We do not collect, receive or store your bank card details or any other payment credentials: payment processing and receipt issuance are handled entirely by the acquiring bank (Tinkoff / T-Bank, or Alfa-Bank — depending on the payment method enabled for you).
Data is used solely for:
We do not sell your personal data or share it with third parties for commercial purposes, and we do not use it for advertising or profiling.
We process personal data on the following grounds (Article 6 of Federal Law No. 152-FZ "On Personal Data"):
Data is stored on servers located in the Russian Federation. Passwords are stored in hashed form (bcrypt); authorization tokens are valid for 30 days.
Your IP address is processed transiently at request time solely to determine your country and is not stored in our systems.
Personal data is retained until the account is deleted; deletion is immediate and irreversible.
Upon account deletion, records of completed payments are anonymised — their link to you is removed — and are thereafter kept only in anonymised form for accounting and tax purposes for the period required by law (as a general rule, at least 5 (five) years), ceasing to be your personal data.
To prevent repeated use of the free trial after account deletion, a technical device identifier is retained (with no link to your account or other personal data).
To provide the service we engage the following processors under contracts obliging them to keep data confidential and secure (Article 6 of Federal Law No. 152-FZ). Each processor receives only the minimum data needed for its function:
App builds and updates are delivered via the Expo platform (Expo Application Services); no user personal data is transmitted when delivering updates.
The core processing of your data (authentication, syncing, payment acquiring, transactional email delivery, storage) takes place in the Russian Federation.
We use the Sentry service to collect technical errors of the mobile app. No personal data is sent to Sentry: only anonymised technical information about the failure is processed. Your email, name, flashcard content and payment details are not included in the diagnostics.
As no personal data is transferred outside the Russian Federation, no cross-border transfer of personal data takes place.
The Service is rated 0+ but is not intended for independent registration by children. If a user is under 14, their personal data is processed with the consent of their legal representatives (parents, adoptive parents or guardians).
We do not knowingly collect data from minors beyond the information listed in Section 1.
You have the right to:
For other requests (data copy, consent withdrawal), email support@kioku-flashcards.com — we respond within 30 days. Withdrawing consent results in the cessation of processing and deletion of your account unless another legal basis for processing applies; it does not affect the lawfulness of processing carried out before withdrawal.
You also have the right to lodge a complaint with the competent data protection authority (Roskomnadzor).
If you are located in the European Economic Area or the United Kingdom, the General Data Protection Regulation (GDPR) applies to you. The operator acts as data controller; the legal bases for processing are your consent (Art. 6(1)(a)), performance of a contract (Art. 6(1)(b)) and compliance with legal obligations (Art. 6(1)(c)). You additionally have the right to data portability, the right to object to processing, and the right to lodge a complaint with your local data protection supervisory authority.
If we make significant changes to this Policy, we will notify you through the app upon your next sign-in.
Data controller: Ivan Leveev, sole proprietor (individual entrepreneur), OGRNIP 326774600362592, Tax ID (INN) 772793261189, address: Moscow, Yuzhnobutovskaya St. 147.
For questions about personal data processing: support@kioku-flashcards.com.
The app does not use advertising cookies or third-party analytics trackers. On the mobile app side, only technical error reporting (Sentry) is used, with no personal data.