PRIVACY POLICY

Last updated: July 13, 2025

 

This Privacy Notice describes how and why we may access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

 

- Download and use our mobile application (**GriLEX**) or any other app of ours that links to this Privacy Notice.

- Use **GriLEX**. GriLEX is an educational mobile app that helps you prepare for direct recruitment exams in the Ministry of Internal Affairs (MAI) — police, gendarmerie, border police, etc. — and for rank promotion of MAI agents/NCOs taking exams to enter the officers’ corps. The app aggregates official question banks, offers timed simulations of the written test, and progress statistics so you can optimize your time and go into the exam with confidence.

- Interact with us in related ways, including for any sales, marketing, or events.

 

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use the Services.

 

**SUMMARY OF KEY POINTS**

This summary provides the key points from our Privacy Notice, but you can find out more details by following the links or by reading the full table of contents below.

 

- **What personal information do we process?** When you visit, use, or navigate the Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about the personal information you provide to us.

 

- **Do we process sensitive information?** Some information may be considered “special” or “sensitive” in certain jurisdictions (racial or ethnic origin, sexual orientation, religious beliefs, etc.). We do not process such information.

 

- **Do we collect information from third parties?** We do not collect information from third parties.

 

- **How do we process your information?** We process it to provide, improve, and administer the Services, to communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process data only when we have a valid legal basis to do so. Learn more about how we process your information.

 

- **When and with whom do we share personal information?** We may share data in specific situations and with certain third parties. Learn more about when and with whom we share your personal information.

 

- **How do we keep your information safe?** We have appropriate organizational and technical processes in place to protect your data. However, no electronic transmission or storage technology can be guaranteed to be 100% secure. Learn more about how we keep data safe.

 

- **What are your rights?** Depending on where you are located, applicable law may grant you certain rights regarding your personal data. Learn more about your privacy rights.

 

- **How do you exercise your rights?** The easiest way is through a data subject access request or by contacting us directly. We will review and respond in accordance with applicable law.

 

- **Want to learn more?** Review the full Privacy Notice.

 

**TABLE OF CONTENTS**

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6. DO WE COLLECT INFORMATION FROM MINORS?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK

9. DO WE MAKE UPDATES TO THIS NOTICE?

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

### 1. WHAT INFORMATION DO WE COLLECT?

**Personal information you disclose to us**

 

*In short: We collect personal information that you provide to us.*

 

We collect personal information that you voluntarily provide when you register for the Services, express interest in us or our products and Services, participate in activities within the Services, or contact us.

 

**Personal information provided by you.** The information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products or features you use. The information may include:

 

- email addresses

- usernames

- passwords

 

**Sensitive information.** We do not process sensitive information.

 

**Payment data.** We may collect data necessary to process your payments, such as your payment instrument number and the security code associated with it. All payment data are handled and stored by RevenueCat: <https://www.revenuecat.com/privacy/>.

 

**App data.** If you use our app, we may collect, with your permission:

 

- **Mobile device access.** Permissions for certain features (e.g., network connectivity). You can change these permissions in your device settings.

- **Mobile device data.** We automatically collect information such as your device’s unique ID, model and manufacturer, operating system and version, system configuration, app identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, IP address (or proxy server). We may also collect data about the mobile network associated with your device, its platform, and the app features you used.

- **Push notifications.** We may request to send you push notifications about your account or certain app features. You can disable these notifications in your device settings.

 

This information is primarily needed for the security and operation of the app, troubleshooting, and internal analytics.

 

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes.

 

**Google API**

Use of information received from Google API adheres to the Google API Services User Data Policy, including the Limited Use requirements.

 

### 2. HOW DO WE PROCESS YOUR INFORMATION?

*In short: We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.*

 

We process personal information for various reasons, depending on how you interact with our Services, including:

 

- **To facilitate account creation and authentication and otherwise manage user accounts.** We may process your information so you can create and access your account and keep it in working order.

 

- **To provide and facilitate delivery of services to you.** We may process your information to provide the requested service.

 

- **To respond to your inquiries/offer support.** We may process your information to answer questions and resolve any issues with the requested service.

 

- **To send you administrative information.** We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

 

- **To process and manage your orders.** We may process your information to fulfill and manage orders, payments, returns, and exchanges made through the Services.

 

- **To solicit feedback.** We may process your information when necessary to request feedback and to contact you about your use of the Services.

 

- **To send you marketing and promotional communications.** We may process the information you send to us for marketing purposes, in accordance with your preferences. You can unsubscribe from our marketing emails at any time. For more details, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.

 

- **To administer prize draws and competitions.** We may process your information to administer and manage prize draws and competitions.

 

- **To evaluate and improve our Services, products, marketing, and your experience.** We may process information when we believe it is necessary to identify usage trends, determine the effectiveness of promotional campaigns, and improve the Services, products, marketing, and your experience.

 

- **To identify usage trends.** We may process information about how you use the Services to better understand their usage and improve them.

 

- **To comply with legal obligations.** We may process your information to comply with legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

 

### 3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

*In short: We may share information in specific situations described in this section and/or with the following third parties.*

 

We may need to share your personal information in the following situations:

 

- **Business transfers.** We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

 

### 4. HOW LONG DO WE KEEP YOUR INFORMATION?

*In short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless otherwise required by law.*

 

We will retain personal information only for as long as necessary for the purposes described here, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements). No purpose in this notice requires us to keep personal information longer than the period in which users have an account with us.

 

When we no longer have a legitimate business interest in processing your personal information, we will delete or anonymize it. If this is not possible (for example, because the data is stored in backup archives), we will securely store and isolate it from any further processing until deletion is possible.

 

### 5. HOW DO WE KEEP YOUR INFORMATION SAFE?

*In short: We aim to protect your personal information through a system of organizational and technical security measures.*

 

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your data, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should access the Services only within a secure environment.

 

### 6. DO WE COLLECT INFORMATION FROM MINORS?

*In short: We do not knowingly collect data from or market to children under 18 years of age.*

 

We do not knowingly collect, solicit, or sell personal data from children under 18 years of age, nor do we sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or legal guardian of a minor and consent to the minor’s use of the Services. If we learn that we have collected personal information from users under 18 years of age, we will deactivate the account and take reasonable measures to promptly delete such data.

 

### 7. WHAT ARE YOUR PRIVACY RIGHTS?

*In short: You can review, change, or terminate your account at any time, depending on your country, province, or state of residence.*

 

**Withdrawal of consent:** If we rely on your consent to process your personal data (express or implied, as permitted by applicable law), you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. Withdrawal will not affect the lawfulness of processing before the withdrawal and, where permitted by law, will not affect processing based on legal grounds other than consent.

 

**Opting out of marketing and promotional communications:** You can unsubscribe from our marketing and promotional communications at any time in the app settings or by contacting us using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will be removed from marketing lists. However, we may still send you service-related messages necessary for account administration, responses to requests, or other non-marketing purposes.

 

**Account information:**

If you would like to review or change the information in your account or terminate your account, you can:

 

- log into your account settings and update your user data.

 

Upon your request to terminate the account, we will deactivate or delete your account and information from our active databases. However, we may retain certain information for fraud prevention, troubleshooting, assisting with investigations, enforcing legal terms, and complying with applicable legal requirements.

 

### 8. CONTROLS FOR DO-NOT-TRACK

Most web browsers and some mobile operating systems and mobile applications include a “Do-Not-Track” (“DNT”) setting you can activate to signal your preference not to be tracked online. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you via an updated version of this Privacy Notice.

 

### 9. DO WE MAKE UPDATES TO THIS NOTICE?

*In short: Yes, we will update this notice as necessary to remain compliant with relevant laws.*

 

We may revise this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top. If we make material changes, we will notify you either by prominently posting a notice or by directly sending you a notification. We encourage you to review this notice frequently to stay informed about how we protect your data.

 

### 10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by e-mail at dylancsoftware@gmail.com

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### 11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the laws in your country, you may have the right to request access to the personal data we collect, details about how we processed it, correction of inaccuracies, or deletion of your personal data. You may also have the right to withdraw your consent for processing. These rights may be restricted in certain circumstances under the law. To request to review, update, or delete your data, please complete and submit a data subject access request.