Privacy Policy
Apps covered: CPD Tracker / Instructor Development Tracker (iOS and Android) and the related website at drivinginstructorapps.co.uk (collectively, the “Service”). Instructor Questions and Pocket Trainer have their own privacy policies, linked from their App Store and Google Play listings.
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 or Google Play Billing).
- 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 at any time.
- Legal & compliance (legal obligation): tax/VAT records, fraud prevention.
3) Subscriptions & payments
All in-app purchases are processed by Apple or Google. We receive non-financial transaction metadata (e.g., product ID, receipt status) but no full card details. Your purchase is also governed by the Apple Media Services Terms & Conditions or the Google Play Terms of Service.
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 and Google 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 your rights, email philcowleyadi@gmail.com. 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.
11) Contact
Email: philcowleyadi@gmail.com