Prepwise Privacy Policy

This Privacy Policy describes how Prepwise (we, us, or our) collects, uses, stores, and processes information in connection with the Prepwise mobile application and related services (the Service). By using the Service, you acknowledge the processing of your information as described herein.

I. Information We Collect

While Prepwise does not require traditional account registration, we collect specific data to ensure Service integrity and performance:

• Usage and Progress Data: Course activity, lesson completion, quiz answers, and real-time study metrics.
• Device and Technical Information: Device model, operating system version, Identifier for Vendor (IDFV), and when authorized through the App Tracking Transparency prompt, the Identifier for Advertisers (IDFA).
• Purchase Information: Subscription tier, purchase timestamps, transaction identifiers provided by Apple. Payment card details are NEVER collected or seen by Prepwise.
• Network and Connectivity Data: Connection type and IP address used to optimize content delivery and secure cloud-based features.
• Cloud Storage Data: Study progress and app state synchronized via Apple iCloud under your Apple ID.
• Security and Traceability Data: Invisible digital watermarks uniquely linked to your User ID are embedded in educational materials to prevent unauthorized distribution.
• Diagnostics: Anonymized crash reports and performance metrics to maintain service reliability.

II. App Tracking Transparency (ATT)

On first launch the iOS system displays the App Tracking Transparency prompt asking whether Prepwise may track you across other companies' apps and websites. Your response controls whether your IDFA is shared with our advertising partners.

• If you tap "Allow": your IDFA may be shared with Google Mobile Ads for personalized advertising and with Adapty for subscription attribution.
• If you tap "Ask App Not to Track": your IDFA is not shared. Ads still appear but are contextual (non-personalized).

You may change this choice at any time in Settings, Privacy & Security, Tracking.

III. Third-Party Services and Data Processors

Prepwise uses the following third-party services. Each processor receives only the data categories listed and acts solely on our behalf under a data processing agreement:

• Apple (iCloud, StoreKit 2, App Attest, SKAdNetwork): study progress synchronization, in-app purchase processing, device attestation, privacy-preserving ad attribution. Data categories: User ID, Device ID, Purchase records.
• Firebase (Firestore, Authentication, App Check, Crashlytics, Cloud Functions) by Google: backend data storage for ban list and trace audit log, device integrity verification, crash and performance reporting. Data categories: User ID, Device ID, Crash Data, Diagnostics.
• Google Mobile Ads and Google AdMob: ad serving, impression counting, SKAdNetwork attribution. Data categories: IDFA (only if you authorized ATT), Device ID, IP address.
• Adapty: subscription and entitlement management, paywall analytics. Data categories: Device ID, IDFA (only if you authorized ATT), Purchase History, Subscription status.

We do not sell your personal information to data brokers. We do not use your data to train AI models outside the scope of Service delivery.

IV. Legal Basis for Processing

• Contractual Necessity: To provide the educational content, subscription access, and auto-save features you requested.
• Legitimate Interests: To protect our intellectual property through steganographic tracing, prevent fraud, ensure network security, maintain cloud synchronization, and improve the Service.
• Consent: For personalized advertising via IDFA, granted only through the ATT system prompt and withdrawable at any time in iOS Settings.
• Legal Obligation: To comply with regulatory, tax, and accounting requirements.

V. Data Persistence and Cloud Synchronization

• iCloud Integration: Your progress data is backed up to your personal iCloud storage under your Apple ID.
• Firebase Backend: A minimal subset of data (ban list records, trace audit entries, subscription status) is stored in Firebase Firestore to enforce content protection and manage entitlements.
• User Responsibility: You are responsible for maintaining the security of your Apple ID. Prepwise does not have access to your private iCloud files beyond the specific data containers allocated to our Service.

VI. Data Sharing and Disclosure

We do not sell your personal information. Disclosure is limited to:

• Service Providers: The processors listed in Section III, acting on our behalf under contract.
• Security and Compliance: We may disclose data to comply with legal processes, valid subpoenas, court orders, or to enforce our Membership Integrity Agreement if leaked content is traced back to a specific ID.
• Business Transfers: If Prepwise is involved in a merger, acquisition, or asset sale, your information may be transferred. You will receive notice of any such change.

VII. Your Rights and Data Control

Depending on your jurisdiction you have the following rights:

• General rights: Access and Portability, Deletion and Correction, Opt-Out of Personalized Ads (revoke ATT in iOS Settings), Human Review of automated decisions.
• EU and UK residents (GDPR, UK GDPR): Right to object, restrict processing, lodge a complaint with your national data protection authority.
• California residents (CCPA, CPRA): Right to know, delete, correct, limit use of sensitive personal information, opt out of "sharing" for cross-context behavioral advertising. We do not knowingly sell California residents' personal information.
• Virginia, Colorado, Connecticut, Utah residents: Equivalent rights under applicable state privacy laws.

To exercise any of these rights email support@reply-prepwise.com. We respond within 30 days.

VIII. Children's Privacy

The Service is intended for users aged thirteen (13) and older. We do not knowingly collect personal information from children under 13. If we learn that we have collected information from a child under 13 we will delete it promptly. Parents who believe their child under 13 has provided information should contact support@reply-prepwise.com. Users aged 13 to 17 must use the Service under the supervision of a parent or legal guardian.

IX. Data Retention and Security

Retention Periods:

• Active progress and subscription data: retained while your subscription is active plus 90 days after cancellation.
• Ban list entries and trace audit logs: retained 7 years for content-protection enforcement.
• Crash and diagnostic logs: anonymized within 90 days, aggregated after 24 months.
• IDFA (if authorized): not persisted on our servers beyond 30 days.

Security Measures: Industry-standard TLS 1.2+ encryption for data in transit, AES-256 for data at rest, Firebase App Check device attestation, Apple App Attest for release builds, rate-limited API endpoints, and continuous monitoring.

Breach Notification: In the event of a personal data breach posing a risk to your rights, we will notify you and relevant supervisory authorities within the timeframes required by applicable law (72 hours for GDPR).

X. International Data Transfers

Your information may be processed in the United States and other countries where our processors operate. We implement Standard Contractual Clauses (SCCs) approved by the European Commission and UK Addendum where required.

XI. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified through:

• A notice in the app prior to the change taking effect.
• An update to the "Last updated" date at the top of this Policy.
• Where required by law, an email or in-app opt-in consent prompt.

Continued use of the Service after the effective date of a revised Policy constitutes acceptance.

XII. Contact Information

Website: https://prepwiselearning.com
Email: support@reply-prepwise.com

Data Controller: Prepwise
EU/UK Representative: Available on request via the contact email above.