Privacy policy

最終更新日 01/11/2026

Version: 1.0 Effective date: 16/10/2026 Last updated: 01/11/2026

1. Data Controller

Sara Nicastro Trieste, Italy Email: saranicastro.sn@gmail.com

(“Controller”, “we”, “us”)

For any question about this Policy or the processing of your personal data, contact us at the email address above.

Data Protection Officer (DPO): No Data Protection Officer has been appointed under Art. 37 GDPR, as the Controller is a single independent developer who does not carry out large-scale processing or systematic processing of special categories of data.

2. Who this Policy applies to

This Privacy Policy (“Policy”) applies to the Fox Cards mobile application (“App”), available on the Google Play Store for Android devices, developed and operated by the Controller named above.

Fox Cards is a flashcard app for studying: you create decks and cards (optionally with attached photos and PDFs), organise them in folders and review them with a spaced-repetition algorithm (FSRS) that works out, on the device, when to show you each card again. An in-app Shop lets you download ready-made decks, some free and some paid.

Privacy-relevant features:

• No account. There is no registration, sign-in or user profile. We use no authentication system.
• No Controller server holding your data. We run no backend or remote database containing your decks, cards or progress. The Controller has no access, at any time, to the content you enter in the App. The only remote infrastructure the App uses on the Controller’s behalf is a read-only storage space (Firebase Storage) from which the App downloads the Shop catalogue and decks (see section 4.2): the App never uploads anything to it.
• Data on the device. Decks, cards, attachments, study progress and preferences are stored in the App’s private storage on your device. The only exception is Android’s system auto-backup, which may copy part of them to the Google Drive space of your Google account (see section 4.5): it is run by Google, not by the Controller, and you can turn it off.

By using the App you accept the practices described in this Policy. If you do not agree, please do not use the App.

3. Minimum age

The App is intended for users aged 13 or over. We do not knowingly collect personal data from children under 13, or under the higher threshold set by the country of residence for independent digital consent (between 13 and 16 in European Union countries; in Italy, 14 under Legislative Decree 101/2018; in South Korea, 14 under the PIPA; in China, 14 under the PIPL). If you believe a minor has used the App without the consent of the person with parental responsibility, contact us: we will explain how to remove the local data from the device (see section 9.0).

4. Personal data we collect

4.1 Data you process locally in the App (not transmitted to the Controller or to third parties)

This data stays on your device, in the App’s private storage. It is not sent to the Controller and is not transmitted to the third-party providers listed in section 6. The App offers no cloud backup of its own; the only exception to this data staying on the device is Android’s system auto-backup described in section 4.5 (never towards the Controller).

4.2 Data transmitted to third parties while using the App

The App connects to the Internet (INTERNET permission) solely for the purposes described below. In these operations some technical data (in particular your IP address, inevitably visible to any server you contact) is processed by third parties. If you have made at least one purchase, studying and the library also work without a connection; otherwise, after 30 consecutive seconds without a connection the App shows a full-screen notice that suspends its use until the network is back (see Terms and Conditions, section 2.1).

The App does not send Google, RevenueCat or anyone else the text of your cards, the names of your decks or folders, your attachments or your study progress.

External links: the App items that open this Policy, the Terms, the Facondia Lab website or the App’s Google Play listing (“Rate the app”) open your browser or the Google Play app: from that point the privacy policies of those services apply.

4.3 Data we do NOT collect

• No account, no identity. The App has no login, does not ask for your name, email, phone number or other identifying data, and creates no user profile.
• No study content to third parties. See section 4.2, last paragraph.
• No crash reporting. The App does not integrate Firebase Crashlytics or any other automatic error-reporting system. If the App crashes, no report is sent to us.
• No remote push notifications. Study reminders are local notifications, scheduled and generated on the device at the times you choose; the App does not integrate Firebase Cloud Messaging or any other push notification service and registers no notification token.
• No geolocation data. The App does not request the location permission. See the “Attachments” row in section 4.1 for photo EXIF metadata, which stays on the device.
• No biometric data.
• We do not sell personal data to third parties.

4.4 Device permissions requested by the App

All the permissions above except Notifications are normal (install-time) permissions: they are granted automatically on installation and, on many devices, do not appear on the App’s permission screen.

Photos and PDFs: to attach a photo you can take it with the device’s camera app or pick it from the gallery through Android’s system picker; for a PDF you use the system file picker. The App requests neither the camera permission nor any storage permission: it only receives the photo or file you choose, without ever accessing your whole gallery or the device’s storage.

4.5 Android system auto-backup (Android Auto Backup)

The App offers no cloud backup of its own and the Controller runs no server holding your data. However, as a default setting of the operating system, Android Auto Backup may copy part of the App’s data to the Google Drive space associated with your Google account, so that it can be restored when you reinstall the App or set up a new device. The App explicitly limits what is copied:

Purchases are never included in the backup: they are restored from your Google Play account (see the Terms and Conditions).

Features of this backup:

• it is run entirely by Google and the Android operating system, not by the Controller, which has no access to it at any time;
• the data is stored in your Google account’s Drive space, under your control, and is encrypted with a key tied to the device credentials;
• it falls under Google’s terms of service and privacy policy for your Google account / Google Drive;
• you can turn it off at any time in Android settings (Settings > Google > Backup, or Settings > System > Backup) and delete existing backups from the same screen or from Google Drive (Backups section).

5. Purposes and legal bases of processing

6. Third-party services

We use the following third-party services, each subject to its own privacy policy:

For advertising and measurement services, Google acts under its own terms; information on how Google uses data from partner apps: https://policies.google.com/technologies/partner-sites

All the providers listed process data in accordance with the GDPR (including through Standard Contractual Clauses where applicable) and with the laws of the United States and the other countries where they operate. This Policy does not cover the privacy practices of third-party sites and services reachable through links in the App. Links to the providers’ policies may be updated by the respective third parties; if a link does not work, look for the current privacy policy directly on the provider’s website.

7. International data transfers

The third-party providers listed (Google LLC, RevenueCat, Inc.) are based in the United States and may transfer and process personal data in the USA and in other countries outside the European Union.

Such transfers take place in compliance with applicable law, including:

• Standard Contractual Clauses (SCC) approved by the European Commission (Decision 2021/914/EU);
• Google’s participation in the EU-US Data Privacy Framework (in force since July 2023).

The Controller does not transfer to any country your decks, cards or progress: they do not leave your device, except for the optional Android auto-backup to the Google Drive space of your Google account (see section 4.5), run by Google and subject to Google’s policies on the location of your account data.

Note for residents of Japan: under Art. 28 of the APPI, transferring personal data to a third party located in a foreign country is subject to specific requirements when that country is not recognised by the Personal Information Protection Commission as having a data protection system equivalent to Japan’s (the United States is not so recognised). By using the Shop, advertising or purchases, or by leaving usage statistics active, you consent to the transfer of the related technical data to Google LLC and RevenueCat, Inc. (both based in the United States — see section 6). You may withdraw consent with the controls in section 12 or by ceasing to use the App.

Note for residents of China: under Art. 39 of the Personal Information Protection Law (PIPL), transferring personal data outside the People’s Republic of China requires the data subject’s separate and specific consent. By using the Shop, advertising or purchases, or by leaving usage statistics active, you give that separate consent to the transfer of the related technical data to Google LLC and RevenueCat, Inc., revocable at any time with the controls in section 12 or by ceasing to use the App.

8. Data retention

9. Your rights

9.0 How to delete your data

Since there is no account and the Controller runs no server holding your data, you have direct and complete control over all your study content:

• Delete individual items: you can delete individual cards, decks or folders directly in the App at any time.
• Delete everything: in Android settings, Settings > Apps > Fox Cards > Storage > Clear data immediately and irreversibly removes all of the App’s local data.
• Uninstall the App: uninstalling deletes all of the App’s local data from the device.
• Delete the system backup: if Android auto-backup is active (section 4.5), the copy on your Google Drive must be deleted separately from Android settings (Settings > Google > Backup) or from Google Drive.
• Usage statistics: you can ask for their early deletion by writing to the Controller; where applicable, you can also withdraw consent from the App’s “Privacy and data” item (section 12).

If you have already uninstalled the App: the local data was already removed from the device by Android on uninstall. For data processed by third-party providers (see section 6), you can contact those providers directly or write to the Controller at the email address at the top of this document. General instructions are also available at https://nicastro.in/legale/data-deletion-cancellazione-dati/.

Since your study content resides exclusively on your device and the Controller has no access to it, the Controller cannot physically provide you with a copy of that data or delete it on your behalf: you exercise the rights of access, rectification and erasure over that data directly through the App (viewing, editing, deleting). All rights remain fully exercisable against the third-party providers listed in section 6 for the data they process.

9.1 GDPR rights (EU/EEA and UK)

As a data subject under the GDPR (Regulation (EU) 2016/679) and the UK GDPR, you have the right to:

• Access (Art. 15): obtain confirmation of processing and a copy of your personal data.
• Rectification (Art. 16): correct inaccurate or incomplete data.
• Erasure (“right to be forgotten”, Art. 17): request deletion of the data, subject to legal obligations requiring its retention.
• Restriction of processing (Art. 18).
• Portability (Art. 20): receive your data in a structured, machine-readable format. Your study content resides only on your device, the Controller has no access to it and the App does not currently offer an export function; Android’s direct device-to-device transfer (section 4.5) lets you copy it to a new phone.
• Objection (Art. 21): object to processing based on legitimate interest.
• Withdrawal of consent: withdraw consent at any time (personalised advertising, usage statistics) without affecting the lawfulness of prior processing.
• Complaint to the competent supervisory authority:
  • Italy and EU: Garante per la protezione dei dati personali (www.garanteprivacy.it, +39 06 696771)
  • United Kingdom: Information Commissioner’s Office (ICO, ico.org.uk, 0303 123 1113)

To exercise your rights, write to saranicastro.sn@gmail.com with the subject “GDPR rights request”. We will respond within 30 days (extendable to 90 days in particularly complex cases, with notice within the first month).

9.2 CCPA/CPRA rights (California, USA)

If you are a California resident, under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), you have the right to:

• Know which categories of personal data we collect and with whom we share them (see sections 4 and 6).
• Deletion of your personal data, with the exceptions provided by law.
• Correction of inaccurate personal data.
• Opt out of the sale or sharing of personal data. We do not sell personal data. Serving personalised ads via Google AdMob may constitute “sharing” under the CPRA: you can opt out at any time by not giving consent in the Google UMP form (where applicable), by disabling ad personalisation in Android settings (Settings > Google > Ads) or resetting the Android Advertising ID, or by making any in-app purchase, which removes advertising. You can also send us a request at the email address below.
• Non-discrimination for exercising your rights.

Do Not Track (DNT): Fox Cards is a native mobile application and does not operate through a browser. DNT signals sent by browsers do not apply to the App and are not recognised. To manage tracking preferences, use the controls described in section 12.

To exercise CCPA/CPRA rights, contact us at saranicastro.sn@gmail.com with the subject “California Privacy Request”. We will respond within 45 days, extendable by a further 45 days with notice.

Other US states: if you reside in another US state with a comprehensive privacy law (e.g. Virginia, Colorado, Connecticut, Texas, Oregon, Montana), we grant you rights equivalent to those described in this section, in addition to the minimum standard described in section 9.14.

9.3 LGPD rights (Brazil)

If you are a Brazilian resident, under the Lei Geral de Proteção de Dados Pessoais (LGPD, Law No. 13.709/2018), you have the right to: confirmation of processing, access, correction, anonymisation/blocking/deletion of unnecessary data, portability, information about the third parties with whom data is shared, withdrawal of consent and objection to processing. We will respond within 15 days of the request. You may lodge a complaint with the ANPD (Autoridade Nacional de Proteção de Dados, www.gov.br/anpd).

9.4 APP rights (Australia)

If you are an Australian resident, data processing complies with the Australian Privacy Principles (APP, Privacy Act 1988 Cth). You have the right to access your personal data and request its correction; we will respond within 30 days. You may lodge a complaint with the Office of the Australian Information Commissioner (OAIC, www.oaic.gov.au).

9.5 PIPEDA/CPPA rights (Canada)

If you are a Canadian resident, we process your data in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the Consumer Privacy Protection Act (CPPA) and equivalent provincial laws (PIPA Alberta/BC, Law 25 Quebec). You have the right of access and rectification; we will respond within 30 days. You may lodge a complaint with the Office of the Privacy Commissioner of Canada (www.priv.gc.ca).

9.6 PDPA rights (Thailand and Singapore)

If you are a resident of Thailand, we respect the Personal Data Protection Act B.E. 2562 (PDPA 2019). If you are a resident of Singapore, we respect the Personal Data Protection Act 2012 (PDPA). In both cases you have the right of access, correction, deletion and portability of data. To exercise them, contact us at the email address indicated.

9.7 POPIA rights (South Africa)

If you are a South African resident, we process your data in compliance with the Protection of Personal Information Act (POPIA, Act 4 of 2013). The Information Regulator is the competent supervisory authority (www.inforegulator.org.za, inforeg@justice.gov.za).

9.8 PIPL rights (People’s Republic of China)

If you are a resident of the People’s Republic of China, we process your data in compliance with the Personal Information Protection Law (PIPL, in force since 1 November 2021). You have the right to request access to and a copy of your personal data, correction of inaccurate data, deletion, withdrawal of consent to processing, and an explanation of the rules by which we process your personal data. You may lodge a complaint with the Cyberspace Administration of China (CAC, www.cac.gov.cn). The PIPL also requires your separate consent to transfer your personal data outside China (Art. 39): see the dedicated note in section 7.

9.9 APPI rights (Japan)

If you are a Japanese resident, we process your data in compliance with the Act on the Protection of Personal Information (APPI, Act No. 57/2003, as amended). You have the right to request disclosure of the purposes of use and of the retained personal data, correction, addition or deletion of inaccurate data, and suspension of use or deletion where processing does not comply with the APPI or is no longer necessary. To exercise these rights, contact us at the email address indicated. The competent supervisory authority is the Personal Information Protection Commission (PPC — www.ppc.go.jp).

9.10 PIPA rights (South Korea)

If you are a resident of the Republic of Korea, we process your data in compliance with the Personal Information Protection Act (PIPA, Act No. 10465/2011, as amended). You have the right to request access, rectification, deletion and suspension of the processing of your personal data. You may lodge a complaint with the Personal Information Protection Commission (PIPC, www.pipc.go.kr). The PIPA also requires your consent to transfer your personal data outside South Korea: by using the Shop, advertising or purchases, or by leaving usage statistics active, you give that consent, revocable with the controls in section 12 or by ceasing to use the App.

9.11 DPDP rights (India)

If you are an Indian resident, we process your data in compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act). You have the right to access your personal data, request its correction and deletion, and nominate a person to exercise your rights in the event of incapacity or death. You may lodge a complaint with the Data Protection Board of India.

9.12 FADP rights (Switzerland)

If you are a Swiss resident, we process your data in compliance with the Federal Act on Data Protection (nFADP, in force since 1 September 2023). You have rights of access, rectification and deletion analogous to those under the GDPR (see section 9.1). The competent supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch).

9.13 152-FZ rights (Russian Federation)

If you are a resident of the Russian Federation, we process your data in compliance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (as amended). You have the right to request access, rectification, blocking and deletion of your personal data, and to withdraw consent to processing at any time. You may lodge a complaint with Roskomnadzor (rkn.gov.ru).

Data localisation (Art. 18(5)): the Controller runs no server holding your data: your study content resides on your device, under your control — not on infrastructure managed by the Controller inside or outside Russia. The optional Android auto-backup (section 4.5) is run by Google to your Google account’s space, not by the Controller. The third-party providers listed in section 6 act as independent processors and may process technical data outside the Russian Federation as part of their respective services.

9.14 Other jurisdictions

If you reside in a country not expressly listed in this section, we apply, as a minimum standard, the protections provided by the GDPR (access, rectification, erasure, objection — see section 9.1). You may exercise the rights granted by the law of your country of residence by writing to saranicastro.sn@gmail.com: we will respond within 30 days.

10. Children — COPPA (USA)

In compliance with the Children’s Online Privacy Protection Act (COPPA, 15 U.S.C. 6501 et seq.), the App is not directed to children under 13 and we do not knowingly collect personal data from such children without verifiable parental consent. If you are a parent or guardian and believe your child has used the App and provided personal data to a third-party provider, contact us at saranicastro.sn@gmail.com.

11. Data security

We adopt technical and organisational measures appropriate to the risk, including:

• Local data protected by the Android operating system sandbox: the databases, attachments and preferences reside in the App’s private storage, not accessible to other applications.
• Network communications over encrypted connections (HTTPS/TLS) to third-party providers.
• A read-only Shop storage space protected by Firebase App Check: the App can only download data, never upload it.
• No Controller server holding your data and no account: the Controller holds no central store of user data that could be breached.
• App updates through Google Play.

No data transmission or storage system can guarantee absolute security. Since we do not process your personal data on our own systems, a personal data breach under Arts. 33-34 GDPR attributable to the Controller cannot arise; any incidents at the third-party providers listed in section 6 are handled by those providers under their own procedures.

12. Advertising, usage statistics and consent (AdMob / Firebase Analytics / Google UMP)

Advertising. The App only shows interstitial ads (full-screen) at the start of a study session, at limited frequency: at most one ad per half day and at most two per day. There are no banners. Any in-app purchase (a colour theme, a Shop deck or the dedicated “remove ads” purchase) permanently removes advertising: from then on the App no longer requests ads. Downloading a free deck from the Shop is not a purchase, does not involve RevenueCat or Google Play Billing and does not remove advertising.

Usage statistics. The App records anonymous usage events through Firebase Analytics (section 4.2) to understand which features are used. Events never contain your study content.

Consent. In geographic areas where the law requires it (e.g. European Union, United Kingdom, Switzerland), on first launch you are shown a GDPR-compliant consent form (through Google User Messaging Platform — UMP). Until you answer, no ad is requested and usage statistics remain off. In the form you can:

• Accept personalised ads and usage statistics;
• Decline (you may still see contextual non-personalised ads; usage statistics stay off or limited according to your choices).

In geographic areas where local law does not require the consent form, ads may be personalised according to the advertising settings of your device and Google account, and usage statistics are active on the basis of legitimate interest: you can object at any time by writing to saranicastro.sn@gmail.com (subject “Statistics objection”).

How to change your preferences:

• Review or change your consent from the App’s Settings > Info and legal > Privacy and data item, which reopens the Google UMP form (the item appears only in areas where the law requires consent; it stays available even after a purchase, because the form also covers usage statistics).
• On Android 13 and later, manage Android’s Privacy Sandbox APIs (Topics, Attribution Reporting) from the device’s Settings > Privacy > Ads.
• Disable ad personalisation in Android settings: Settings > Google > Ads, or reset or delete your Android Advertising ID.
• Manage Google advertising settings: https://adssettings.google.com
• Remove advertising entirely with any in-app purchase.

13. Cookies and tracking technologies

Fox Cards is a native Android mobile application and does not use cookies. The integrated third-party services (AdMob, Firebase Analytics) may use cookie-like identifiers (e.g. Android Advertising ID — AAID, the App-installation identifier) and, on Android 13 and later, Android’s Privacy Sandbox APIs described in section 4.4, subject to the consent preferences described in section 12. You can reset or disable the AAID in Android settings: Settings > Google > Ads.

14. Automated decision-making

The App uses one automated process, run entirely on the device: the FSRS spaced-repetition algorithm works out, from the ratings you give while reviewing, when to show you each card again. The calculation serves only to organise your study, is not transmitted to anyone and depends only on the answers you give.

This process produces no legal effects or decisions that significantly affect the individual within the meaning of Art. 22 GDPR. No behavioural profiling for commercial purposes is carried out beyond the personalised advertising described in section 12, subject to consent where required and always able to be disabled.

15. Changes to this Policy

We reserve the right to update this Policy to reflect legislative, technical or operational changes. The current version is always available at https://nicastro.in/legale/fox-cards-privacy-policy/ and reachable from within the App (Settings > Info and legal): please check it periodically. The date of the last change is always shown at the top of the document. Continued use of the App after any change constitutes acceptance of the updated version.

16. Governing law and jurisdiction

This Policy and any dispute concerning the processing of personal data carried out by the Controller are governed by Italian law, in compliance with applicable European rules (in particular the GDPR).

For any dispute concerning the interpretation, validity or performance of this Policy, the Court of Trieste (Italy) has exclusive jurisdiction, subject to any mandatory provision of law applicable in the user’s country of residence.

Users resident in the European Union retain in any case the right to lodge a complaint with the supervisory authority of their country of residence under Art. 77 GDPR, regardless of the contractual jurisdiction indicated.

17. Contact

For any question, request to exercise rights or complaint:

Data Controller Sara Nicastro Trieste, Italy Email: saranicastro.sn@gmail.com

We will respond to all requests within 30 days of receipt.

Policy drafted in compliance with: Regulation (EU) 2016/679 (GDPR) · UK GDPR · California Consumer Privacy Act/California Privacy Rights Act (CCPA/CPRA) · Children’s Online Privacy Protection Act (COPPA) · Lei Geral de Proteção de Dados (LGPD, Brazil) · Personal Information Protection Law (PIPL, China) · Personal Data Protection Act (PDPA, Thailand 2019 and Singapore 2012) · Australian Privacy Principles — Privacy Act 1988 (Australia) · PIPEDA/Consumer Privacy Protection Act (Canada) · Protection of Personal Information Act (POPIA, South Africa) · Act on the Protection of Personal Information (APPI, Japan) · Personal Information Protection Act (PIPA, South Korea) · Federal Law No. 152-FZ on Personal Data (Russian Federation) · Digital Personal Data Protection Act (DPDP, India 2023) · Federal Act on Data Protection (nFADP, Switzerland)

This Policy was drafted by the Controller for informational purposes. For complex legal questions or to verify compliance in specific jurisdictions, consulting a lawyer specialised in privacy law is recommended.