Privacy Policy

Flashside is an app and website built and operated by CQUELLE GmbH, Erdkampsweg 70a, 22335 Hamburg, Germany ("we"). This policy explains what personal data we process when you use Flashside, why, and what your rights are.

Flashside is offline-first: your collections, cards and study history live on your device. We only receive data when you choose to create an account, synchronise, share a collection, send feedback, subscribe to or use Flashside Plus, or when the app reports an error, or as described under Usage statistics and App version and platform.

Controller

CQUELLE GmbH, Erdkampsweg 70a, 22335 Hamburg, Germany. Managing director: Eugen Yamamoto. Email: welcome@cquelle.com.

What we process and why

Account data

If you create an account we process your email address and a hashed password in order to provide the account, synchronisation and sharing (Art. 6(1)(b) GDPR, performance of a contract). You can delete your account at any time from the app or the website; this removes your account data and the collections stored with it.

Sign in with Apple and Sign in with Google

If you sign in with Apple or Google, the provider sends us a signed token with the email address of your account there, whether that address is verified, and the provider's identifier for you. On your first sign-in with Apple your name may also be passed on, and a Google token may contain your name; we do not store your name. We use the verified email address to create your Flashside account or to link the sign-in to an existing account with the same address, and we keep the provider's identifier linked to your account so that the same button signs you in again. When you sign in with Apple, we may also keep a token Apple issues for that sign-in. We do this to provide the account (Art. 6(1)(b) GDPR). The link and the token are deleted with your account.

Content you synchronise or share

Collections, cards, pictures and audio clips you synchronise with your account or share with others are stored on our servers so that they can be delivered to your other devices and to the people you share them with (Art. 6(1)(b) GDPR). Content you keep only on your device never reaches us. If your device's own backup is switched on, it can include the app's stored data, such as this content and your study history: on Android in the backup of your Google account, on iOS in your iCloud backup. That backup belongs to your account with Google or Apple, and you can switch it off in your device's settings; we cannot read it.

When a teacher shares a collection with a class and you switch on sharing your progress with the teacher at the download, the teacher sees the first name you type, how many cards of your copy you have started and have due, and the day you last studied it, never the time. They see no email address and nothing else about your studying. Switching it off erases the first name and removes you from the list (Art. 6(1)(a) GDPR, your consent). Without the switch, your download counts only.

Anonymous device identifier

The app creates a random identifier on installation so that shared collections and feedback can be attributed to a device without an account. It is not linked to your name or email address unless you sign in (Art. 6(1)(f) GDPR, our legitimate interest in operating the Service without requiring an account).

When you first open flashside.app we store once, together with the anonymous device identifier, the page you arrived on, the name of the website that linked to us and any campaign tags in the link, so we can tell which sources bring learners. No IP address and no cookie are stored for this. The tags are cleared after 90 days unless the device is linked to an account.

Usage statistics

The app and the website report to us, together with the anonymous device identifier, that they were opened on a given day; the website does so only while you are signed in. The app also reports that you started studying, that you started an extra session of new cards beyond today's limit (the "Learn more cards" button), that it asked the store to show its rating prompt, that this request was refused or not available, and that you tapped "Rate Flashside".

We keep one row per device and day with these facts and how often they happened, together with the platform and version, and use them to see how many devices use the Service and which parts of it work (Art. 6(1)(f) GDPR, our legitimate interest in improving the Service). If you were signed in for any of these reports on that day, the row is linked to your account, and it stays linked after you sign out. The stores do not tell us whether you left a rating. The rows are deleted after 90 days, and a row linked to your account at once when you delete your account.

App version and platform

The app tells our servers which platform (iOS, Android or web) and which version it is running, together with the date it was last active. We use this to keep older versions working, to decide which versions we still need to support, and to see which platforms our learners use (Art. 6(1)(f) GDPR, our legitimate interest in maintaining the Service). We look at these figures and the usage statistics in aggregate. Our admin tool also shows, for a single account or anonymous device, the platform and version it last used and when, so we can answer feedback and look into problems that affect one version.

Consent records

For a signed-in account we record which version of the Terms of Service and this Privacy Policy you accepted and when, and your choice about marketing emails together with the date of the choice and the client it was made on. We keep these records to be able to demonstrate that consent was given (Art. 6(1)(c) and Art. 7(1) GDPR).

Emails

Service emails - registration confirmation, password reset, security notices and notice of material changes to the terms or this policy - are sent to your account's email address because they are needed to operate the Service (Art. 6(1)(b) GDPR).

Marketing emails about new features, learning tips and offers are sent only with your consent (Art. 6(1)(a) GDPR). You give or withhold it when you register or sign in, and you can change your mind at any time in the app under Account → Email preferences, in your profile on the website, or through the unsubscribe link in every marketing email. Withdrawing consent does not affect the lawfulness of processing before the withdrawal, and it never affects your use of Flashside. Marketing emails carry a small tracking image and individually coded links, so we learn whether a mail was opened and which link was clicked; we keep the event and the time, never your IP address or browser, and it stops when you withdraw consent.

Feedback

Feedback you send from the app is stored together with your account or device identifier so that we can act on it (Art. 6(1)(f) GDPR).

When you send us feedback from the app or the website, the text of your message is analysed by an AI model (Amazon Bedrock, hosted in the EU) so we can see whether the feature you ask about already exists and prepare an answer. The message stays linked to your account or anonymous device identifier so the answer can reach you. It is not used to train the model.

Feedback you send us, including any pictures or files you attach, is also forwarded to our internal team chat (Slack, hosted in the USA under the EU-US Data Privacy Framework) so we can answer it quickly. Only your messages, their attachments and the app's language and version are forwarded, never your account or e-mail address. Attachments are deleted together with your feedback or your account. If you allow notifications, the app registers a push token for your device with us so we can tell you when we have answered your feedback. If you are signed in, the app also registers this token without asking for that permission, so we can send your other devices a silent signal, with no content, telling them to fetch your latest changes; it shows nothing on your screen. The token is linked to your account or anonymous device identifier, is removed when you sign out or the device stops responding, and is used for nothing else.

Flashside Plus subscription

When you subscribe to Flashside Plus, the app sends us the store's record of your purchase, and we confirm it with the app store you subscribed through. That store also tells us when the subscription renews, changes or ends. We store with your account the platform, the product, the store's transaction identifier, when the subscription ends, whether it will renew, and whether it is a test purchase, so that Plus works wherever you are signed in (Art. 6(1)(b) GDPR). We do not receive your payment details; the store processes your purchase under its own privacy policy.

Plus features and AI processing

When you use a Plus feature, including the free monthly uses, we send the content the feature needs to our service providers: for translations, card suggestions, explanations and quizzes, the text of the cards concerned; for the weekly coach note, a summary of your last week of study (figures such as reviews and minutes studied, the titles of your collections and the fronts of cards you keep missing); for cards or a quiz from a photo, the photo you choose; and for read-aloud with natural-sounding voices, the text to be spoken. This content is processed by Amazon Web Services (AWS), using Amazon Bedrock for the AI model and Amazon Polly for the voices, in AWS data centres in the European Union. We do not send your name, email address or account identifier with it. We process this content to provide the feature you asked for (Art. 6(1)(b) GDPR).

So that the same content is not processed twice, we keep the results, for example a translation, a quiz, the cards made from a photo or an audio clip, in a cache on our servers. The cache identifies a result by a fingerprint of the content and does not record who asked for it. A photo is not kept once the cards or the quiz have been made from it. For each account we count, per month, how many Plus requests of each kind were made, so that we can apply the free monthly uses and the fair-use limits (Art. 6(1)(b) GDPR) and understand the cost of Plus (Art. 6(1)(f) GDPR, our legitimate interest in running Plus at a sustainable cost).

Log data

When an error occurs in the app, or when our servers handle a request, we may collect log data such as your device's IP address, device name, operating system version, the configuration of the app at the time, and the time and date of the request. We use it to diagnose faults and to keep the Service secure (Art. 6(1)(f) GDPR).

Service providers

We use hosting and email delivery providers and, for Flashside Plus, AI and text-to-speech providers, acting on our instructions and under data processing agreements. They receive only the data needed to perform their task and may not use it for any other purpose. Where a provider processes data outside the European Economic Area, the transfer is covered by the European Commission's standard contractual clauses or an adequacy decision.

To deliver push notifications and the silent sync signal, we pass your device's push token and a short message with no content from your cards to Apple Push Notification service on iOS or Google Firebase Cloud Messaging on Android.

reCAPTCHA

The sign-in and registration pages on the website use Google reCAPTCHA v3 to tell a person apart from an automated script. This keeps someone else from signing your address up and stops our sign-up mail being used to reach people who never asked for it (Art. 6(1)(f) GDPR). When you open one of those two pages, Google receives your IP address and information about your browser and how you interact with the page, and returns a score we use only to decide whether to accept the submission. reCAPTCHA is loaded on no other page, and not at all in the mobile app. What Google does with that data is described in the Google Privacy Policy and the Google Terms of Service.

Retention

• Account data and synchronised content: until you delete your account.
• Consent records: for as long as we need to be able to demonstrate that consent was given, and no longer than three years after the account is deleted or the consent is withdrawn.
• App version and platform: for as long as the device record exists.
• Usage statistics per device and day: 90 days, and at once when you delete your account if the row is linked to it.
• Links to a sign-in provider: until you delete your account.
• Plus subscription details: until you delete your account.
• Monthly Plus usage counts: 24 months after the end of the month they belong to, also when you delete your account in the meantime; after a deletion they are linked only to an internal identifier, not to your name or email address. We use them to apply the fair-use limits and to understand the cost of Plus.
• Cached Plus results: not linked to any account; deleted 12 months after they were last used.
• Weekly coach notes: linked to your account; deleted 90 days after they were written, and at once when you delete your account.
• Log data: at most 90 days, unless needed to investigate a security incident.

Security

We value your trust in providing us your personal data and use commercially reasonable technical and organisational measures to protect it. Remember that no method of transmission over the internet, or method of electronic storage, is completely secure, and we cannot guarantee absolute security.

Links to other sites

Flashside may contain links to other sites. If you follow a third-party link, you will be directed to that site. These external sites are not operated by us, so we advise you to review their privacy policies. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children's privacy

Flashside accounts are not intended for anyone under the age of 16. We do not knowingly collect personal data from children under 16. If we learn that a child under 16 has provided us with personal data, we delete it from our servers. If you are a parent or guardian and are aware that your child has provided us with personal data, please contact us.

Your rights

You have the right to access the personal data we hold about you, to have it rectified or erased, to restrict its processing, to receive it in a portable format, and to object to processing based on our legitimate interests. Where processing is based on consent, you may withdraw it at any time. To exercise these rights, contact us at welcome@cquelle.com. You also have the right to lodge a complaint with a supervisory authority; the authority responsible for us is the Hamburg Commissioner for Data Protection and Freedom of Information (Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit).

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When a change is material we announce it in the app and ask signed-in users to review and accept the new version. The current version is always available in the app and at flashside.app/privacy-policy.

Contact us

If you have any questions or suggestions about this Privacy Policy, do not hesitate to contact us.

CQUELLE GmbH
Erdkampsweg 70a
22335 Hamburg
Germany

Email: welcome@cquelle.com
Website: www.cquelle.com

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