Privacy Policy
Version {{VERSION}} of {{DATE}}. Text in braces must be completed; "Note:" paragraphs must be removed before publication.
1. In short
- Without an account, your progress stays on your phone: we never receive it.
- With an optional account, we process your email address and progress to sync your devices, hosted in the European Union.
- No ads, no trackers, no sale of data.
- You can export your data and delete your account from within the app.
2. Controller
{{COMPANY_NAME}}, {{LEGAL_FORM}}, {{ADDRESS}}, registration {{RCS}}. Privacy contact: {{PRIVACY_EMAIL}}. {{Data Protection Officer: name and contact, if appointed.}}
3. Data, purposes, legal bases and retention
| Purpose | Data | Legal basis (GDPR Art. 6) | Retention |
|---|---|---|---|
| Offline study, no account | Progress and settings, stored on the device only | No processing by the Publisher | Until uninstall or deletion by the user |
| Account creation and management | Email address, account ID, anonymised Apple ID (Sign in with Apple), creation date | Performance of contract (6(1)(b)) | Life of the account; deleted {{within 30 days}} of the request; accounts inactive for {{3 years}} deleted after notice |
| Progress sync | Answers, flashcard reviews, sections read, exams, settings, timestamps | Performance of contract (6(1)(b)) | Life of the account |
| Purchases and entitlements | RevenueCat user ID, products purchased, dates, entitlement status, store country | Performance of contract (6(1)(b)); legal accounting obligations (6(1)(c)) | Life of the account; accounting records {{10 years}} |
| Crash fixing | Crash report, stack trace, device model, OS and app versions, with no email or user ID | Legitimate interest (6(1)(f)): app stability | {{90 days}} |
| Support and error reports | Email, message content | Legitimate interest (6(1)(f)) | {{3 years}} after last contact |
| Audience measurement | {{To be decided: none, consent-exempt tool (CNIL configuration) or opt-in}} | {{Legitimate interest if exempt / consent (6(1)(a))}} | {{13 months max}} |
No automated decision producing legal effects is made. Readiness indicators are computed on your device for your own use.
4. Recipients and processors
| Recipient | Role | Location | Safeguards |
|---|---|---|---|
| Supabase, Inc. (hosted on AWS, EU region: Ireland) | Processor: database, authentication | European Union; possible support access from the United States | Data processing agreement (DPA); {{standard contractual clauses (SCCs) / EU-US Data Privacy Framework (DPF)}} for any access outside the EU |
| RevenueCat, Inc. | Processor: purchases and entitlements | United States | DPA; {{DPF if certified at publication, otherwise SCCs 2021/914}}; supplementary measures |
| Functional Software, Inc. (Sentry) | Processor: crash reports | {{EU data region if selected, otherwise United States}} | DPA; {{DPF / SCCs}}; minimised data (no user ID, IP not stored) |
| Apple Inc., Google LLC | Independent controllers for payment, distribution and Sign in with Apple | Per their policies | Their privacy policies |
| {{Transactional email provider (magic link)}} | Processor | {{EU}} | DPA |
Note: check each US provider's DPF certification and the Sentry region actually configured at publication.
No data is sold or used for advertising.
5. Security
Encryption in transit (HTTPS), row-level access control in the database, session tokens stored in the device's secure storage (Keychain, Keystore), restricted admin access, encrypted backups. App content is verified by digital signature.
6. Your rights
You have the rights of access, rectification, erasure, restriction, objection (for processing based on legitimate interest) and portability, and, under French law, the right to set instructions for your data after death.
- Delete your account: Settings › Account › Delete my account. Server data is erased and deletion is confirmed to you. Also available at {{ACCOUNT_DELETION_URL}}. Subscriptions are cancelled separately in your Apple or Google account.
- Export: Settings › Export my progress (readable file, with or without an account).
- Other requests: {{PRIVACY_EMAIL}}. We reply within one month.
You may lodge a complaint with the French data protection authority (CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr) or the authority of your country of residence.
7. App permissions
| Permission | When | Why |
|---|---|---|
| Notifications | Only when you turn on the daily reminder | Local reminder scheduled on the device; no push server |
No access to location, contacts, camera, microphone or photos. No advertising identifier.
8. Minors
The app is intended for adult professionals. {{Minimum age to be confirmed.}}
9. Changes
Material changes are announced in the app before they take effect. The current version and its date appear at the top of this document.