Who is responsible
Daniil Batsyn, an individual based in Georgia, is the publisher of Hola Cards and the controller for the app and website data processing described in this policy. Address: New Gudauri, Loft 1, Gudauri 4702, Georgia. Privacy contact: [email protected].
For website purchases through CloudPayments, Индивидуальный предприниматель Бацын Даниил Дмитриевич (individual entrepreneur Daniil Dmitrievich Batsyn, Russia; INN 773715591537; OGRNIP 322774600498546) is the seller and is responsible for processing order, payment, refund and legally required accounting records. The seller's address, contact details and purchase conditions are provided in the subscription terms.
What stays on your device
Your learning data has a local copy on your device. That includes the words you study, your custom word groups, your progress and statistics, any photos you attach to cards, and microphone audio used for pronunciation practice.
Speech recognition runs on the device with a downloaded model. Audio from your microphone is processed locally and is not uploaded to us or to any third party.
An account is optional. Cloud storage is used when you sign in and synchronize; the account section below explains this.
Accounts, website advertising and payments
The web learning area requires sign-in; the public demo does not. The mobile app also supports guest learning. Firebase Authentication processes account identifiers, email and sign-in identity, while Firebase Firestore stores profile details and synchronized learning data. Devices retain local learning data and unsent changes for offline use. You can delete your account in account settings; contact us if you need help. Uninstalling the app or clearing browser storage does not delete the cloud account.
Web voice practice processes microphone audio on your device. Progress synchronization does not upload those recordings. Signing out separates local learning data from the next account used on that device.
The free website can display Yandex advertising. AdSense is currently disabled. The advertising provider may process cookies and browser or device information. Where an advertising choice is required, advertisements wait for that choice. A refusal or a browser Global Privacy Control signal disables website advertising. Page-text collection is disabled in the learning area.
CloudPayments processes card details in its payment form. Our billing service keeps the account identifier, email, order, price, billing consent, payment and refund status, and subscription dates. Adapty receives purchase and subscription information to make access available across platforms. We do not store card numbers or security codes. Payment records may need to be retained after account deletion for accounting, refunds and applicable legal duties.
Mobile live translation with AI
Live translation is an optional online feature in the mobile app. After your permission, recognised Spanish text and recent text context from the same session are sent through the Hola Cards translation server to DeepSeek, a third-party AI service, to produce contextual translations. The request also contains a randomly generated session identifier, the selected translation language and segment positions. Raw microphone audio is processed on your device and is not sent to Hola Cards or DeepSeek.
Before sending text for the first time, the app explains this sharing and asks you to allow it. Your choice is saved on the device for that version of the disclosure. Declining, closing the request or opening the privacy link does not grant permission and sends no text. You can continue using local flashcards and other learning modes without allowing online translation. Saved text cannot be retried online without this permission.
Hola Cards keeps text context in server memory to translate subsequent segments in the same session. Translation history also has a local copy in the app, which you can clear there. Words or groups you choose to save from a translation follow the learning-data synchronization rules above.
Provider information is available in the DeepSeek privacy policy. That document distinguishes DeepSeek’s own services from applications built on its platform; the Hola Cards processing and choices are described in this policy. For questions or deletion requests relating to information sent through Hola Cards, use the contact details in this policy.
What is collected
The app collects analytics and diagnostic data so we can see which features are used and when something crashes:
- device identifiers, including an advertising identifier;
- product interaction, such as which screens and practice modes are opened;
- purchase history for subscription state;
- crash data, performance data, and other diagnostics;
- coarse, city-level location derived from the network connection.
We do not upload your contacts or personal photos for analytics. Account and synchronized learning data are described separately below.
When you visit holacards.org, Cloudflare and our web server may process technical request data such as IP address, browser and device information, requested page, referrer, campaign parameters, approximate location, and store-button clicks for security, operation, aggregate analytics, and attribution. Store-click events use a random event ID and are not tied to a Hola Cards account.
Third-party services
These services process the data above on our behalf. Each has its own privacy policy:
- Google Firebase — analytics, remote configuration, and push notifications;
- AppMetrica — product and diagnostic analytics;
- Meta — app event measurement;
- Adapty — subscription state;
- Cloudflare — website delivery, security, and web analytics;
- Google Analytics — optional website analytics loaded only after consent;
- Unity Ads / Unity LevelPlay, Google Mobile Ads and Yandex Mobile Ads — advertising in the free version;
- Apple and Google — payment processing for in-app purchases.
- DeepSeek — contextual translation of text from the optional mobile live translator, after explicit permission;
In-app store purchases are handled by Apple and Google. We never receive or store your card details.
Advertising and tracking
The free version may show third-party interstitial ads. Premium removes ads. Advertising and measurement providers may use device or advertising identifiers for ad delivery, attribution, frequency control, fraud prevention, and measurement. On iOS, permission is requested before access to data used for tracking where required.
In mobile release 1.26.7, Hola Cards tells Yandex before the ad service starts that consent to personal-data processing and location collection has not been granted. This does not disable all advertising or the technical processing described above. The iOS tracking choice is separate. Website advertising choices are described in the accounts and website section.
How to delete your data
Uninstalling the app removes everything stored on the device. To request deletion of analytics data associated with your device, write to [email protected] from the address you want us to reply to and include your device platform. We answer deletion requests within 30 days.
Children
Hola Cards is not directed at children under 13, and we do not knowingly collect data from them.
Changes to this policy
If this policy changes we update the effective date at the top of the page. This version is effective 2026-09-26.