Privacy Policy — SQE1 Practice App

Last updated: 12 November 2025

Provider: Mr Stanislav Lynnyk (self-employed)
Address: 32/1 Tudsbery Avenue, Edinburgh EH16 4GX, United Kingdom
Email: sqe1practice@gmail.com

Not affiliated with or endorsed by the Solicitors Regulation Authority (SRA) or Pearson VUE.

1. Purpose of this Policy

This notice explains what data we collect, why, and how we protect it when you use the SQE1 Practice mobile application ("App").

We follow UK GDPR / EU GDPR principles of lawfulness, fairness and transparency, and comply with the UK Data Protection Act 2018, EU Regulation 2016/679, UAE PDPL (45 of 2021) and the Hong Kong PDPO (Cap 486).

2. Data we collect and why

Type of Data	Examples	Purpose	Lawful basis
Device & App logs	app version, language, OS type	diagnostics & bug fixing	legitimate interest (security)
Purchase information	Google Play order ID, token, SKU	verify entitlement, provide subscription access	contract performance
Local usage data (on device)	progress, answers, statistics	display your results locally	not transmitted — stored only on your device
Support emails	name (optional), email content	reply to queries, resolve issues	consent / legitimate interest
Crash reports (optional)	stack trace, device model	improve stability	legitimate interest (if enabled via Google Play)

The App does not require registration or collect study answers on our servers. All practice results stay on your device.

3. No special-category data

We do not collect or process any "special category" or sensitive personal data (race, religion, health, biometrics, etc.).

4. Third-party processors

Processor	Purpose	Safeguards
Google Play Billing	manages purchases, trials and renewals	data handled under Google Play Developer Distribution Agreement & Privacy Policy
(Optional) Azure OpenAI Service	AI explanations if user activates feature	data minimised → prompt only; no storage; EU/UK data centre if available

No analytics, ads, or social trackers are embedded.

5. Storage and retention

Local data (answers, progress) — stored only on your device and deleted when you uninstall the App.
Billing tokens — kept securely for as long as your subscription is active and up to 6 years after for statutory accounting (UK HMRC requirement).
Support emails — kept up to 12 months unless longer retention is legally required.

6. Security

We use industry-standard encryption (AES-256 for local data if backup enabled, TLS for network calls) and store purchase tokens encrypted within the app's sandbox.

Only Mr Stanislav Lynnyk or authorised support personnel can access support emails.

7. Your rights

Under UK / EU GDPR:

Access, rectification, erasure ("right to be forgotten")
Restriction or objection to processing
Data portability
Complaint to ICO (UK) or local supervisory authority (EEA)

Contact s.lynnyk.usbk@gmail.com to exercise rights.

Under UAE PDPL:

Right to know, rectify, erase, restrict and withdraw consent (subject to lawful basis).

Under Hong Kong PDPO:

Rights of access and correction under sections 18 & 22; DPP 1–6 apply. Contact us for requests.

8. International data transfers

Our primary storage and business operations are in the United Kingdom.

If we transfer data outside the UK/EU, we use adequate jurisdiction decisions or standard contractual clauses (GDPR Art. 46).

9. Children

The App is not intended for users under 18. We do not knowingly collect data from minors. If you believe a minor has used the App, contact us to delete the data.

10. Changes to this Policy

We may update this Policy for legal or technical reasons. Material changes will be announced in-app and become effective no sooner than 30 days after notice.

11. Contact

Data Controller: Mr Stanislav Lynnyk (self-employed)
Email: sqe1practice@gmail.com
Postal address: 32/1 Tudsbery Avenue, Edinburgh EH16 4GX, United Kingdom
Supervisory authority: Information Commissioner's Office (ICO, UK).