inc. to process limited usage events so we can improve Memoraft's user experience. Analytics is off by default. Collection starts only after you enable Share usage analytics under Settings > Privacy & support and accept the explanation. There is no retrospective collection of activity before consent. Availability depends on your installed build; if the control is absent, this PostHog integration is not enabled in that build. This integration is not enabled on our website.

We do not send flashcard text, deck names or deck identifiers, photos, imported files, AI prompts, purchase receipts, email addresses, or raw error messages to PostHog. We do not use this integration for screen recordings, session replay, automatic tap capture or crash recording. We do not join its identifiers to RevenueCat identifiers or advertising IDs, or use these events to target advertising.

A random identifier lets us recognize the same consenting installation across app launches. This makes the data pseudonymous, not fully anonymous. PostHog also receives your IP address when the device connects to its service. We disable geographic enrichment for these analytics events; this does not prevent the service from receiving your network IP address.

You can withdraw consent at any time using Share usage analytics. This stops future collection and discards queued events on the device. Requests already delivered cannot be recalled. Withdrawal does not affect the lawfulness of earlier processing and does not automatically erase previously received events. This choice is separate from Ad Privacy Choices, Apple's tracking permission on iOS, and device advertising controls on Android.

To request access to or deletion of analytics events, email support@memoraft.io and include the Analytics ID shown under Settings > Privacy & support. Keep a copy before resetting or uninstalling the app, or enabling analytics again after withdrawing consent. We retain the withdrawn ID locally so you can make a request; enabling analytics again creates a new ID. We may not be able to locate earlier events without their identifier. Please do not send your flashcards or store-account password.

Service providers and disclosures

We may also disclose information when required by law, to protect users or the service, or as part of a business reorganization subject to appropriate safeguards. We do not disclose your on-device decks because we do not receive them unless you choose an online feature or send them to support.

• Apple: app distribution, payments, subscription management, and device services.
• Google Play: Android app distribution, payments, subscription management, and related platform services.
• OpenAI: AI image and text processing for deck generation.
• RevenueCat: subscription validation, entitlement management, and purchase analytics.
• PostHog Inc.: optional, consent-based usage analytics for improving the iOS and Android apps in enabled builds, using our EU Cloud project. See https://posthog.com/privacy and https://posthog.com/subprocessors for provider information.
• Google AdMob and User Messaging Platform: rewarded ads, consent management, measurement, fraud prevention, and diagnostics.
• Vercel and Upstash: backend hosting, security logs, and pseudonymous quota or entitlement-cache storage.

Retention

• On-device learning data: until you reset the app, uninstall it, or erase the device or backup.
• Usage-analytics events: retained only for as long as needed to compare app versions, assess repeat use and evaluate usability improvements, subject to applicable deletion requests and legal requirements. Turning analytics off does not itself delete server-side events. Local unsent events are held in a bounded memory queue, not stored on disk, and are discarded when collection stops or the app process ends.
• Local analytics preferences and identifiers: retained until Reset all data, uninstall or device erasure, subject to backups. Turning analytics off retains the previous identifier locally for privacy requests; enabling it again replaces it. Resetting or uninstalling stops local collection but does not request deletion from PostHog.
• AI request data on our backend: held in memory for the request and not intentionally persisted; provider abuse-monitoring logs may remain for up to 30 days.
• Pseudonymous quota counters: about 35 days; Pro-status cache: about five minutes.
• Complimentary access-code attempt counters: about two minutes. Pseudonymous redemption and campaign counters: until the access campaign's fixed expiry plus one day, for no more than 367 days after activation. The submitted code is checked in memory and is not intentionally logged or stored as plaintext by our backend.
• Support messages and security records: only as long as reasonably needed to resolve the request, protect the service, and meet legal requirements.
• Advertising, purchase, and infrastructure records: according to the provider's published retention rules and applicable law.

International transfers

We select PostHog's EU Cloud region for usage-event storage. EU hosting does not mean all processing stays within the EU: authorized support access and subprocessors may process information in other countries under the applicable data-processing and transfer arrangements.

Our providers may process information in the United States and other countries. Where EU, UK, or Swiss transfer rules apply, we rely on adequacy decisions, approved standard contractual clauses, the EU-U.S. Data Privacy Framework where valid and applicable, or another lawful transfer mechanism, together with supplementary safeguards where needed.

Your EEA, UK, and Swiss rights

Depending on the law and circumstances, you may request access, correction, deletion, restriction, portability, or objection; withdraw consent; and complain to a regulator. Email support@memoraft.io. Because most learning data is local, the fastest deletion method is Settings → Account → Reset all data.

We do not make decisions producing legal or similarly significant effects solely through automated processing. AI-generated flashcards may be inaccurate and should be reviewed by you.

United States privacy rights

Residents of California and other covered states may have rights to know, access, correct, delete, or obtain a copy of personal information and to opt out of certain targeted advertising, sale, sharing, or profiling. We do not sell personal information for money. Use of AdMob may be considered sharing or targeted advertising under some state laws.

Use Settings → Privacy & support → Ad Privacy Choices and your device's advertising privacy controls (iOS tracking settings or Android ads settings) to control advertising, or email support@memoraft.io. We honor applicable requests and do not discriminate for exercising privacy rights. Authorized agents may submit requests, but we may verify authority and identity. We do not knowingly use or disclose sensitive personal information for purposes requiring a separate right to limit.

Children

The service is not directed to children under 13. Users in the EEA, UK, or Switzerland must be at least 16 unless a parent or guardian has authorized use where local law permits a lower age. We do not knowingly collect personal information from a child in violation of applicable law.

If you believe a child provided personal information improperly, contact support@memoraft.io so we can investigate and delete it where required.

Security

We use data minimization, encrypted network transport, secret management, access controls, short-lived caches, and pseudonymous identifiers where practical. No service is completely secure, so please avoid uploading information you do not need for the requested feature.

Changes and contact

We may update this policy as the service or law changes. Material changes will be posted here with a new date. Questions and requests: support@memoraft.io.