Privacy Policy

Last Updated: April 14, 2025

Cognifly Ltd (collectively, “Company”, "we", "us" and/or "our") operates Anki Flashcards: Study Smarter mobile application (collectively, the “application”, “app”) and other related services (collectively, the “Services”).

We are committed to protecting your privacy. This Privacy Policy describes how we collect, store, use and distribute information through our Services in terms of the General Data Protection Regulation (GDPR).

Please read this Privacy Policy carefully. By starting to use our Services, you consent to this Privacy Policy.

We care about the protection and confidentiality of your data. We therefore only process your data to the extent that:

• It is necessary to provide the application Services you are requesting,
• You have given your consent to the processing, or
• We are otherwise authorized to do so under the data protection laws.

By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you at this moment consent that we will collect, use, and share your information in the following ways.

Remember that your use of application Services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in Terms of Use.

If you have any questions, suggestions or comments about privacy or protection and confidentiality of your data, please contact us at: ankidev@proton.me

1. Personal data we collect about you

Here we list all the types of personal information we collect and store throughout your experience with application. Some of this information may be shared with service providers who help us deliver your experience with application. The personal data that we may collect about you broadly falls into the following categories:

Data Collection for Functional Purposes

We request and process specific personal information when utilizing the app. This information is essential to ensure the app's optimal functionality and the delivery of requested Services. Without such information, the complete functionality of the App and the provision of desired Services may be unattainable. The subsequent categories of data may be subject to processing:

• Activity Information. This encompasses data directly associated with your utilization of the app. Upon configuring the relevant settings on your device, we may gain technical access to your camera or Photos to scrutinize the pictures you capture or upload through the app. It should be noted that we refrain from gathering, storing, or utilizing the files present in your Photos unless you actively upload such files to the app.
• Information Linked to Your app Account. If you choose to register within the app by connecting your account to your Apple ID, Google, or Facebook account, certain categories of data may undergo processing. These include details regarding your chosen method of registration within the app (such as signing in with Apple/Google/Facebook) and the email address linked to your account.
• User-Uploaded Content. Content that users upload to the app, whether for basic or extended functions, including the identification feature, is subject to our Terms of Use in addition to the present Privacy Policy. Please be aware that uploading or submitting any User Content containing personal data, or protected personal data of other individuals (such as names, addresses, phone numbers, email addresses, etc.), is strictly prohibited.
• Contact Information. Information such as your name, email address, and any additional content included in your email, which you voluntarily provide when contacting us via email or support form, is collected, stored, and processed using our cloud storage provider. We employ this information to effectively address your inquiries, fulfill your requests, send you communications upon your request, and execute the Services you've asked for.

Information That Is Processed Automatically

When you download and access our app, we may collect certain information automatically from your device. In some countries, this information may be considered personal data under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, other internal identifiers (integers), browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our app.

Collecting this information enables us to better understand the users of our app, where they come from, and what content or functionality in our app is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our app to our users.

Information that we obtain from third party sources

From time to time, we may receive personal data about you from third party sources (including Apple, Google, and Facebook), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal data to us.

The types of information we collect from third parties include name, email address, external tokens/ids and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you.

Payment Information

We utilize Apple and Google to process all financial transactions and Palina Baltsevich is not provided with any personal data related to your transaction.

2. Legal basis for processing personal data

Our primary goal is to continuously enhance our pp and offer novel experiences to our users. In pursuit of this mission, we utilize your information for the following purposes:

• Service Availability: We employ functional information and automatically processed data to ensure the delivery of all requested Services.
• App Improvement and Monitoring: Utilizing automatically processed data, we strive to understand user behavior, identify trends, detect potential technical issues or outages, and operate, safeguard, enhance, and optimize our app.
• Personalized Advertising and Content: We may use automatically processed information for marketing objectives, such as displaying ads tailored to your interests. This involves presenting personalized content, which could include online advertisements or other marketing materials.
• Communication: Your information is used to engage with you via newsletters, sending marketing notifications, gathering feedback about your app experience, and informing you about our policies and terms. Additionally, we utilize your data to respond promptly when you reach out to us.
• Fraud Prevention and Law Enforcement: Upholding a spam-free and secure environment within our app is paramount. We may utilize your information to prevent, detect, and investigate instances of fraud, security breaches, potentially prohibited or illegal activities, safeguard our trademarks, and enforce our Terms of Use.

Should new purposes arise for processing your personal data, we will inform you of any such changes by updating this Privacy Policy accordingly before commencing the processing of information for those additional purposes.

3. With whom we share your personal information

We may de-identify or anonymize your information so that you are not individually identified, and provide that information to our partners.

We also may combine your de-identified information with that of other users to create aggregate de-identified data that may be disclosed to third parties who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal experience. For example, we may use information gathered to create a composite profile of all the users of the Services to understand community needs, to design appropriate features and activities. However, we never disclose aggregate information to a partner in a manner that would identify you personally, as an individual.

Personal Data is collected for the following purposes and using the following Services:

We routinely share personal data with service providers we use to help us run our business or provide the Services or functionalities in the app, including:

• Apple, Google;
• RevenueCat for analytics Services;
• BugSnag and Sentry for support Services;
• Firebase Analytics, Apple Search Ads Attribution for the purposes of marketing performance measurements, conversion tracking and retargeting.

We only allow our group companies and service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide Services to us and to you.

We or the third parties mentioned above may occasionally also need to share your personal data with:

• external auditors, e.g. in relation to the audit of our accounts —the recipient of the information will be bound by confidentiality obligations
• professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
• other parties in connection with a significant corporate transaction or restructuring, including a potential or actual merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

4. How we secure and protect your information

We use a variety of industry-standard security technologies and procedures to help protect your data from unauthorized access, use, or disclosure.

• All transmitted data are encrypted during transmission. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All stored data are maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords.
• While we use reasonable commercial efforts to protect the data, no technology, data transmission or system can be guaranteed to be 100% secure. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your data, we will notify you as soon as we spot the issue.

5. Where we store your data

Our Services are operated in the United States of America. If you are located in another jurisdiction, please be aware that the information you provide to us may be transferred to, stored and processed in the U.S.A. By using our Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the U.S.A., a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

6. Data retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. Your data protection rights

As an application member, you have the following data protection rights, depending on the circumstances of the specific case:

• Disclosure

  To receive information about your personal data processed by us and to request access to your personal data and/or copies of these data. This includes information on the purpose of use, the category of data used, its recipients and authorized persons and, if possible, the planned duration of data storage or, if this is not possible, the criteria for determining this duration.

• Correction, deletion or limitation of processing

  To request the correction, deletion or limitation of the processing of your personal data, e.g. by sending us an email. If (i) the data are incomplete or incorrect, (ii) they are no longer necessary for the purposes for which they were collected, (iii) the consent on which the processing was based has been revoked, or (iv) you have successfully exercised your right to object to data processing; in cases where data is processed by third parties, we will forward your requests for correction, deletion or limitation of the processing to these third parties, unless this proves impossible or involves a disproportionate effort.

• Opposition to the processing

  To object to the processing for reasons arising from your particular situation.

• Refusal and revocation of consent

  To refuse your consent or – without affecting the legality of data processing prior to the revocation – to revoke your consent to the processing of your personal data at any time.

• Automatic decisions

  To require that you be subject to a decision based exclusively on automated processing only in the exceptional cases provided by law, if that decision has legal effect against you or significantly affects you in a similar manner; should such an automated decision take place in exceptional cases, you have the right to obtain information on the logic involved and the scope of the intended effects.

• Right of appeal

  Communicate with and, if necessary, complain to the data protection supervisory authority.

8. How to delete your data

You can delete all your account information by deleting your account in the app. To delete your account, click on the three dots icon in the top right corner, then click “Other”, select “Delete account”, and follow the instructions.

9. Children’s Privacy

We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us, and we will endeavor to delete that information from our databases.

10. Changes to Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.