Privacy Policy

Last Updated: October 2025

Your privacy matters to us. This Privacy Policy explains how Scroll IQ ("we," "us," "App") collects, uses, and protects your information.

1. INFORMATION WE COLLECT

1.1 Account Information
When you sign up using Apple Sign In:

• Email address (optional, based on Apple settings)

• Name (optional, based on Apple settings)

• Unique user identifier

1.2 Usage Data

• Cards viewed and quiz results

• Learning streaks and progress

• Categories you explore

• Time spent in app

• Device type and OS version

• App version

• Language preference

1.3 Technical Data

• IP address (anonymized)

• Device identifiers (for crash reporting)

• App performance metrics

1.4 Data We DO NOT Collect

• Precise location data

• Contacts or photos

• Financial information (handled by Apple)

• Browsing history outside the app

• Microphone or camera access

2. HOW WE USE YOUR INFORMATION

We use your data to:

• Provide and improve the App

• Personalize your learning experience

• Track your progress and achievements

• Send notifications (if enabled)

• Provide customer support

• Analyze app usage and fix bugs

• Prevent fraud and abuse

• Comply with legal obligations

3. LEGAL BASIS FOR PROCESSING (GDPR)

We process your data based on:

• Contract: To provide services you requested

• Legitimate Interest: To improve and secure the App

• Consent: For marketing communications (opt-in)

• Legal Obligation: To comply with laws

4. DATA SHARING AND DISCLOSURE

4.1 We DO NOT Sell Your Data

4.2 Third-Party Services
We share limited data with:

• Apple: Authentication and payment processing

• Supabase: Database hosting and backend services

• Analytics Services: Anonymous usage statistics (if implemented)

• Crash Reporting: Anonymous crash logs for debugging

4.3 Legal Requirements
We may disclose data when required by law, court order, or to:

• Protect our rights

• Prevent fraud

• Ensure user safety

4.4 Business Transfers
If we merge or are acquired, user data may transfer to the new entity.

5. DATA STORAGE AND SECURITY

5.1 Where We Store Data

• Servers located in [EU/US/etc.]

• Hosted by Supabase (AWS infrastructure)

• Encrypted in transit and at rest

5.2 Security Measures

• Industry-standard encryption

• Secure authentication protocols

• Regular security audits

• Access controls and monitoring

5.3 Data Retention

• Active accounts: Data retained while account exists

• Deleted accounts: Data deleted within 30 days

• Backups: Deleted within 90 days

• Legal requirements may require longer retention

6. YOUR RIGHTS

6.1 Access and Portability
Request a copy of your data in machine-readable format.

6.2 Correction
Update incorrect information in App settings.

6.3 Deletion
Delete your account and associated data anytime.

6.4 Objection
Object to certain data processing activities.

6.5 Restriction
Request restricted processing of your data.

6.6 Withdraw Consent
Withdraw consent for marketing communications.

6.7 Complaint
File complaint with your data protection authority.

To Exercise Rights:
Email: contact@scroll-iq.com
We respond within 30 days.

7. COOKIES AND TRACKING

7.1 We Use:

• Essential cookies for authentication

• Analytics for app improvement (optional)

7.2 Third-Party Tracking:

• Apple App Store analytics

• No advertising trackers in Premium version

7.3 Do Not Track:
We respect Do Not Track signals where technically feasible.

8. CHILDREN'S PRIVACY

• Not directed at children under 13

• Do not knowingly collect data from children

• Parents: Contact us to delete child's data

• COPPA compliant

9. INTERNATIONAL TRANSFERS

Your data may be transferred to countries outside your residence. We ensure adequate protections through:

• Standard Contractual Clauses (EU)

• Privacy Shield frameworks where applicable

• Equivalent safeguards

10. YOUR CALIFORNIA PRIVACY RIGHTS (CCPA)

California residents have rights to:

• Know what data we collect

• Delete personal information

• Opt-out of data sales (we don't sell data)

• Non-discrimination for exercising rights

Shine the Light Law:
Request list of third parties receiving data for marketing (none currently).

11. EUROPEAN USERS (GDPR)

EU/EEA residents have additional rights:

• Data portability

• Right to be forgotten

• Object to processing

• Restrict processing

• Lodge complaint with supervisory authority

Data Controller:
Alex Charbonneyre
36 Route de Nice, 06320 La Turbie

12. PUSH NOTIFICATIONS

You control notification settings:

• Learning reminders

• Streak alerts

• New content announcements

Manage in: Settings → Notifications

13. CHANGES TO PRIVACY POLICY

We may update this policy and will:

• Notify you via email or in-app notice

• Post updated version with "Last Updated" date

• Require acceptance for material changes

14. DATA BREACH NOTIFICATION

In case of a breach affecting your data:

• We'll notify you within 72 hours

• Provide details of the breach

• Explain mitigation steps

• Comply with all legal notification requirements

15. CONTACT US

Privacy Questions:
Email: contact@scroll-iq.com

Data Protection Officer (if required):
Email: contact@scroll-iq.com

Response Time: Within 30 days

16. CONSENT

By using Scroll IQ, you consent to this Privacy Policy.