Privacy Policy
Protecting your personal data is important to us. This policy informs you in accordance with the General Data Protection Regulation (GDPR) about which personal data are processed when you use Atrio, for what purpose, and on what legal basis.
Last updated: 30 September 2026
Courtesy translation
This page is an English courtesy translation of our privacy policy. The German version at /datenschutz is the legally binding version.Contents of this policy
- Controller
- Overview of the processing
- Hosting
- Server log files
- Cookies and local storage
- Registration and account
- Learning content
- AI-assisted import
- Voluntary feedback survey
- Waitlist and email delivery
- Database
- Processors at a glance
- Security measures
- Retention periods and deletion
- Your rights as a data subject
- No automated decision-making
- Changes to this privacy policy
- Contact for privacy-related matters
1.Controller#
The controller within the meaning of the GDPR and other national data protection laws is:
Christoph Beer
Barbara-Kayser-Straße 1
70825 Korntal-Münchingen, Deutschland
Email: atrio@christophbeer.de
2.Overview of the processing#
Atrio is a study tool that lets you turn notes, scripts, PDFs, and images into flashcards and learn with spaced repetition. The application processes personal data only to the extent necessary to operate the service and provide its features.
We do not process any data on the basis of consent, do not use any tracking or advertising cookies, and do not sell any data. The processing is based on Art. 6(1)(b) GDPR (performance of a contract) and Art. 6(1)(f) GDPR (legitimate interest in a secure, stable, and functional service).
3.Hosting#
This website is hosted by Vercel Inc. (340 S Lemon Ave #4133, Walnut, CA 91789, USA). When the website is accessed, Vercel processes technically required data (in particular IP address, time, and the pages accessed). This serves the provision, security, and stability of the service. The legal basis is Art. 6(1)(f) GDPR.
Vercel processes data partly in data centers outside the EU (in particular in the USA). Vercel is certified under the EU-US Data Privacy Framework, and where required we additionally use the EU Standard Contractual Clauses. Further information can be found in the Vercel privacy policy.
File storage (Vercel Blob)
With the AI import and with uploads, the uploaded files (images, PDFs, CSV or text files) are transmitted to Vercel's object storage (Vercel Blob) and temporarily cached there for processing. The files may contain learning content or other information that you provide yourself. This happens exclusively to carry out the requested import function. The legal basis is Art. 6(1)(b) GDPR.
This data is also processed on Vercel's servers (among others in the USA) and falls under the guarantees mentioned above (EU-US Data Privacy Framework or Standard Contractual Clauses). Only upload files that you have created yourself or whose processing you are permitted to carry out.
Usage statistics (Vercel Web Analytics)
We use Vercel Web Analytics to understand how the website is used and to improve the service. The collection is active in the base layout component and therefore applies to all pages of Atrio. Page views as well as aggregate information about referrer, device, browser language, resolution, and approximate location are collected. IP addresses are not stored permanently; Vercel Web Analytics does not use persistent visitor IDs, advertising IDs, or fingerprinting and does not set profiling cookies. The analysis is carried out exclusively in aggregate form; individual persons cannot be inferred from it, and the data are not shared with third parties for advertising purposes. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in a stable and usable service). Collection can be restricted via enabled ad blockers, your browser's settings, or your browser's Do Not Track signal.
Spam protection (Cloudflare Turnstile)
To protect registration, the waitlist, the feedback survey, and guest imports from automated abuse (bots), we use the Cloudflare Turnstile service (Cloudflare Inc., 101 Townsend St, San Francisco, CA 94107, USA). When the protection widget loads, your IP address and technical information about your browser are transmitted to Cloudflare and processed there to assess whether the request comes from a human being. We do not transmit any further personal data to Cloudflare. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in defending against abuse and spam). Cloudflare processes data in the USA on the basis of the EU-US Data Privacy Framework or the EU Standard Contractual Clauses. Further information can be found in the Cloudflare privacy policy.
4.Server log files#
When the website is accessed, the hosting provider automatically collects information in so-called server log files that your browser transmits:
- IP address of the requesting device
- Date and time of the request
- Page / URL accessed
- HTTP status code and amount of data transferred
- Browser type, browser version, and operating system
- Referrer URL (previously visited page)
These data are not merged with other data sources and are not used to identify individuals. They serve the delivery of content, the ensuring of IT security, and error analysis. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in secure and stable operation). The log files are stored for as long as necessary for these purposes and then deleted.
5.Cookies and local storage#
Session cookie “ar_session”
When you sign in, we set a technically necessary session cookie so that you can stay signed in. It does not contain a plaintext password value; only a hash value of the token is stored server-side. The cookie is valid for up to 30 days and then automatically expires. The legal basis is Art. 6(1)(b) GDPR (provision of the account or the signed-in features).
Local storage (localStorage / IndexedDB)
To display settings and provide offline features, your browser stores data locally on your device:
- “ar-theme” and “ar-accent” – your display and color preferences
- “guest_cards” – cards created in guest mode (they remain exclusively on your device)
- “atrion_anon_id” – a random identifier generated on your device so that your payment or interest signal can be assigned and duplicate submissions detected
- Offline cache (IndexedDB) – a local copy of your learning content for offline use
- Study session cache – a temporary store for currently running study sessions
The settings, guest cards, and caches remain on your end device and are not transmitted to us or to third parties. It is different for “atrion_anon_id”: This identifier is transmitted to our server together with your payment or interest signal and stored in the database. It serves solely for assignment and protection against abuse and duplicate submissions, not for profiling or tracking your learning behaviour; no account is linked to the identifier as long as you are not signed in. You can delete the local storage at any time using your browser's functions.
We do not use any cookies for advertising, tracking, or profiling by third parties. The web analytics collection described in section 3 is carried out without profiling; in practice it can be disabled via ad blockers and does not set any identifying cookie.
6.Registration and account#
To use the study features you can create an account. In the process we process the following information:
- Username (publicly visible as your display name)
- Email address (for account and support purposes)
- Password – stored exclusively as a cryptographic hash (bcrypt)
- Time of registration
- Account settings (e.g. daily goals, reminder rate, color scheme)
The processing serves the provision of your account and the use of the signed-in features. The legal basis is Art. 6(1)(b) GDPR.
7.Learning content#
Your learning content – flashcards, decks, folders, exam dates, subjects, and your review statistics (spaced repetition) – is stored to enable your study workflow across all devices. The legal basis is Art. 6(1)(b) GDPR.
If you share a deck via the community feature, selected content (deck title, cards) as well as your username become visible to other users as author information and can be found via search. Therefore do not share cards that contain personal or confidential information. You can revoke the sharing at any time; afterwards the deck is no longer accessible to others.
Import from flashcard study pages
Atrio offers public flashcard study pages for university subjects. If, as a signed-in user, you take over such a deck into your account, a conversion row is stored – your user ID, the ID of the accessed flashcard study page along with its slug, the ID of the created deck, and the timestamp. The sole purpose is to evaluate which topics and pages lead to successful use. The legal basis is Art. 6(1)(b) GDPR (performance of the service including optimization).
For this conversion tracking no cookies are used and no visitor IDs, IP addresses, device fingerprints, or other identifiers of guest visitors are stored. For the flashcard study pages we do not run our own click or page-view counting beyond the general web statistics; page views are collected in aggregate by the web analytics described in section 3. The evaluation of the conversions is carried out exclusively in aggregate form (number of conversions per period and per slug); individual user IDs are not disclosed for this purpose. Conversion data are included in the data export.
If a takeover is only completed after registration, Atrio remembers the intended action locally in your browser for at most 30 minutes. Only the deck ID, the ID of the flashcard study page, the return address within Atrio, and the timestamp are stored. This information does not leave your device. The entry is deleted as soon as the takeover is completed or as soon as you visit the registration page again and the entry is older than 30 minutes; no automatic deletion at a fixed time takes place. As long as you are not signed in, the entry is not linked to your account.
The conversion data are stored for as long as the row exists in the database; the row contains your user ID and is not automatically deleted along with the account. No automatic deletion after a fixed period takes place. You can view the data at any time via the data export and request their deletion by emailing atrio@christophbeer.de; the deletion also affects the associated copied deck, provided it does not contain its own learning-history data. Automatic self-service deletion via the settings is not available.
It is different for the AI import for non-signed-in visitors: For abuse protection and rate limiting, a pseudonymous device marker (SHA-256 hash of IP address, user agent, and Accept-Language) is used there. Even then no IP address is stored in plaintext, but the marker can be linked to a person. Details in section 8.
8.AI-assisted import#
Via the “AI import” feature you can upload texts, images, and PDF pages to automatically generate flashcards from them. For this feature to work, your uploaded content is transmitted together with a processing request to an AI service:
- OpenRouter (openrouter.ai) – the AI service through which the processing runs: primarily via the provider InferenceNet, and automatically via the provider DeepInfra if that provider is unavailable (no training use and no storage of prompt data).
The transmitted data are used solely to generate your flashcards and are not used by us for other purposes. The legal basis is Art. 6(1)(b) GDPR (provision of the requested feature). Please only upload material that you have created yourself or that you are entitled to have processed.
To avoid duplicate costs for identical imports, responses from the AI services are placed in a cache in our database. What is stored is the response generated by the model as text. This means: The image file itself is not stored, but the content derived from your material very much is. In the lossless import modes “Vocabulary list” and “Handwriting”, the stored response contains a verbatim transcription of your material; in card recognition, recognized topics and phrasings are also taken over.
The cryptographic checksum (SHA-256) of the complete request to the AI model serves as the key. The cache is not bound to your account. If exactly the same file with the same settings is imported again, the already stored response can be reused – also by another person. The stored entry can be retrieved for at most 24 hours and is additionally cleaned up nightly.
The providers mentioned may process the data in data centers outside the EU to fulfill the processing order. Where required, this is done on the basis of the EU-US Data Privacy Framework or the EU Standard Contractual Clauses. Further information can be found in the OpenRouter privacy policy.
Note on AI-generated content
Flashcards are generated by an AI model. Content may contain errors. Review the generated cards before studying and before using them for exams. This does not constitute automated decision-making within the meaning of Art. 22 GDPR.9.Voluntary feedback survey#
As part of product development, we may voluntarily ask for your assessment, e.g. of features or of a possible pricing model. If you take part, we store your answers in connection with your account:
- Your assessment (e.g. Yes / Maybe / No)
- A price indication you provided (optional)
- A free-text comment you entered (optional)
Participation is voluntary. You can leave out any information you do not want to provide. The data are used solely to improve the product. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in product development) or your voluntary provision of the information. You can request deletion at any time.
10.Waitlist and email delivery#
On the pricing page you can join a waitlist for the paid Endspurt plan. In the process we process:
- Your email address – for the invitation to the first founders wave
- optionally your exam date and a label (e.g. “Mathe LK”)
- optionally a price indication you provided and a free-text comment
- your waitlist position as well as the status (signed up / invited / converted)
The legal basis is your sign-up as a request to conclude a (later) contract (Art. 6(1)(b) GDPR). Invitations and information are sent by email via Resend Inc. (USA). Transmissions to the USA take place on the basis of the EU-US Data Privacy Framework or the EU Standard Contractual Clauses.
You can request removal from the waitlist and deletion of your email address at any time via the contact channels listed below.
11.Database#
Your account data and learning content are stored in a managed cloud database (libsql/Turso), which may be replicated across multiple locations for high availability. Processing may therefore take place outside the EU. Where required, the transmission is based on appropriate safeguards (EU Standard Contractual Clauses or adequacy decisions).
Access to your data is held exclusively by the system itself and the controller. There is no disclosure to third parties for advertising purposes.
12.Processors at a glance#
For the processing described in this policy we use the following processors (Art. 28 GDPR). They process data exclusively on our instructions and only to the extent necessary for the respective purpose. Where data are transmitted to third countries (in particular the USA), this is done on the basis of the EU-US Data Privacy Framework or the EU Standard Contractual Clauses.
- Vercel Inc. (USA) – hosting of the website, object storage (Vercel Blob) for uploaded files, and web analytics (usage statistics)
- Turso (United Kingdom) – managed libsql database for account data and learning content
- OpenRouter (USA) – AI-assisted processing during import (primarily InferenceNet, automatic fallback DeepInfra)
- Cloudflare Inc. (USA) – spam protection (Turnstile) for registration, waitlist, surveys, and guest imports
- Resend Inc. (USA) – sending emails, e.g. waitlist invitations
13.Security measures#
We take technical and organizational measures to protect your data against loss, misuse, and unauthorized access:
- Encrypted transmission via TLS/HTTPS
- Passwords are stored exclusively as a bcrypt hash
- Session tokens are stored only as a hash (SHA-256) in the database
- Rate limiting and CSRF protection on the API endpoints
- Access rights according to the principle of least privilege
14.Retention periods and deletion#
Your data are stored only for as long as necessary for the purposes stated above or as required by statutory retention periods.
- Account data and learning content: for as long as your account exists. Account deletion is carried out on your request via the contact channels listed below (there is currently no automatic deletion function in the account).
- Session data: until the session expires (max. 30 days).
- Server log files: only as long as necessary for security and error analysis.
- Source files uploaded for the AI import: for the duration of the processing in Vercel Blob; automatic deletion does not currently take place. You can request deletion at any time.
- Cache for AI responses: stored entries can be retrieved for at most 24 hours, after which they are additionally cleaned up nightly. The cache contains content derived from your material, not the image file itself. Details in section 8.
- Conversion data from flashcard study pages: for as long as the corresponding database row exists. They are not automatically deleted with the account, are included in the data export, and are deleted on request.
If you want to delete your account, write to us via the contact channels listed below. We will carry out a deletion without undue delay.
15.Your rights as a data subject#
You have the following rights regarding your personal data:
- Access to the data processed by us (Art. 15 GDPR)
- Rectification of incorrect data (Art. 16 GDPR)
- Deletion of your data (Art. 17 GDPR)
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR) – you can download your data at any time in the “Settings” section as a JSON file
- Objection to the processing (Art. 21 GDPR)
- Complaint to a data protection supervisory authority (Art. 77 GDPR)
To exercise these rights, an informal message to the email address mentioned above is sufficient. The supervisory authority responsible for you depends on your federal state or place of residence.
16.No automated decision-making#
We do not use any procedures for automated decision-making including profiling within the meaning of Art. 22 GDPR that would have legal effect for you or similarly affect you.
17.Changes to this privacy policy#
We reserve the right to adapt this privacy policy so that it always complies with current legal requirements or to reflect changes to our services. The version published at the time applies. You can find the date of the last update at the top of this page.
18.Contact for privacy-related matters#
For questions about the processing of data, to exercise your rights, or if you have concerns about the processing of your data, contact us at any time:
Christoph Beer
Email: atrio@christophbeer.de
For privacy-related questions you can also reach us via the Imprint page.