Privacy Policy · Terms of Use (EULA)
In short: your decks, cards and photos are processed only on your device. There is no account, no advertising and no tracking. Our own server is contacted only when you activate a school licence — and then it receives just the licence code and a random installation ID, never your name or your study content. On Android, subscriptions run through Google Play and the service provider RevenueCat, which receive the purchase data described in section 5.
HBJ-Solutions GbR
Haardter Str. 13
67433 Neustadt an der Weinstraße, Germany
Email: hello@hbj-solutions.com
VAT ID: DE462565189
Represented by the partners: Ben Grégory Seiler, Julius Maximilian Spindler
This policy covers the Flashwise app for iPhone (Apple App Store) and for Android (Google Play). Where the two differ, the section says so.
Decks, cards, review history and scheduling data are stored exclusively in the app's protected, private storage on your device. We operate no server for this content, there is no account and no sign-up, and none of it is transmitted to us or to any third party. Your device's own backup (iCloud or Google backup) may include this data according to your device settings; that backup is between you and Apple or Google.
The "Scan vocabulary" feature recognises text in a photo you choose and turns it into cards. The photo and the recognised text are processed entirely on your device and are never uploaded to us. We do not keep the photo — only the text you confirm becomes cards.
These Pro features also work entirely on your device. Pronunciation uses the text-to-speech voices installed on your device (Apple's voices on iOS; on Android the voices of your text-to-speech engine, and Flashwise only uses voices that work offline, so the words are never sent to a speech server). The language of a deck is detected on the device (Apple NaturalLanguage on iOS, Google ML Kit language identification with a built-in model on Android). Study reminders are local notifications scheduled on your device, and your study history for the Progress screen (reviews per day) is stored only on your device. None of this is sent to us.
The apps contain no analytics SDK, no advertising and no advertising identifiers (Apple IDFA or Google Advertising ID). We do not track you across apps or websites and do not build profiles. Nothing you do inside the app is reported to us.
Flashwise Pro subscriptions — and the earlier one-time Pro unlock — are handled entirely by Apple (App Store / StoreKit). We receive no name, address or payment details. Apple is the controller for payment processing; Apple's Privacy Policy applies. The app checks your subscription status on the device through StoreKit; no other service is involved.
Payments are handled by Google Play (Google Ireland Limited) as an independent controller; Google's Privacy Policy applies. We never see your payment details, name or email address.
To show the current prices and to know whether your subscription is active, the Android app uses RevenueCat (RevenueCat, Inc., USA) as our processor under Art. 28 GDPR. When the app starts, and when you buy or restore a subscription, RevenueCat receives:
| Data | Why | Legal basis |
|---|---|---|
| A random app user ID created by RevenueCat (not linked to your Google account, name or email) | To keep subscription status apart from other users' | Art. 6(1)(b) GDPR — providing the subscription you bought; for the technical data also Art. 6(1)(f) — operating the service securely |
| Google Play purchase records: purchase token, order ID, product, purchase, renewal and expiry dates, price, currency and store country | To verify purchases with Google and unlock Pro, including after reinstalling | |
| Technical data sent with each request: IP address, app version, Android version, device language | To deliver the right prices and operate the service |
RevenueCat does not receive your decks, cards, photos or any school-licence data. Purchase records are kept for as long as needed to provide the subscription and to meet statutory retention duties. RevenueCat's privacy policy: revenuecat.com/privacy.
If your school bought a licence, activating it is the only feature that contacts our own
server (flashwise.hbj-solutions.com; requests to the former address
funnyareas.com/flashwise are forwarded there). At that moment the app transmits:
| Data | Why | Legal basis |
|---|---|---|
| The activation code | To check the code is valid and unused | Art. 6(1)(b) GDPR — performing the licence contract |
| A random installation ID generated by the app | To limit one code to a small number of devices | Art. 6(1)(f) GDPR — preventing licence abuse |
| IP address of the request (kept only as a hashed value for rate limiting, deleted within 24 hours) | Blocking automated guessing of codes | Art. 6(1)(f) GDPR — IT security |
The request reaches our server through Cloudflare, which also sees the IP address (see section 11).
The installation ID is a random value created by the app. It is not an advertising identifier (Apple IDFA or Google Advertising ID), not your device's serial number or Android ID, and not linked to your Apple ID or Google account. It cannot be used to identify you personally, and deleting the app discards it.
After a successful activation the app stores a digitally signed licence file locally and verifies it offline. No further requests are made to our server — we cannot see how or whether you use the app afterwards.
Schools manage their licence in the Flashwise school dashboard
(flashwise.hbj-solutions.com). For the data a school keeps there, the school is the
controller and we act as its processor under Art. 28 GDPR; a data processing agreement
is available on request.
Licence records (code, optional pupil name, activation timestamps, installation IDs) are kept for the duration of the licence and deleted at the latest 12 months after it expires, unless statutory retention duties (e.g. German commercial or tax law) require longer for the underlying invoice. Staff accounts are deleted when the school deletes them, and at the latest 12 months after the school's licence ends. The dashboard activity log is kept for 24 months. Hashed IP addresses used for rate limiting are deleted within 24 hours; the server keeps no web access logs. For subscription records at RevenueCat, see section 5.
You have the right to information (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and to object (Art. 21 GDPR). You may also lodge a complaint with a supervisory authority — for us, the Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz. To exercise any right, email hello@hbj-solutions.com. For data held on behalf of a school, please contact the school first; we will forward requests to them.
Because we hold no names or contact details of individual app users outside the school licence system, we usually cannot identify you from the app alone. For requests about Android subscription data, please include the Google Play order number (it starts with "GPA.") from your purchase receipt, so we can find the record.
Flashwise is a study app suitable for all ages and is used in schools. It contains no advertising, no cross-app tracking, no chat or sharing between users and no external links inside the learning flow. It does not ask for names, email addresses, contacts or location. Purchases in the app are protected by the store's own parental controls (Apple Screen Time / Ask to Buy, Google Family Link / purchase authentication).
Our licence server and school dashboard run on a server we rent from Hostinger, located in
France (European Union), under a data processing agreement (Art. 28 GDPR). All requests to
flashwise.hbj-solutions.com pass through the network of Cloudflare, Inc. (USA),
which we use to protect the server against attacks and to deliver it securely over HTTPS.
Cloudflare processes the IP address and technical request data (such as time, URL and browser
type) on our behalf for this purpose; this may happen outside the EU. The transfer is based on
the EU-U.S. Data Privacy Framework, under which Cloudflare is certified (Art. 45 GDPR), and on
the EU Standard Contractual Clauses in Cloudflare's data processing agreement (Art. 46(2)(c)
GDPR). Our legal basis is Art. 6(1)(f) GDPR (IT security). Apple and Google
process purchases as independent controllers under their own privacy policies. RevenueCat,
Inc. (Android subscriptions only) processes data in the USA on our behalf; the transfer is
based on the EU Standard Contractual Clauses in RevenueCat's data processing agreement
(Art. 46(2)(c) GDPR).
We will update this policy when the app changes. The current version always applies.
These terms govern your use of the Flashwise application for iOS and Android ("the App") provided by HBJ-Solutions GbR, Haardter Str. 13, 67433 Neustadt an der Weinstraße, Germany ("we", "us"). By downloading or using the App you agree to them.
We grant you a personal, non-exclusive, non-transferable, revocable licence to use the App on devices that you own or control, as permitted by the terms of the store you obtained it from (the Apple Media Services Terms and Conditions for the App Store, or the Google Play Terms of Service). You may not sell, rent, sublicense, redistribute, decompile or reverse-engineer the App, except to the extent such restriction is prohibited by applicable law.
The App is free to download and includes a limited free tier (currently 2 decks with up to 20 cards each). "Flashwise Pro" unlocks unlimited decks and cards, the spaced-repetition scheduler, photo vocabulary scanning and CSV import.
Pro is offered as an auto-renewable subscription, billed monthly or yearly through the store you downloaded the App from:
Earlier iOS purchasers: customers who bought the former one-time "Flashwise Pro" unlock on the App Store keep Pro permanently at no further cost, and can restore it on new iOS devices with "Restore Purchases".
Schools and other institutions may purchase licences directly from us. In that case:
A school licence obtained this way is not purchased through Apple or Google and is not an in-app purchase. Neither Apple nor Google is a party to it or bears any responsibility for it.
Decks, cards and imported material remain yours and are stored on your device. You are responsible for ensuring that content you import — including text recognised from photographs of books or worksheets — does not infringe third-party copyright. Use the photo scanning feature only on material you are entitled to copy, such as your own notes or material your school permits you to digitise for personal study.
We may update the App to fix defects, improve features or maintain compatibility with new iOS and Android versions. We may change or discontinue individual features; where a paid feature is discontinued without an equivalent replacement, your statutory rights remain unaffected.
Statutory warranty rights under German law apply and are not limited by these terms. Beyond that, we are liable without limitation for intent and gross negligence, for injury to life, body or health, and under the German Product Liability Act. For slight negligence we are liable only for breach of an essential contractual obligation, and then limited to the foreseeable damage typical for this type of contract. The App is a study aid; we do not warrant any particular learning outcome or examination result.
This section applies if you obtained the App from the Apple App Store. You acknowledge that these terms are concluded between you and us, not with Apple, and that Apple is not responsible for the App or its content. Apple has no obligation to furnish any maintenance or support for the App. In the event the App fails to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price of the App (if any); to the maximum extent permitted by law, Apple has no other warranty obligation whatsoever with respect to the App. Apple is not responsible for addressing any claims by you or a third party relating to the App, including product liability, legal or regulatory non-compliance, or consumer protection claims. Apple and its subsidiaries are third-party beneficiaries of these terms and, upon your acceptance, will have the right to enforce them against you. You represent that you are not located in a country subject to a U.S. Government embargo or designated as a "terrorist supporting" country, and that you are not listed on any U.S. Government list of prohibited or restricted parties.
This section applies if you obtained the App from Google Play. These terms are concluded between you and us, not with Google. Purchases made through Google Play are also subject to the Google Play Terms of Service; where those terms and these differ on a purchase through Google Play, Google's terms prevail for that purchase.
German law applies, excluding the UN Convention on Contracts for the International Sale of Goods. Mandatory consumer protection provisions of your country of residence remain unaffected. For merchants, the place of jurisdiction is Neustadt an der Weinstraße, Germany.
HBJ-Solutions GbR · Haardter Str. 13 · 67433 Neustadt an der Weinstraße, Germany
hello@hbj-solutions.com