Privacy Policy

At Retain, we understand that privacy is important. This privacy policy applies to our web and mobile app, Retain, and explains how we collect, use, and share information about you when you use our services. By using Retain, you agree to the collection, use, and sharing of your information as described in this policy. If you do not agree with our policies and practices, do not use our services.

Information We Collect

We collect information about you when you use Retain. This includes:

• Information you provide to us: When you create an account or profile on Retain, we may ask you to provide personal information such as your name, email address, and phone number. If you contact us for support or with questions, we may also collect information about you in order to assist you.
• Information we collect automatically: When you use Retain, we may collect certain information automatically, such as your IP address, device type, and operating system. We may also collect information about your use of Retain, including the actions you take, the pages you visit, and the time you spend on the app.

Use of Your Information

We use the information we collect about you to provide, maintain, and improve our services. This may include: Creating and managing your account: We use your information to create and manage your Retain account, and to enable you to use the app. Personalizing your experience: We may use your information to personalize your experience on Retain, such as by showing you content that is relevant to your interests. Improving our services: We may use your information to understand how people use Retain and to improve the app.

Sharing of Your Information

We do not share your personal information with third parties for their own marketing purposes. However, we may share your information with third parties in the following circumstances:

• With your consent: We may share your information with third parties if you have given us your consent to do so.
• For legal reasons: We may share your information if we believe it is necessary to comply with a legal obligation, such as a court order or subpoena.
• To protect the rights and safety of others: We may share your information if we believe it is necessary to prevent harm to others.
• With service providers: We may share your information with third party service providers who perform services on our behalf, such as hosting, data analysis, and payment processing. These service providers are contractually obligated to only use your information as necessary to provide the services they are performing for us.

Use of Artificial Intelligence (Google Vertex AI)

To power the "Voice Study" feature, our app integrates with AI models provided by Google (Google Vertex AI). When you actively use this feature, the app collects and transmits specific data to facilitate the conversational experience.

• Data Processed: We send your spoken audio and the text content of your current flashcards to Google’s AI services.
• Purpose: This data is used exclusively to generate real-time, conversational audio responses for your study session.
• Data Retention & Privacy: The audio and card data sent to Google is processed anonymously and is not linked to your personal identity or account. Google retains this data temporarily (for a maximum of 24 hours) solely for the purpose of session continuity.
• Model Training: Your data is strictly used to provide the Voice Study service and is not used to train Google’s or any other third-party AI models.

By using the Voice Study feature, you consent to this specific data processing. You can choose not to use the Voice Study feature if you do not wish to share this data.

Data Retention and Deletion

We will retain your information for as long as your account is active or as needed to provide you with our services. If you wish to delete your account or request that we no longer use your information to provide you with our services, please contact us at info@retaincards.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to This Privacy Policy

We may update our privacy policy from time to time. We will post any changes on this page and encourage you to review the policy periodically. If we make significant changes to our policy, we may also provide additional notice, such as by sending an email notification or displaying a notice on the app.

If you have any questions regarding these terms, please contact me at info@retaincards.com.

Turnstile Privacy Addendum

Last updated: JUNE 18, 2025 1. INTRODUCTION Turnstile, developed by Cloudflare, Inc. (Cloudflare), is a pro-privacy website security tool that processes minimal Signals (as defined below) solely to protect web properties against malicious activity by distinguishing human users from bots and blocking bot traffic. Cloudflare does not control whether a website chooses to use Turnstile; instead, we make Turnstile available to any website that is looking for a way to detect and block bot traffic. 2. SCOPE OF THIS ADDENDUM This Turnstile Addendum is supplemental to Cloudflare's main Privacy Policy. It provides additional information specific to your use and interaction with Turnstile. This Addendum also applies to the personal data processed using Cloudflare’s Challenge Platform, and any reference to “Turnstile” in this addendum applies equally to the Challenge Platform. The Cloudflare Privacy Policy continues to apply to your use and interaction with Turnstile, except where this Turnstile Addendum provides more specific information. In those cases, the more specific information will apply instead. 3. INFORMATION WE COLLECT Cloudflare Turnstile processes a variety of client-side signals (“Signals”) such as client IP address, TLS Fingerprint, User-Agent Header and Sitekey and associated origin. Cloudflare does not have the ability to directly identify any individuals from any of the Signals Turnstile collects, including IP addresses. 4. HOW WE USE INFORMATION WE COLLECT (i) Bot detection and blocking Turnstile is a tool to protect web properties by distinguishing human users from bots and blocking any detected bot traffic that could otherwise harm the safety and security of that property. It does so by evaluating the Signals listed above specific to both the website visitor and the website visited. The purpose of collecting these Signals is not to identify, profile or target any individuals but solely to detect and block bots. The Signals collected by Turnstile are strictly necessary for this purpose (i.e. detecting and blocking bots to enable visitors to enjoy a safe and secure experience when visiting websites that have implemented Turnstile). Cloudflare is a data processor of Signals that we process to provide the Turnstile service to our customers, that is, securing our customers’ websites. This means that we process Signals for this purpose on behalf of, and pursuant to instructions issued by, our website operator customers (who are the data controllers of any data processed for this purpose). If you have questions, or wish to exercise any data protection rights, regarding Cloudflare’s processing of Turnstile data to provide our service, please contact the relevant website operator. (ii) Improving Turnstile’s bot detection capabilities Cloudflare also processes the Signals described in this Privacy Notice to improve Turnstile. This is necessary to refine and improve our bot detection algorithms in order to respond to evolving bot threats, and to maintain the security of the web properties that website visitors choose to visit. Cloudflare is a data controller of Signals that we process to improve Turnstile’s bot detection capabilities. This Turnstile Privacy Notice (in conjunction with Cloudflare's main Privacy Policy) governs our processing of Signals for this purpose. 5. NOTICE TO EU AND UK RESIDENTS To the extent that the data described in the Turnstile Privacy Notice qualifies as personal data, then: When processing this personal data as a processor to protect our customers' websites, our customers, as controllers, determine the lawful basis of this processing, and we process this data under their instruction and on their behalf; and When processing this personal data as a controller, we rely on our legitimate interests in improving the effectiveness of Turnstile's bot detection capabilities to process this Turnstile data. 6. COOKIES The Signals collected by Turnstile are strictly necessary for the purpose of detecting and blocking bots to enable visitors to enjoy a safe and secure experience when visiting websites that have implemented Turnstile. For more information about the cookies used by Cloudflare, please check our Cookie Policy and our Turnstile Developer Docs. CONTACT FOR PRIVACY CONCERNS If you have questions or concerns about this Turnstile Privacy Notice or your personal data processed through Turnstile, please contact Cloudflare’s Data Protection Officer at dpo@cloudflare.com.