Privacy Policy

Version: 1.2 Last Updated: September 1, 2026

1. Controller

Data controller under GDPR:

Birgit Pohl Danziger Straße 88 10405 Berlin Germany Email: hello@sparkweaver.app

2. General Information

The use of our Sparkweaver app involves the processing of personal data. This Privacy Policy informs you about what data we collect, for what purpose, and on what legal basis.

We take the protection of your personal data very seriously and handle your personal data confidentially and in accordance with legal data protection regulations (GDPR) and this Privacy Policy.

3. Data We Collect

3.1 Required Data (necessary for using the app)

Email Address and Authentication Data

• Purpose: Registration, login, account management
• Legal basis: Art. 6(1)(b) GDPR (contract performance)
• Retention period: Until account deletion

Learning Content (Flashcards, Learning Progress)

• Purpose: Providing learning features, synchronization across devices
• Legal basis: Art. 6(1)(b) GDPR (contract performance)
• Retention period: Until deleted by user or account deletion

Usage Data (Study Sessions, Interactions)

• Purpose: Personalizing learning experience, progress tracking
• Legal basis: Art. 6(1)(b) GDPR (contract performance)
• Retention period: Until account deletion

3.2 Technical Data

Device Information

• Operating system and version
• App version
• Device model
• Purpose: Bug fixing, performance optimization
• Legal basis: Art. 6(1)(f) GDPR (legitimate interest)

Crash Reports and Diagnostic Logs

• Purpose: Improving app stability
• Legal basis: Art. 6(1)(f) GDPR (legitimate interest)
• Retention period: 90 days

4. Data Sharing with Third Parties

Your account data, learning content and learning progress are stored on our own servers in the European Union. We do not use a database or hosting provider that would receive this data as a processor.

We only share your data with third parties in the following cases:

4.1 Service Providers (Data Processors)

Mistral AI (AI Features)

• Provider: Mistral AI SAS, France
• Purpose: AI-powered flashcard generation, evaluating your answers, chat responses
• Processed data: Learning content you input (no email address)
• Data transfer: None outside the EU
• Privacy: https://mistral.ai/terms#privacy-policy
• Important: Your data is not used to train models

Google Play Services (Android)

• Provider: Google LLC, USA
• Purpose: App distribution, in-app purchases, crash reports
• Privacy: https://policies.google.com/privacy

Apple App Store (iOS)

• Provider: Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland
• Purpose: App distribution, in-app purchases, crash reports
• Privacy: https://www.apple.com/legal/privacy/

4.2 Payment Processing

Depending on which store you obtained the app from, a subscription is billed either by Google or by Apple. In both cases we receive only the confirmation of a successful purchase.

Google Play Billing (for In-App Subscriptions)

• Provider: Google LLC
• Processed data: Transaction data (no credit card details stored by us)
• Purpose: Processing subscription payments
• We only receive confirmation of successful purchases, not payment details

Apple In-App Purchase (for In-App Subscriptions)

• Provider: Apple Distribution International Ltd., Ireland
• Processed data: Transaction data (no payment details stored by us)
• Purpose: Processing subscription payments
• You may choose Apple Pay as your payment method inside Apple's purchase flow. We receive neither your payment details nor which method you used.

5. Data Transfer to Third Countries

Your account data, learning content and learning progress stay within the European Union. They are stored on our own servers and processed by an AI provider based in the EU.

The exceptions concern the store you obtained the app from.

If you obtained the app from the Google Play Store, Google LLC in the USA receives installation and subscription data and, if you have enabled diagnostics on your device, crash reports.

If you obtained the app from the Apple App Store, Apple Distribution International Ltd. in Ireland is your contracting party for obtaining the app and for purchases inside it. Apple processes installation and subscription data, and diagnostic data if you have enabled sharing on your device, and may transfer that data to Apple Inc. in the USA.

Both transfers are based on EU Standard Contractual Clauses (Art. 46 GDPR). You can find the details in the Google and Apple privacy policies linked above.

6. Your Rights

Under GDPR, you have the following rights:

6.1 Right to Access (Art. 15 GDPR)

You can request information about your stored data at any time.

6.2 Right to Rectification (Art. 16 GDPR)

You can request correction of inaccurate data.

6.3 Right to Erasure (Art. 17 GDPR)

You can request deletion of your data ("right to be forgotten").

• By email: Request to hello@sparkweaver.app

6.4 Right to Restriction (Art. 18 GDPR)

You can request restriction of processing.

6.5 Right to Data Portability (Art. 20 GDPR)

You can receive your data in a structured, machine-readable format.

• By email: Request to hello@sparkweaver.app

6.6 Right to Object (Art. 21 GDPR)

You can object to the processing of your data for reasons arising from your particular situation.

6.7 Withdrawal of Consent (Art. 7(3) GDPR)

If processing is based on your consent, you can withdraw it at any time.

6.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority:

Competent authority for us: Berliner Beauftragte für Datenschutz und Informationsfreiheit Alt-Moabit 59-61 10555 Berlin, Germany Website: https://www.datenschutz-berlin.de

You may also lodge a complaint with the supervisory authority of the state you live in, or of the place where you believe the infringement occurred.

7. Data Security

We implement technical and organizational security measures:

• ✅ Encrypted data transmission (TLS/SSL)
• ✅ Encrypted stored data
• ✅ Access restrictions and authentication
• ✅ Regular security updates
• ✅ Secure server infrastructure

8. Retention Period

We store your data only as long as:

• It is necessary for the purposes for which it was collected
• Legal retention periods exist
• You have consented to the storage

After Account Deletion:

• Immediate deletion of all personal data
• Exception: legal retention obligations (e.g., invoice data for tax purposes: 10 years)

9. Cookies and Tracking

Our app does not use cookies or tracking for advertising purposes.

We only collect technically necessary data to provide functionality.

10. Minors

Our app is intended for users aged 13 and above. We do not knowingly collect data from children under 13 without parental consent.

11. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in legal requirements or app features.

The current version is always available on our website.

You will be informed of significant changes by email or app notification.

12. Contact

For questions about data protection or to exercise your rights, please contact:

Email: hello@sparkweaver.app Response time: Within 30 days