Privacy Policy

Last updated: 13 October 2026

1. Data controller

Andrea Libutti — sole proprietorship "LIBUTTI ANDREA"
Italian VAT number 18598921007
Registered office: Via Riva Ligure 44 — 00163 Rome (RM), Italy
For privacy matters and to exercise your rights: [email protected].

2. Data we process

• Account: email address, name (optional) and your confirmation that you are at least 14 (some accounts created between mid-August and early September 2026, or with older versions of the app, also hold the date of birth entered at the time). If you sign in with Google we receive your email, name and profile picture; with Apple, your email and, when it provides it, your name. In both cases we store the identifier they assign to you and, for Apple, the token we need to revoke that access when you delete your account.
• Content: the decks, cards, folders and notes you create, and the material you send to AI Studio (text, PDFs, photos, the transcript of a lecture).
• Study: sessions, answers, scores, times and streaks.
• Subscription: active plan, status and dates. Payment is handled by the App Store and Google Play: we never receive your card details.
• Social features, if you use them: friend code, friendships and leaderboard.
• Technical data: device type, operating system, app version and language, IP address in the server logs, and the identifier needed to deliver notifications to you.

Only with your consent to usage statistics: events about how you use the app (for example a generation started or a study session completed), tied to your account identifier. This data is pseudonymous, not anonymous, and does not include the content of your decks. On iOS, also which Apple ad campaign the install came from (campaign, ad group, keyword and country, provided by Apple): PostHog and RevenueCat receive them. We do not collect the device advertising identifier and we do not track your activity across third-party apps or websites. You can decline: the app works exactly the same.

Only with your consent to error reports: app errors, not only crashes, and some performance measurements, tied to your account identifier. Our server reports its own technical errors regardless of this consent, without the content of your requests.

We do not collect your location, your contacts or biometric data.

3. Why we process it, and on what basis

• To provide the service (contract, Art. 6.1.b GDPR): account, syncing decks across devices, studying, subscriptions, notifications if you turn them on, support.
• With your consent (Art. 6.1.a GDPR): sending your material to Google Gemini to generate cards, usage statistics, app error reports. We do not send promotional emails.
• To keep the service secure (legitimate interest, Art. 6.1.f GDPR): server logs, abuse prevention, backups.

Consent to AI processing and to usage statistics can be changed in the app, under Profile → Privacy & Data. Consent to error reports is given the first time you open the app and, for now, cannot be changed from the app afterwards: the choice is stored on your phone. If you want us to delete the reports already received, email [email protected].

4. AI and card generation

When you use AI Studio, the material you send (notes, the text or pages of a PDF, photos, the transcript of a recorded lecture) goes to Google Gemini, in the United States, only to generate your cards. With the type of service we use, Google does not use this content to train its models; it may keep it for a limited period, solely to detect abuse.

What stays on our servers:

• while an analysis is waiting for your choice we keep the text, so you don't have to upload it twice: we delete it when you generate the cards, when you discard the analysis or when you delete your account, and in any case within 4 days;
• a deck may keep a copy of the text it was created from, which is used to generate more cards on the same topics, until you delete the deck;
• for every generation, our technical log keeps the beginning of the text (the first 200 characters), the topics the AI identified in it and the generated cards: for confirmed generations for as long as your account exists, even if you delete the deck; for the others about 30 days;
• the server logs may contain the beginning and the end of an AI response and, if your text looks like it contains instructions aimed at the AI, its first 120 characters: they are overwritten on rotation. When a generation fails, the error message and up to 5,000 characters of the AI service's response stay in a log for as long as your account exists;
• the photos you send are not kept;
• backups keep this data for up to 30 days.

Recorded lectures, where the feature is available: transcription happens on your phone and the audio never leaves it. Only the transcribed text reaches the server, and it is handled like any other notes.

5. Who we share it with

We do not sell your data. To run the service we use these providers:

• OVHcloud (EU): servers and database;
• Backblaze (EU): encrypted backups;
• Cloudflare (global network, including outside the EU): traffic protection and routing, website, email forwarding;
• Google (USA): Gemini to generate cards, Sign in with Google, purchases on Android through Google Play, the mailbox that receives the emails you send us;
• Apple (USA and EU): Sign in with Apple, purchases on iOS through the App Store, delivery of notifications on iOS;
• RevenueCat (USA): subscription status;
• Expo (USA): sending notifications and app updates;
• Brevo (EU): verification, password-reset and sign-in security emails;
• Sentry (EU): error reports;
• PostHog (EU): usage statistics, only with your consent.

For providers outside the European Union, transfers rely on the EU-US Data Privacy Framework or on the European Commission's standard contractual clauses.

Other users: anyone with the link to a deck or folder you shared can read its content, even without an account, until you revoke the share, and anyone who has already imported it keeps their copy, which still shows your name as the author. Anyone who has your friend code can add you as a friend, without you having to accept: your friends see your name, avatar, level, streak, weekly points and your recent activity (the names of the decks you study, scores, milestones, completed challenges).

6. How long we keep it

• For as long as you have an active account.
• If you delete your account: we deactivate it immediately and you have 30 days to change your mind, then we permanently erase the account and what it contains. Only a few technical rows remain, with no name, email or content, tied to your internal identifier (subscription events, use of saved streaks, content rejected by the AI). Backups keep the data for up to 30 more days.
• AI generation logs: the ones holding only numbers (date, cost, amount of text) are anonymised after 90 days and deleted within 12 months; the others (beginning of the text, generated cards, errors) stay for as long as your account exists, as described above.

How to delete your account and what happens next: memoflash.app/en/delete-account.

7. Your rights

You have the right of access, rectification, erasure, restriction, portability and objection, and you can withdraw any consent you have given at any time. From the app you can download a file with your profile, your decks with their cards, your notes, your latest study sessions, your badges and your friends: Profile → Privacy & Data → Export my data. For any other data or request, email [email protected]: we reply within 30 days.

You also have the right to lodge a complaint with the Italian data protection authority (garanteprivacy.it) or with the authority of the country where you live.

8. Minors

MemoFlash is for people aged 14 and over: to use it you must declare that you are. If you believe a child under 14 has given us their data, email [email protected].

9. Cookies

The memoflash.app website uses only technical cookies required for it to work. The app does not use tracking cookies.

10. Changes

When this policy changes we update the date at the top. If the way we process your data changes, we tell you by email.