Privacy Policy

Willys Flashcard App · Effective Date: June 18, 2026 · Last Updated: June 18, 2026

This Privacy Policy explains how Coastal Dune Labs LLC (“we,” “us,” or “our”) handles information in Willys Flashcard App (“Willys” or the “App”), a flashcard study application for iPhone, iPad, and Mac. In short: your data stays on your device, we operate no servers that receive or store it, the App’s AI features run entirely on your device, and we use no analytics, advertising, or tracking.

1. Information We Collect

1.1 Data You Create in the App

Willys has no accounts and no login. The flashcards, decks, tags, notes, images, audio recordings, documents you import, and study and review history you create (“Your Content”) are stored locally on your device using Apple’s on-device storage frameworks. We do not operate servers that receive or store Your Content, and we cannot access it.

1.2 Audio Recordings

If you record audio to attach to a card, the recording is saved locally alongside your cards. Audio is never uploaded to us or to any third party.

1.3 Website Contact Form

If you contact us through our website, we collect the name, email address, and message you provide. This information is processed through Netlify Forms and is used solely to respond to your inquiry.

1.4 Information We Do Not Collect

We do not use third-party analytics services, advertising frameworks, data brokers, or cross-app tracking, and we do not request App Tracking Transparency permission because we do not track you. Our Apple privacy manifest declares no tracking and no data collection.

2. On-Device AI Features

Willys can generate flashcards from text and PDFs using Apple Intelligence, which runs entirely on your device. Any content you provide for generation — including PDF text and prompts — is processed locally and is never sent to Coastal Dune Labs or any third party. There is no API key, no cloud account, and no external AI service involved on our part. Apple’s on-device intelligence features are governed by Apple’s own privacy terms.

3. How Your Data Is Stored

3.1 On Your Device

By default, Your Content is stored only on your device and protected by your device’s built-in security features. We do not have access to data stored on your device.

3.2 Optional iCloud Sync

If you enable iCloud sync, Your Content is synchronized across your devices through your own private iCloud account using Apple’s CloudKit. This data resides in your personal iCloud database, accessible only to your Apple ID. Coastal Dune Labs cannot access it, and you can disable sync at any time. Data syncs are managed by Apple and subject to Apple’s privacy and security practices.

3.3 Backups You Export

Willys lets you export a backup file containing Your Content. These files are saved wherever you choose and remain under your control; we never receive them. Because a backup contains your data, keep exported files secure.

4. Device Permissions

Willys requests permissions only when you use the related feature, and only for on-device functionality:

Microphone — only if you record audio to attach to a card. Recordings are stored locally and are never transmitted to us.
Notifications — only if you enable study reminders. Reminders are scheduled locally on your device; we do not send push notifications from any server.
Files — to import PDFs or documents you select, and to read or write backup files you choose. We access only the files you pick.

5. Third-Party Services

Willys itself contains no third-party analytics, advertising, or tracking SDKs. The only third parties involved are:

Apple — provides the App Store, processes subscription purchases and manages billing, and provides optional iCloud/CloudKit sync and on-device Apple Intelligence. Your use of these is governed by Apple’s terms and privacy policy.
Netlify — hosts our website and processes submissions from our contact form.

We do not sell, rent, or share your information with third parties for marketing purposes.

6. Data Retention and Deletion

We do not retain your personal data because we do not collect it. Your Content persists on your device, and in your iCloud account if you enable sync, until you delete it. You can delete individual records within the App or remove all local app data by uninstalling Willys. Contact form submissions are retained only as long as necessary to resolve your inquiry.

7. Children’s Privacy

Willys is suitable for users of all ages, including students. Because the App collects no personal information, has no accounts, displays no advertising, and transmits no user content to us or any third party, it does not knowingly collect personal data from anyone, including children under 13. We do not build profiles or track users of any age.

8. Your Rights and Choices

Because Your Content stays on your device — and, if you enable it, in your own iCloud account — you remain in control of it at all times. You can view, edit, export, or delete any of Your Content directly within the App. Since we do not collect or hold your personal data, there is no personal data on our side for us to access, correct, or delete. Depending on where you live (for example, under the GDPR or CCPA/CPRA), you may have additional rights regarding personal data; you may contact us with any questions.

9. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the “Last Updated” date at the top of this page. Continued use of the App after changes are posted constitutes acceptance of the updated policy.

10. Contact Us

If you have questions about this Privacy Policy, please contact us through our contact page.

Coastal Dune Labs LLC, USA