Pass that Paper (“the App”, “we”, “us”, “our”) is provided by SUROS Systems Ltd, a company registered in England & Wales (company number 17358730), registered office 32 Field Lane, Appleton, Warrington, WA4 5JR. We are the “controller” of your personal data for the purposes of the UK GDPR and the Data Protection Act 2018.
For any privacy question, or to exercise your rights, contact us at passthatpaper.app@gmail.com.
This policy covers the personal data involved when you use the App on your device. It does not cover Apple's own handling of your data as the operator of the App Store and your Apple Account — for that, see Apple's Privacy Policy.
Your quiz history, scores, streaks, XP, weak-chapter tracking and app settings (such as dark mode and sound) are stored locally on your device using standard app storage. This information stays on your device, is not transmitted to us, and is not linked to your identity. It is deleted if you reset your progress within the App or delete the App. Because this storage is strictly necessary to make the App work, it does not require your consent.
If you subscribe to Pass that Paper Pro, the purchase is processed by Apple through the App Store. We never see or handle your payment card details. The App receives your subscription status (active or not) so it can unlock paid content.
To check and manage that subscription status reliably across your devices, we use RevenueCat as a processor acting on our behalf. RevenueCat processes a randomly generated app-user identifier together with your purchase and receipt information to tell the App whether your subscription is active. This is not linked to your name or email.
If you have chosen at the operating-system level to share analytics and diagnostics with app developers, Apple may provide us with anonymised, aggregated crash and usage statistics. This is controlled entirely by your device settings and contains no information that identifies you.
Under the UK GDPR we rely on the following lawful bases:
We do not carry out any automated decision-making that produces legal or similarly significant effects, and we do not profile you.
We do not send marketing communications, and because we do not collect your email address or contact details we are not able to. If this ever changes, we will only send marketing where you have asked us to, and you will be able to opt out at any time.
We do not sell your personal data. We share the limited data described above only with the service providers needed to run the App:
We may also disclose information where we are required to do so by law, or where necessary to establish, exercise or defend legal claims.
Some of our providers (such as Apple and RevenueCat) may process data on servers outside the UK. Where they do, that transfer is protected by appropriate safeguards recognised under UK data protection law — such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an adequacy decision.
On-device study data remains on your device until you reset your progress or delete the App. Subscription records are retained by Apple and RevenueCat for as long as needed to provide the service and to meet their own legal, tax and accounting obligations. We do not hold a separate central copy of your personal data.
Under the UK GDPR you have the right to: be informed about how your data is used; access the personal data we hold about you; have inaccurate data corrected; have your data erased; restrict or object to its processing; data portability; and, where we rely on consent, to withdraw that consent at any time. You will not be charged for exercising these rights, and we will not treat you differently for doing so.
Because most of your data lives only on your device, you can exercise many of these rights directly, by resetting your progress or deleting the App. For anything else, contact passthatpaper.app@gmail.com and we will respond within one month.
If you are unhappy with how we have handled your data, you have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), at ico.org.uk or on 0303 123 1113. We would appreciate the chance to resolve your concern first.
The App is intended for adults studying for professional financial-services examinations. It is not directed at children, and we do not knowingly collect data from children.
We take reasonable technical and organisational measures to protect the limited data involved. No method of storage or transmission is completely secure, but keeping your study data on your own device — rather than on our servers — significantly reduces the risk to you.
We may update this policy from time to time. We will change the “Last updated” date above and, for significant changes, bring them to your attention within the App.
SUROS Systems Ltd
32 Field Lane, Appleton, Warrington, WA4 5JR
passthatpaper.app@gmail.com