Privacy Policy (CPD Tracker App)

Controller: Driving Instructor Apps, (“we”, “us”).

Contact: philcowleyadi@gmail.com

Apps covered: CPD Tracker (iOS and Android) and related websites at www.drivinginstructorapps.co.uk (collectively, the “Service”).

We respect your privacy. This policy explains what we collect, why we collect it, how we use it, and your rights under the UK GDPR / EU GDPR.

1) Data we collect

Account data: name, email, password hash (if you sign up with email), Apple ID identifier (if you use Sign in with Apple).
Profile & content: CPD activities (titles, dates, hours, notes, what you learned, implementation notes), goals & tasks, events, favourites, attachments you upload (if applicable).
Transactional: subscription purchase history, product identifiers, receipts (processed via Apple’s StoreKit / App Store).
Device & usage: app version, device model, operating system, general usage events, diagnostics and crash logs.
Support: messages you send to us (email/support forms).

We do not collect precise GPS location or sensitive categories unless you explicitly provide them in free‑text fields.

2) Why we process your data (legal bases)

Provide and maintain the Service (perform our contract with you): account creation, sync/storage of your CPD data, subscriptions.
Improve and secure the Service (legitimate interests): debugging, analytics in aggregate, preventing abuse.
Communications (legitimate interests/contract): important service emails (e.g., changes, outages, receipts). Marketing emails only with your consent; you can opt out anytime.
Legal & compliance (legal obligation): tax/VAT records, fraud prevention.

3) Subscriptions & payments

All in‑app purchases are processed by Apple. We receive non‑financial transaction metadata (e.g., product ID, receipt status) but no full card details. Your purchase is also governed by Apple Media Services Terms & Conditions.

4) Sharing your data

We share data only with:

Service providers (processors) that help us run the Service (e.g., cloud hosting, error logging, analytics, email delivery). They act under contract and follow our instructions.
Apple for in‑app purchases and account‑level platform features.
Legal authorities when required by law or to protect rights, safety, and security. We do not sell your data.

5) International transfers

Where processors are outside the UK/EEA, we use appropriate safeguards such as the UK International Data Transfer Addendum and/or EU Standard Contractual Clauses.

6) Data retention

Account & CPD data: kept while your account remains active. If you delete your account, we delete or anonymise your personal data within [30] days, except where we must retain records for legal reasons.
Transactional/tax data: retained for up to [7 years] as required by law.
Backups: stored for a limited period before being overwritten.

7) Security

We use technical and organisational measures appropriate to the risk (encryption in transit, access controls, least‑privilege policies). No method is 100% secure.

8) Your rights (UK/EU)

You can access, rectify, erase, restrict, object, export your data, and withdraw consent where processing is based on consent. To exercise rights, contact us at www.drivinginstructorapps.co.uk You also have the right to complain to the ICO(UK) or your local EU supervisory authority.

9) Children

The Service is not intended for children under 13. We do not knowingly collect data from children. If you believe a child has provided personal data, contact us and we will delete it.

10) Changes

We may update this policy. We will post the new version with a new “Last updated” date and, where appropriate, notify you in‑app or by email.