Privacy Policy for SwiftStudy
Last updated: July 4, 2026
1. Who we are
Flashcards by SwiftStudy (the “App”) and the website swiftstudyapp.com (together, the “Service”) are provided by KD incubator UG (Haftungsbeschränkt), Schonensche Str. 13, 10439 Berlin, Germany, represented by its managing director Daniel Kilders Diaz (“we”, “us”, “our”). We are the data controller for the processing described in this policy.
2. Scope of this policy
This policy covers the iOS App, the website, in-app purchases, and optional features such as iCloud sync. It describes what data is processed, why, and what rights you have.
3. Content you create in the App
Your flashcards — including any text and images you add — your stacks, study progress, streaks, and settings are yours. You do not need an account to use SwiftStudy, and we do not use your content to make credit, insurance, employment, or similar eligibility decisions. We do not have access to the flashcards you create.
4. Where your content is stored
Your content is stored locally on your device. If you enable iCloud, it is additionally synced to your personal iCloud account via Apple’s CloudKit service so that it is available across your devices. iCloud sync is controlled through your Apple account and device settings, not by us. Apple’s privacy policy applies to iCloud.
5. Purchases
All purchases (for example optional tips) are processed by Apple through the App Store. We never receive or store your payment card details. We use RevenueCat to validate purchases and manage entitlements; for this purpose RevenueCat processes technical purchase information such as a pseudonymous app user ID and purchase history.
6. App analytics
We use TelemetryDeck to collect anonymized usage data (for example which features are used and how often the App is opened). This helps us understand how the App is used and how to improve it. TelemetryDeck does not collect personally identifiable information. You can read more at telemetrydeck.com/privacy.
7. Website analytics
Our website uses Plausible Analytics, a privacy-friendly analytics service that does not use cookies and does not track you across sites. It provides us with aggregate statistics such as page views and referrers.
8. Support and communications
If you contact us (for example by email), we process your contact details and the content of your message in order to respond to your request and improve the Service.
9. Diagnostics
If you have opted in to sharing analytics with app developers in your Apple device settings, we may receive aggregated crash reports and diagnostics via App Store Connect to identify and fix problems.
10. Legal bases (GDPR)
Where the GDPR applies, we process data on the following legal bases: performance of a contract (Art. 6(1)(b) GDPR — providing the App you request), our legitimate interests (Art. 6(1)(f) GDPR — improving and securing the Service), your consent (Art. 6(1)(a) GDPR — e.g. optional diagnostics), and compliance with legal obligations (Art. 6(1)(c) GDPR).
11. Sharing with third parties
We do not sell your data. We share data only with service providers that are necessary to run the Service: Apple (App Store distribution, payments, iCloud/CloudKit), RevenueCat (purchase validation), TelemetryDeck (anonymized app analytics), Plausible (website analytics), and our hosting providers. These providers process data on our behalf or as independent controllers under their own privacy policies.
12. International transfers
Some providers process data outside the European Economic Area (for example in the United States). Where the GDPR applies, such transfers rely on appropriate safeguards such as the EU–US Data Privacy Framework or Standard Contractual Clauses.
13. Data retention
Content in the App stays on your device and in your iCloud account until you delete it. Server-side records (for example support emails or purchase entitlements) are kept only as long as necessary for the purposes described above or as required by law.
14. Your rights
Where the GDPR applies, you have the right to access, rectify, and erase your personal data, to restrict or object to its processing, to receive it in a portable format, and to withdraw consent at any time with effect for the future. You also have the right to lodge a complaint with a data protection authority. To exercise your rights, contact us using the details below.
15. Children
The Service is not directed at children under 13, and we do not knowingly collect personal data from children under 13.
16. Security
We use reasonable technical and organizational measures to protect data. No system is perfectly secure, so we cannot guarantee absolute security — please also keep your device and Apple account protected.
17. Changes to this policy
We may update this policy from time to time. We will post the updated version here with a new “Last updated” date, and we will inform you of material changes where required.
18. Contact
KD incubator UG (Haftungsbeschränkt), Schonensche Str. 13, 10439 Berlin, Germany — office@kdincubator.com