Privacy Policy

Diffused Innovations Ltd ("we", "us", or "our") operates the BritPass: Life in the UK Test mobile application and https://britpasstestapp.com website (together, the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

1. Information We Collect

1.1 Information You Provide

We may collect information you provide directly to us, such as:

• Email address (if you contact us or subscribe to updates)
• Name (if provided through contact forms)
• Any other information you choose to provide

1.2 Automatically Collected Information

When you use our services, we automatically collect certain information, including:

• Device information (device type, operating system, unique device identifiers)
• Usage data (test scores, study progress, time spent in app, features used)
• IP address and approximate location (country/city level)
• Browser type and version
• Referring website or source
• Crash reports and performance diagnostics

1.3 In-App Purchase Information

If you make a purchase (one-time payment or subscription) through the app:

• Payment processing is handled entirely by Apple App Store or Google Play Store
• We do not collect or store your credit card or payment information
• We receive a transaction receipt from the app store to verify your purchase
• We store information about which features you have unlocked
• Subscription status and renewal dates are managed by the respective app store

1.4 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities. These help us improve our services and provide a better user experience.

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services
• Respond to your comments, questions, and requests
• Send you technical notices and support messages
• Monitor and analyse trends, usage, and activities
• Detect, investigate, and prevent fraudulent transactions and abuse
• Personalise and improve your experience
• Comply with legal obligations

3. Legal Basis for Processing (GDPR)

If you are in the European Economic Area (EEA) or United Kingdom, we process your personal data based on:

• Consent: Where you have given us explicit consent
• Contract: Where processing is necessary to provide our services
• Legitimate Interests: Where we have a legitimate business interest that does not override your rights
• Legal Obligation: Where we are required by law to process your data

4. Subscriptions and Payments

BritPass: Life in the UK Test offers both one-time purchases and weekly subscription options. All purchases are processed through the Apple App Store or Google Play Store.

4.1 Payment Processing

• All payments are handled by Apple or Google - we never see your payment details
• Your billing information is subject to the privacy policy of Apple or Google
• We receive a receipt token to verify your purchase status

4.2 Subscription Management

• Weekly Subscriptions: Automatically renew every 7 days unless cancelled
• Cancellation: Manage subscriptions through your Apple ID or Google Play account settings
• Refunds: Processed according to Apple App Store or Google Play Store refund policies
• You can cancel at any time before the next renewal date
• Cancellation takes effect at the end of the current billing period

4.3 Free Trial (if applicable)

If we offer a free trial, you will be charged automatically when the trial ends unless you cancel before the trial period expires. The trial period and subscription price will be clearly displayed before you confirm your purchase.

5. Data Sharing and Disclosure

We do not sell your personal information. We may share your information with:

• App Store Providers: Apple and Google receive transaction data when you make purchases
• Service Providers: Third parties who perform services on our behalf (hosting, analytics, customer support, crash reporting)
• Analytics Providers: We may use services like Google Analytics or Firebase to understand app usage
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets

Third-party service providers are bound by confidentiality agreements and are prohibited from using your data for any purpose other than providing services to us.

6. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your data, we will securely delete or anonymise it.

Typical retention periods:

• Account data: Retained while your account is active, plus 12 months after deletion
• Purchase records: Retained for 7 years for tax and accounting purposes
• Usage data: Aggregated and anonymized after 24 months
• Support communications: Retained for 3 years

7. Your Rights

Under GDPR and UK data protection law, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your personal data
• Restriction: Request restriction of processing
• Portability: Receive your data in a portable format
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time

To exercise these rights, please contact us at privacy@britpasstestapp.com.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. Security measures include:

• Encryption of data in transit (HTTPS/TLS)
• Encryption of sensitive data at rest
• Regular security audits and vulnerability assessments
• Access controls and authentication
• Secure server infrastructure

However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security. Please use strong passwords and keep your login credentials confidential.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. When we transfer data outside the EEA/UK, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

Our servers are located in [specify regions, e.g., UK, EU, US]. App store providers (Apple and Google) may process data in their own facilities worldwide.

10. Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information immediately.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@britpasstestapp.com.

11. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected
• Right to know whether your personal information is sold or disclosed
• Right to say no to the sale of personal information (we do not sell personal information)
• Right to access your personal information
• Right to request deletion of personal information
• Right to equal service and price (we will not discriminate for exercising rights)

12. Third-Party Services and Links

Our services may contain links to third-party websites and integrate with third-party services:

• Apple App Store & Google Play Store: Subject to their respective privacy policies
• Analytics Services: May use Google Analytics, Firebase, or similar services
• Payment Processors: Apple and Google handle all payment processing
• External Websites: Links to government resources and test booking sites

We are not responsible for the privacy practices of these external services. We encourage you to review their privacy policies before providing any personal information.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other reasons. We will notify you of material changes by:

• Posting the updated policy on this page
• Updating the "Last updated" date
• Sending an in-app notification (for significant changes)
• Sending an email notification if we have your email address

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after changes are posted constitutes your acceptance of the updated policy.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• App Name: BritPass: Life in the UK Test
• Legal Entity: Diffused Innovations Ltd
• Store Name: Diffused Labs
• Email: privacy@britpasstestapp.com
• Website: https://britpasstestapp.com
• Response Time: We aim to respond within 30 days