Privacy Policy

Who we are

Cuel ("we", "us", "our") provides the Cuel app for iPhone and iPad and the website at cuel.app, and is the data controller for the personal data described here. You can reach us any time at support@cuel.app.

The information we process

Account information: when you sign in with Apple or create an account, we process an email address and a user identifier so your content stays in sync across your devices.

Content you capture: the text you write, the audio you record, and the cards, reminders, notes, and personal knowledge Cuel creates from them.

Voice input: when you capture by voice, the audio is transmitted so it can be transcribed into text.

Learning activity: your review ratings and progress, used to time your practice.

Purchases: your subscription and entitlement status, so Premium features work across your devices. Apple processes payments, and we never receive your card details.

Private items: entries you choose to mark as private are stored encrypted (see Security).

Diagnostics: limited technical and error information, to keep the service reliable.

How we use your information, and our legal bases

To provide Cuel's core features, including understanding your input, creating learning material, scheduling reviews, and syncing your content. Our basis is performance of our contract with you.

To operate subscriptions, honor your entitlements, and keep the billing records the law requires. Our basis is our contract with you and our legal obligations.

To keep Cuel secure, prevent abuse, diagnose problems, and improve reliability. Our basis is our legitimate interest in running a safe, working service.

To send optional reminders, learning prompts, and any marketing you ask for. Our basis is your consent, which you can withdraw at any time.

We do not sell your personal information, and we do not use your content for advertising or to train AI models.

AI processing

Cuel uses artificial intelligence to interpret what you capture and to generate learning material such as flashcards. To do this, the relevant text (and, for voice, its transcription) is sent to our AI provider, OpenAI, which processes it on our behalf only to return the result to you.

Your content is not used by our AI provider to train its models, and we do not train or fine-tune any model on your personal content.

Cuel also schedules automatically when to bring each item back, based on your past ratings. This times your practice; it does not make any decision that has a legal or similarly significant effect on you.

AI can be wrong. Material Cuel generates may be inaccurate or incomplete, so review it before you rely on it.

Voice input

When you capture by voice, the audio is sent to a speech-to-text provider (OpenAI) to be transcribed, then handled like your other content. Voice capture is optional: you can type instead at any time.

Service providers we rely on

We keep the number of providers small and share only what each one needs to do its job for Cuel: OpenAI, to interpret your input, generate learning material, and transcribe voice; RevenueCat, to manage your subscription status across your devices; Apple, for Sign in with Apple and to process your purchases; and a cloud hosting provider, to store and sync your content securely.

Each provider acts on our instructions, under contract, and only to perform its function for Cuel.

International transfers

Some providers process data outside your country, including outside the EU. Where that happens, we rely on recognised safeguards such as the EU Standard Contractual Clauses and equivalent mechanisms, so your data keeps an equivalent level of protection. Ask us at support@cuel.app for more detail.

How long we keep your data, and deletion

We keep your content while your account is active, and you can edit, archive, or delete individual items at any time.

You can delete your entire account from inside the app. When you do, your account and associated content are removed from our systems without undue delay, and any residual copies in backups are deleted within 30 days. If you signed in with Apple, you can also stop using Sign in with Apple for Cuel at any time in your Apple Account settings.

We keep the limited records we are legally required to retain, such as transaction records for tax and accounting, only for as long as the law requires.

Your rights

Depending on where you live (for example, under the EU GDPR), you have rights over your personal data. These include the right to access it, correct it, delete it, restrict or object to how we use it, receive a copy in a portable form, and withdraw any consent you gave without affecting processing that already happened. You also have the right to complain to your local data protection authority.

To exercise any of these, email support@cuel.app. We respond within the time the law requires, normally within one month.

Cookies

Our website uses one functional cookie to remember your language. We do not use tracking or advertising cookies, and the app itself does not use cookies.

Security

We protect your data in transit and at rest. Items you mark as private are stored encrypted on our servers, so their contents are not readable in plain form, and access to them in the app is protected with Face ID or your device passcode. No system is perfectly secure, but we work hard to keep your data safe and to respond quickly if something goes wrong.

Children

Cuel is not directed to children. You must be at least 16 to use Cuel, and we do not knowingly collect data from children under 16. If you believe a child has given us their data, contact support@cuel.app and we will remove it.

Changes to this policy

We may update this policy as Cuel evolves. When changes are material, we will update the date above and, where appropriate, tell you in the app.

Contact

For any privacy question, or to exercise your rights, email support@cuel.app.