Privacy Policy

Last updated: 2026-11-08

This Privacy Policy explains how WunderCards (the “Application” or “App”) processes personal data, and your rights under the EU General Data Protection Regulation (“GDPR”) and other applicable laws. The Application is intended for personal, informal learning and not for professional, certified, medical, legal, financial, or otherwise regulated use.

The Application is a flashcard and vocabulary-learning tool with optional AI-powered features, account functionality, cross-device synchronization, subscriptions, widgets, on-device reminders, crash reporting, and analytics.

1. Controller

We have not appointed a Data Protection Officer, as we are not legally required to do so. For all privacy matters, contact us at the email above.

2. Plain-Language Summary

This summary is for convenience only; the full policy governs.

• Your flashcards, decks, and study progress are stored on your device and, if you use an account or sync, on our backend in the European Union (Supabase, Frankfurt).
• If you use AI features, the words, text, short audio recordings, or photos you submit are sent to AI providers in the United States (Google Gemini, Anthropic Claude) to generate the result. We do not store your short audio recordings or photos on our backend.
• We use limited third-party services for sign-in, subscriptions, crash reporting, analytics, and abuse prevention.
• We do not sell your data and do not use advertising identifiers or cross-app tracking.
• You can delete your account in the App, and you have the GDPR rights in Section 14.

3. Data We Process

Reminders and study notifications are scheduled locally on your device; we do not send remote/push notifications and do not collect push-notification tokens. We do not receive your Apple ID or Google password, full payment-card number, or App Store billing details.

4. Purposes and Legal Bases

Where the law requires consent, we request it separately and you may withdraw it at any time with effect for the future. Where we rely on legitimate interests, you may object as described in Section 14.

Providing certain data is necessary to use the Application or specific features (e.g. account, sync, AI, subscriptions). If you do not provide it, those features may be unavailable, but you can continue to use the Application’s local, offline functionality.

5. AI Features, Photos, and Audio

Some features use third-party AI providers — currently Google (Gemini) as the primary provider and Anthropic (Claude) as a fallback — to generate translations, examples, and parts of speech, and to extract words from photos and from short voice recordings.

We access these providers through their developer APIs / business services, not through consumer chat accounts. To provide a feature, our backend receives the word, phrase, text, short audio recording, or photo you submit, the selected languages, your subscription tier, an anonymous/pseudonymous identifier, and minimal technical request metadata needed to process the request, enforce quotas, and protect the service. We send AI providers only the data needed to generate the result and do not send them your account or app identifier. AI providers may process AI inputs and outputs to provide, secure, monitor, and improve their services in accordance with their applicable terms and data-processing commitments. Because these providers are in the United States, AI features involve an international data transfer (see Section 10).

Photos you submit for word extraction are processed transiently to produce the result and are not stored on our backend; they are transmitted to the AI provider for processing under its terms.

Audio. When you use voice word extraction, the App records a short audio clip via your device microphone — only when you actively start a recording and only while you are recording. The clip is sent to our AI provider to extract words; it is not stored on our backend, and we do not use it to identify you. The microphone is accessed only for this feature.

You must not submit to AI features any special-category data under Art. 9 GDPR (e.g. health, biometric, or data revealing racial/ethnic origin, religion, or sexual orientation), identity or official documents, payment-card data, passwords or credentials, images of children, private information about other people, or confidential legal, medical, or financial records — unless strictly necessary and you have a valid legal basis and all required consents. You are responsible for the content you submit and for reviewing AI output before relying on it.

6. Special Categories of Data

The Application is not designed to request, require, or collect special categories of personal data within the meaning of Art. 9 GDPR. However, because the Application accepts free-text, audio and photo input, you could submit such data in words, notes, text, audio, or photos. If you do, we process it only to provide the feature you requested and as needed for security, debugging, legal compliance, or legal claims. You must not submit special-category data unless you have a valid legal basis and all required consents.

7. Local Storage, Sync, iCloud, Backups, Notifications, and Widgets

The Application stores your content locally on your device (flashcards, decks, study history, preferences, cached data, technical identifiers).

If you use account or sync functionality, your decks, cards, study state, and preferences are also stored on our backend in the European Union (see Section 9).

A limited subset of settings may be mirrored to the Apple iCloud Key-Value Store so they survive reinstalls and sync across your Apple devices. This includes settings such as your selected languages, study preferences, streak, milestones, onboarding state, the install date, and the number of decks you have created (for the free-tier deck limit) — not your decks or flashcards, and not account credentials or tokens. iCloud Key-Value data is also governed by Apple’s privacy policy and iCloud terms. The Application does not use Apple CloudKit to mirror your flashcards or decks.

Recovery copy. If the App detects that your account session has been lost (for example, after the account was removed on our side), it may automatically upload a one-time copy of the data stored in the App on your device — decks, cards, study progress, settings, and the local database file — to a restricted area of our backend in the European Union, so that we can restore your data or help you through support. Only we can access these copies, and we delete them after 90 days at the latest.

Depending on your device and Apple settings, your local app data may be included in your device backup, including iCloud Backup, which Apple controls under its own terms.

Reminders and study notifications are scheduled locally on your device. Widgets and notifications may display your learning content on your device’s screen depending on your settings; you are responsible for your lock-screen, notification-preview, and widget visibility settings.

Deleting the App from your device may remove local app data but does not by itself delete backend data, iCloud data, Apple subscription records, Google sign-in records, or data held by third-party providers.

8. Subscriptions

Subscriptions and in-app purchases are processed by Apple through the App Store. We use RevenueCat to validate receipts, manage entitlements, trials, and subscription status, restore purchases, and manage access across devices. We do not control Apple’s billing and do not receive your full payment details.

9. Recipients, Processors, and Independent Providers

We use the following third-party providers. Their role under data-protection law depends on the service:

We may update providers where reasonably necessary to operate, secure, improve, or provide the Application, and we will update this Privacy Policy where a change materially affects how personal data is processed. Where required by law, we put appropriate data-processing agreements and transfer safeguards in place. To request the current list, contact support@llamonade.app.

10. International Transfers

Our backend, crash reporting, and analytics are processed within the EU/EEA (Supabase in Frankfurt; Sentry in the EU; TelemetryDeck in Germany).

Certain processing involves providers in the United States — in particular AI features (the words, text, photos, and short audio recordings you submit are processed by our AI providers, Google Gemini and Anthropic Claude), subscription validation (RevenueCat), parts of sign-in and platform services (Apple, Google), edge/proxy processing (Cloudflare), support email (Gmail), and operational backups (GitHub).

Where available and applicable to the specific provider and service, we may rely on an adequacy decision such as the EU–US Data Privacy Framework. Otherwise, we rely on Standard Contractual Clauses and additional safeguards where required. If you require that all data remain exclusively within a specific country or region, do not use the affected features or the Application, unless it expressly provides such a guarantee.

11. Automated Processing

We use automated processing for security and fair-use purposes — for example rate limiting, quota enforcement, and abuse/fraud detection — which may automatically throttle, block, or suspend access. Most such measures are temporary and technical and do not produce legal or similarly significant effects. These measures are necessary to perform our contract with you and to protect the service (Art. 6(1)(b) and (f) GDPR). To the extent any measure would amount to a decision producing legal or similarly significant effects within the meaning of Art. 22 GDPR, you may contact us at support@llamonade.app to express your point of view and request human review. We do not profile you for advertising purposes.

12. Data Retention

We keep personal data only as long as reasonably necessary for the purposes in this policy, unless a longer period is required or permitted by law.

We may retain limited data where necessary to comply with law, prevent abuse, protect the service, or establish, exercise, or defend legal claims.

13. Account Deletion

You can initiate account deletion in the App:

Settings → Account → Delete My Account (with confirmation).

When you delete your account: your backend account and the synced decks, cards, study state, and preferences associated with it are deleted from our active systems; access to synced data may be permanently lost; local data on your device may remain until you delete it or uninstall the App; and some data may persist in backups, logs, or in Apple, Google, subscription, or other third-party systems under their own retention rules. We may retain limited data where necessary for security, abuse prevention, legal compliance, or legal claims.

Deleting your account does not cancel your App Store subscription. You must cancel any active subscription through Apple (Settings → your name → Subscriptions). Deleting the App does not by itself delete your backend account.

14. Your Rights

Where applicable data-protection law grants them, you have the right to: access your data; rectify inaccurate data; erase your data; restrict processing; object to processing based on legitimate interests; data portability (a structured, machine-readable copy, where applicable); and withdraw consent where processing is based on consent — in each case with effect for the future.

To exercise your rights, contact support@llamonade.app. We may need to verify your identity, and we will respond within the time limits required by law. Some rights may be limited where necessary to comply with law, protect the service, prevent abuse, or protect the rights of others.

You also have the right to lodge a complaint with a data-protection supervisory authority, including the authority of your habitual residence or place of work, or our lead authority in Germany, Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (ULD), whose contact details are available on its official website.

15. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or destruction, taking into account the state of the art, the nature, scope, context, and purposes of processing, and the risks to your rights and freedoms. No method of transmission, storage, synchronization, or processing is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your device, Apple ID, Google account, email account, and backups secure.

16. Children

The Application is not directed to children under the age of 16 in the EU/EEA (or the higher minimum age required by applicable law elsewhere). We do not knowingly collect personal data from children below the applicable age without valid parental consent. Parents and guardians are responsible for supervising a minor’s use of the Application, including the AI, audio and photo features. If you believe a child has provided personal data without appropriate consent, contact support@llamonade.app and we will take reasonable steps to delete it.

17. No Sale of Data; No Advertising or Tracking

We do not sell personal data. We do not use your personal data for third-party advertising or cross-context behavioral advertising, and we do not use Apple’s advertising identifier (IDFA) or cross-app tracking. We do not share personal data with third parties for their own independent advertising purposes.

18. Source of Data

We obtain personal data primarily from you and your device. We also receive limited data from Apple and Google when you choose to sign in (a sign-in identifier and, if you allow it, an email or private-relay email address) and from our subscription-management provider regarding your subscription/entitlement status.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the Application, our providers, legal requirements, infrastructure, or data-processing practices. The “Last updated” date indicates the current version. We will update this Privacy Policy where changes materially affect how personal data is processed, and, where required by law, we will provide additional notice or request consent.

20. Website

Our website wundercards.app is hosted by Cloudflare, Inc. When you visit it, Cloudflare processes technical connection data — your IP address, browser user agent, the requested page and the time — to deliver the site and protect it from abuse (Art. 6(1)(f) GDPR); these logs are kept only briefly under Cloudflare’s retention rules. All files of the website, including fonts and images, are served from our own domain; we use no analytics, no advertising cookies and no third-party trackers.

Contact form. If you use the contact form on our website, we process the name (optional), email address and message you enter to answer you (Art. 6(1)(b) and (f) GDPR), and your IP address briefly to limit how many messages can be sent (Art. 6(1)(f) GDPR). The message is delivered to our Gmail mailbox through Cloudflare Email Routing; it is not stored on the website and is kept like other support emails (see Section 12).

21. Contact

End of Privacy Policy.