Privacy Policy

1. Who we are

TVDE Ready is an independent learning service for European Portuguese and TVDE exam preparation. Questions about this policy or your personal data can be sent to support@tvdeready.com.

2. Information we may process

• Account details such as your email address, display name and authentication identifiers.
• Your preferred guidance language, Portuguese level, daily study goal and onboarding choices.
• Learning activity including completed lessons, answers, mistakes, XP, hearts, exam attempts and progress.
• Technical information such as app version, device platform, error logs and notification token.
• If you consent to advertising measurement, limited app-install, session and progress-event data, advertising or campaign identifiers, and device or network information made available by your platform.
• Subscription status and purchase entitlement. Full card details are handled by Apple or Google and are not stored by us.
• Messages you send to support and information you voluntarily provide.

3. Why we use information

• To operate the app, keep your progress and provide the learning features you request.
• To personalise lesson placement, review items and practice recommendations.
• To manage subscriptions, prevent abuse and protect accounts.
• To send study reminders only when you allow notifications.
• To diagnose crashes, measure reliability and improve the service.
• With your consent, to understand whether advertising leads to app installs and useful in-app progress.
• To comply with legal obligations and respond to valid requests.

Depending on the context, processing is based on performing our agreement with you, your consent, our legitimate interests in operating a safe and useful service, or a legal obligation. We rely on your consent for the Meta and TikTok advertising measurement described below.

4. Advertising measurement and attribution

TVDE Ready includes measurement tools from Meta and TikTok so we can understand whether an advert led to an installation and whether people then reach important stages in the app. We do not initialise these tools or send the measurement events described here until you choose to allow advertising measurement in TVDE Ready.

After you consent, iOS may separately show Apple's App Tracking Transparency (ATT) permission. If you deny ATT, TVDE Ready will not enable access to the Identifier for Advertisers (IDFA). Measurement that does not rely on IDFA, including aggregated or privacy-preserving attribution such as Apple's SKAdNetwork, may still operate.

The limited event data may include:

• App installation, launch or session activity and retention signals.
• Completion of registration, onboarding, a placement test or a first successful lesson; a paywall view; or the start of a subscription.
• The event name and broad context such as content type, registration method or completion status, together with app, device, network and campaign information the platform makes available.

The events we configure do not include your email address, display name, NIF, precise location, spoken audio, lesson answers or mistakes, support messages, payment-card information or App Store receipts. A registration event may say which sign-in method was used, but it does not contain the address or account credentials.

For a confirmed subscription event, the app may create a locally derived pseudonymous fingerprint solely to prevent duplicate delivery. We do not send the raw store transaction identifier or purchase receipt.

Meta and TikTok may process device identifiers and product-interaction data for advertising measurement and analytics and may associate received data with other information they hold, as described in their own privacy policies. They may process information outside Portugal or the EEA. Where required, recognised safeguards such as adequacy decisions or standard contractual clauses apply.

Your consent choice and a limited record used to prevent duplicate event delivery are stored on your device. Meta and TikTok retain information according to their own policies and legal obligations, so a single retention period does not apply to all provider data.

You can decline when asked or withdraw consent later under Settings → Privacy & Support in TVDE Ready. This disables future Meta and TikTok measurement from the app. You can also change ATT permission in iOS Settings. Withdrawal does not automatically erase information already received by a provider; contact us at support@tvdeready.com if you want help exercising a data right.

Optional in-app usage measurement

Versions that offer usage measurement ask for a separate, optional choice. It is not bundled with advertising measurement, account registration or notification permission. Learning features remain available if you decline. After you allow it, our Supabase backend may receive first-observed installation, app opening, daily activity, lesson completion and test completion events, together with time, app version, platform, interface language and limited test context such as mode, broad category and completion result.

A random installation secret is created on your device; only its cryptographic digest is retained with server events. This is pseudonymous data, not a count of identifiable people. It is separate from your account, advertising identifier and notification identity. The events do not include your email, name, individual answers, microphone recordings, precise location or payment details, and are not forwarded to Meta or TikTok. Counts can differ from store downloads because people may decline, never open the app, reinstall or use several devices.

Raw usage events are retained for up to 90 days. You can withdraw under Settings; we stop new events and request deletion of this installation's usage history. Offline deletion is retried when connected. A digest of the old identity may remain for up to 90 days solely to prevent delayed requests from recreating deleted events. Hosting and network providers can still process request IP addresses in infrastructure logs. Our application rate limiter retains a daily keyed digest of the gateway-reported network address, not the raw address, for up to three days.

Account registrations and verified email totals are derived separately from account records. Verified purchase, renewal and refund notices come from RevenueCat to our backend; they are not accepted from app usage events. The operational sales report retains product, store, timestamps, currency, amounts and a hashed transaction key, not customer identifiers, raw receipts, card information or the complete webhook payload. Free trials, gifts and sandbox activity are excluded from paid-sales totals. Necessary subscription and financial records follow the applicable service, accounting and legal retention requirements rather than the optional usage deletion policy.

Optional app announcements

On-device learning reminders and remote app announcements have separate settings. Local reminder permission does not opt you into remote announcements. In supported versions, announcements are off by default. Only after you choose App announcements and grant device notification permission do we request an Expo push token and register it with Supabase, together with a separate random installation identity, interface language, platform, app version and consent record. No account, advertising or analytics identifier is attached to that registration.

We use these details to deliver new-content updates and important TVDE Ready news through Expo and Apple APNs or Google FCM. We do not require microphone, contacts or location access. You can turn announcements off in Settings or disable device notifications. Turning announcements off requests removal of the server token; an offline request is retried. Already submitted notifications cannot be recalled, so you may also disable device notifications while removal is pending. Invalid tokens are removed when the delivery provider reports them.

Registrations expire after 90 days without refresh. A revoked-identity digest is retained for up to 90 days to stop delayed registrations, and minimal campaign and provider-receipt records for up to 30 days to prevent duplicates and troubleshoot delivery. A provider acknowledgement does not prove that a message appeared or was read. These choices do not affect your Premium entitlement or learning access.

Website cookies and measurement

On tvdeready.com, optional measurement tools stay off until you make a choice in the cookie panel. Analytics consent enables Google Analytics to measure page views, store-button clicks, and free-practice starts and completions (including the total number of correct answers, without individual answers or account identifiers), and Microsoft Clarity to record website interactions such as clicks, scrolling and browsing sessions. Marketing consent enables the Meta and TikTok website pixels for page views and store-button clicks. A store-button click does not establish that an app was installed or that a subscription was purchased. Website consent is separate from the advertising-measurement choice in the mobile app.

You can allow either category, reject both, or change your decision at any time using Cookie preferencesat the bottom of every page. We store your choice in your browser for up to 180 days. Withdrawing a category stops future measurement from that category and reloads the page to remove its loaded tools. It does not erase data a provider has already received.

With permission, these providers may receive browser, device and network information, page locations, campaign identifiers, and the limited interactions described above. Their cookies may include Google Analytics' _ga cookies, Meta's _fbp and _fbc, and TikTok's_ttp cookies. Provider retention periods differ. We do not configure email, phone, account, purchase-receipt or payment-card matching in these website tools.

Learn how the providers process information: Google, Meta, and TikTok. These services may process data outside the EEA under their applicable terms and safeguards.

Microsoft Clarity website recordings

We use Microsoft Clarity to understand how visitors interact with our public website through session recordings and heatmaps. Clarity is loaded only after you allow Analytics in the cookie panel. Clarity advertising storage remains denied; your Marketing choice controls the existing Meta and TikTok pixels. You can reject optional tools or withdraw permission using Cookie preferences.

Clarity masks input fields and sensitive text such as email addresses. We do not send customer account identifiers through its Identify API. Authentication return pages are excluded, and Clarity is not started on URLs containing unknown query parameters or token-like fragments. This installation covers the website, not the mobile app.

Clarity may use first-party cookies such as _clck and _clsk after consent, and Microsoft may receive browser, device, interaction and network information. Learn more in Microsoft's Privacy Statement. Microsoft processes information under its applicable terms and safeguards. Withdrawing permission stops the recorder and reloads the page; it does not erase data already received.

5. AI-assisted features

Some practice and exam-preparation content may be generated or adapted using artificial intelligence. We send only the information needed to produce the requested learning content and apply automated validation before it reaches the app. Do not enter sensitive personal information into free-text fields.

6. Service providers and international transfers

We use specialist providers for hosting, authentication, database storage, app delivery, artificial intelligence, notifications, purchases, email and diagnostics. Current providers may include Supabase, Expo, OpenAI, RevenueCat, Apple, Google, Cloudflare, Microsoft, Meta and TikTok. RevenueCat helps validate subscription status and purchase entitlements; Apple and Google process the underlying store payment; and Meta and TikTok provide the consent-based advertising measurement described above. Depending on the service, a provider may act under our instructions or as a separate controller under its own privacy terms.

Information may be processed outside your country. Where required, we use recognised safeguards such as adequacy decisions or standard contractual clauses.

7. Retention and security

We retain account and learning data while your account is active and only as long as needed for the purposes described above. Some records may be kept longer where law, fraud prevention, accounting or dispute resolution requires it. We use access controls, encryption in transit and other proportionate safeguards, but no system can promise absolute security.

8. Your choices and rights

Depending on your location, you may have rights to access, correct, export, restrict, object to or delete your personal data, and to withdraw consent. You can also disable notifications in your device settings.

Send requests to support@tvdeready.com or follow the account deletion instructions. You may also complain to your local data protection authority. In Portugal, this is the CNPD.

9. Children and changes

TVDE Ready is intended for adults preparing for professional driving activity and is not directed to children. We may update this policy as the service develops. Material changes will be communicated in the app or by another appropriate method.