MicroLearning

# Privacy Policy **Last Updated: January 2, 2026** **APP DEV MASTERS LTD** ("we", "us", "our", or the "Company") operates the MicroLearning mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. --- ## 1. Data Controller **Company name:** APP DEV MASTERS LTD **Company number:** 14989815 **Email:** info@appdevmasters.com For residents of the European Economic Area (EEA), APP DEV MASTERS LTD is the data controller responsible for your personal data. --- ## 2. Information We Collect ### 2.1 Information You Provide **Account Information:** - Email address (provided via Sign in with Apple, if you choose to share it) - Display name (provided via Sign in with Apple, if you choose to share it) - User ID (automatically generated unique identifier) **User-Generated Content:** - Topics of interest you select for lessons - Custom categories you create - Lesson preferences (language, difficulty) - Notification preferences and scheduling settings ### 2.2 Information Collected Automatically **Device and Technical Information:** - Device type and model - Operating system version - App version - Timezone - Push notification token (FCM token) for delivering notifications **Usage Information:** - Lessons generated and completed - Quiz attempts and scores - Session data (app opens, duration) - Feature interactions and preferences - Subscription status ### 2.3 Information We Do NOT Collect - Location data - Contacts or address book - Camera or microphone data - Health or fitness data - Financial account information (payment processing is handled by Apple) --- ## 3. How We Use Your Information We use the information we collect to: | Purpose | Legal Basis (GDPR) | |---------|-------------------| | Provide and maintain the App | Performance of contract | | Generate personalized micro-lessons | Performance of contract | | Deliver scheduled lessons and notifications | Performance of contract | | Process subscriptions and credits | Performance of contract | | Send service-related communications | Performance of contract | | Improve and optimize the App | Legitimate interest | | Analyze usage patterns and trends | Legitimate interest | | Detect and prevent fraud or abuse | Legitimate interest | | Comply with legal obligations | Legal obligation | --- ## 4. Third-Party Services We use the following third-party services to operate the App: ### 4.1 Firebase (Google LLC) - **Purpose:** Authentication, database storage, cloud functions, push notifications - **Data shared:** User ID, email, display name, lesson data, preferences, FCM token - **Privacy Policy:** https://firebase.google.com/support/privacy - **Data location:** United States (with EU Standard Contractual Clauses) ### 4.2 Mixpanel Inc. - **Purpose:** Analytics and usage tracking - **Data shared:** User ID, app version, device info, usage events - **Privacy Policy:** https://mixpanel.com/legal/privacy-policy/ - **Data location:** United States (with EU Standard Contractual Clauses) ### 4.3 OpenAI, L.L.C. - **Purpose:** AI-powered lesson generation - **Data shared:** Topics you request for lesson generation (no personal identifiers) - **Privacy Policy:** https://openai.com/privacy - **Data location:** United States - **Note:** Topics are processed server-side; no direct connection from your device ### 4.4 Apple Inc. - **Purpose:** Authentication (Sign in with Apple), in-app purchases - **Data shared:** Authentication tokens, purchase transactions - **Privacy Policy:** https://www.apple.com/legal/privacy/ --- ## 5. Data Retention We retain your personal data for as long as your account is active or as needed to provide you with the App's services. | Data Type | Retention Period | |-----------|-----------------| | Account information | Until account deletion | | Lesson history | Until account deletion | | Quiz attempts | Until account deletion | | Analytics data | 24 months from collection | | Push notification tokens | Until account deletion or token refresh | When you delete your account, we permanently delete all associated personal data within 30 days, except where retention is required by law. --- ## 6. Your Rights Under GDPR If you are located in the EEA, UK, or Switzerland, you have the following rights: ### 6.1 Right of Access You have the right to request a copy of the personal data we hold about you. ### 6.2 Right to Rectification You have the right to request correction of inaccurate personal data. ### 6.3 Right to Erasure ("Right to be Forgotten") You have the right to request deletion of your personal data. You can delete your account directly in the App under **Settings > Account > Delete Account**. ### 6.4 Right to Restrict Processing You have the right to request restriction of processing of your personal data. ### 6.5 Right to Data Portability You have the right to receive your personal data in a structured, machine-readable format. ### 6.6 Right to Object You have the right to object to processing of your personal data based on legitimate interests. ### 6.7 Right to Withdraw Consent Where processing is based on consent, you have the right to withdraw consent at any time. ### 6.8 Right to Lodge a Complaint You have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO): https://ico.org.uk To exercise any of these rights, contact us at: **info@appdevmasters.com** --- ## 7. International Data Transfers Your information may be transferred to and processed in countries outside your country of residence, including the United States. When we transfer data outside the EEA, we ensure appropriate safeguards are in place, including: - EU Standard Contractual Clauses - Adequacy decisions by the European Commission - Binding Corporate Rules where applicable --- ## 8. Data Security We implement appropriate technical and organizational measures to protect your personal data, including: - Encryption of data in transit (TLS/SSL) - Encryption of data at rest - Firebase Security Rules to restrict data access - Regular security audits and updates - Access controls limiting data access to authorized personnel only However, no method of transmission over the Internet or electronic storage is 100% secure. --- ## 9. Children's Privacy The App is not intended for children under 13 years of age (or 16 in certain jurisdictions). We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at **info@appdevmasters.com**. --- ## 10. Push Notifications If you enable push notifications, we use Firebase Cloud Messaging to deliver scheduled lesson reminders and updates. You can manage notification preferences in: - **App Settings > Notifications** - **Device Settings > Notifications > MicroLearning** --- ## 11. In-App Purchases All purchases are processed through Apple's App Store. We do not collect or store payment information. Apple's payment privacy policy applies: https://www.apple.com/legal/privacy/ --- ## 12. Analytics and Opt-Out We use Mixpanel for analytics to improve the App. You can opt out of analytics tracking by: 1. Enabling "Limit Ad Tracking" in your iOS device settings 2. Contacting us at **info@appdevmasters.com** to request analytics opt-out --- ## 13. Changes to This Privacy Policy We may update this Privacy Policy from time to time. We will notify you of any material changes by: - Posting the new Privacy Policy in the App - Updating the "Last Updated" date at the top Your continued use of the App after changes constitutes acceptance of the updated Privacy Policy. --- ## 14. Contact Us If you have any questions about this Privacy Policy or our data practices, please contact us: **APP DEV MASTERS LTD** Company number: 14989815 Email: **info@appdevmasters.com** For GDPR-related inquiries, please include "GDPR Request" in the subject line. --- ## 15. Legal Basis Summary (GDPR Article 6) | Processing Activity | Legal Basis | |--------------------|-------------| | Account creation and authentication | Contract performance | | Lesson generation and delivery | Contract performance | | Subscription management | Contract performance | | Push notifications (service-related) | Contract performance | | Analytics and improvements | Legitimate interest | | Fraud prevention | Legitimate interest | | Marketing communications | Consent (if applicable) | | Legal compliance | Legal obligation | --- *This Privacy Policy is effective as of January 2, 2026.*