PRIVACY POLICY

Mobile applications(App Store/Google Play)

• Driving Theory Test by Lerny

• Testy na prawo jazdy by Lerny

Last updated: 25.11.2025

Controller / Publisher: LLC "SolanaSoft"

Contact email: lernyapps@outlook.com

1. Summary — short version

• No account or registration: the App does not require or collect user registration or directly collect personal data (name, email, phone).
  
• Third-party SDKs: Amplitude, AppsFlyer, AdMob, RevenueCat (and similar providers) are used and may collect device identifiers and technical usage data.
  
• ATT / Advertising ID: we request ATT consent on iOS prior to collecting IDFA for advertising/attribution. You may decline.
  
• Contact: for privacy requests write to lernyapps@outlook.com.
  

2. Data we collect — short explanation

You indicated that the App itself does not collect personal data or user registrations. However, some third-party SDKs and service providers integrated into the App may collect the following categories of data automatically:

• Identifiers: Advertising ID (IDFA on iOS / GAID on Android) — collected only if you grant permission (ATT) or where necessary for attribution.
  
• Usage and analytics data: app usage events, session times, feature usage, non-personal telemetry (collected by Amplitude or similar).
  
• Diagnostics: crash reports, performance metrics (may include limited device data and OS version).
  
• Purchases / subscription status: purchase receipts or subscription state as provided by the store/RevenueCat (we do not store full card or bank details).
  
• IP address (technical): for analytics and general functioning; may be used in anonymised form for geo-estimation.
  

We do not knowingly collect name, email, phone, precise location, payment card details, or other personal identifiers in the App itself. If any such collection is added in the future we will update this policy and obtain applicable consents.

3. How we use data & legal bases

• Analytics & product improvement (legitimate interest / consent): to understand app usage and improve the product. We rely on legitimate interest for non-identifying analytics, and on consent for advertising identifiers (ATT).
  
• Attribution & marketing (consent / legitimate interest): to measure installs and campaigns (AppsFlyer). Where required, consent will be requested.
  
• Fraud prevention and security (legal basis: legitimate interest).
  
• Legal compliance (legal obligation).
  

4. Third-party providers / processors

We use and may add the following categories of processors: Amplitude (analytics), AppsFlyer (attribution), Google AdMob (ads), RevenueCat (subscription management). We may add other providers over time. We have Data Processing Agreements or contractual safeguards with processors where required and will document Standard Contractual Clauses for any transfers outside the EEA/UK as needed.

5. International transfers

Some processors operate or store data outside the EEA/UK. Where applicable, we use appropriate safeguards (SCCs, EU-US data transfer mechanisms where valid) to protect data.

6. Advertising & ATT (iOS)

• On iOS devices we will request permission under Apple’s ATT framework before accessing the advertising identifier (IDFA) or engaging in tracking for advertising. If you decline, we will not access the IDFA for tracking.
  
• You may also opt out of personalised ads in the device settings or via in-app settings (where provided). Declining tracking may reduce or limit functionality of some advertising features or measurement.
  

7. Data retention — general approach (no fixed periods)

We retain data only as long as necessary to fulfil the purpose it was collected for, including legal, tax or accounting obligations. Aggregated or anonymised analytics data may be retained for longer for product improvement. Specific retention periods will be provided upon request.

Note: you asked to avoid fixed retention durations. For compliance and transparency it is recommended to publish exact retention periods later; for now we keep the policy intentionally general — replace with exact periods before final legal review.

8. Your rights (EU/UK)

If you are located in the EU/EEA or UK you have the right to: access, rectify, erase, restrict processing, object, data portability and withdraw consent. To exercise your rights contact lernyapps@outlook.com. We will respond within applicable statutory timeframes (usually 30 days).

9. Children & age limit

The App is intended for users aged 16 or older. We do not knowingly collect personal data from children below this age. If you believe we have collected information from a child in violation of law, contact lernyapps@outlook.com and we will promptly remove such data.

10. Security

We implement reasonable technical and organisational measures to protect data from unauthorised access, loss or alteration. No security measure is absolute; we will notify authorities and users of a personal data breach where required by law.

11. Changes to this Privacy Policy

We may update this Policy. Material changes will be notified via the App. The “Last updated” date indicates the current version.

12. Contact & Supervisory Authorities

Contact: lernyapps@outlook.com.

Attribution & Public Sector Content Notices (examples for in-app or store listing)

• For DVSA (UK) content (where applicable):
  
  Contains public sector information licensed under the Open Government Licence v3.0. © Driver and Vehicle Standards Agency (DVSA).
  
• For gov.pl content (where applicable):
  
  Contains public information published by the Polish Ministry of Infrastructure on gov.pl. Use of those materials is subject to the terms shown on gov.pl and applicable Polish law.