Privacy Policy
Effective date: 1 October 2026Last updated: 12 October 2026
This policy explains how Passa handles information when you use the website or app. Passa has no user accounts and does not send your study answers or progress to a Passa account. Technical information may still be processed when you visit the website, email us, download content or make an in-app purchase.
1. Information we collect
Information you provide
If you email us, we receive your email address, message and any attachments. Please avoid sending sensitive information unless needed for your request. You do not need to create an account or provide your name or email address to study in the app.
Information stored on your device
Settings, study progress, saved questions and practice history are stored on your device. They are not sent to us for syncing.
Website, content and purchases
Cloudflare delivers and protects the website and app content, processing IP addresses and technical request data. Adapty manages subscription access and processes profile identifiers, device information and purchase events. Apple or Google Play handles payments; Passa does not receive your full payment card details.
2. Purposes and lawful basis
We use support emails to read and answer your request, normally on the basis of our legitimate interest in providing support (GDPR Article 6(1)(f)). Technical server data may be needed to deliver the website or content and protect the service. If you buy Premium, purchase and entitlement information is needed to provide that feature (Article 6(1)(b)). We may also retain information to comply with a specific legal obligation (Article 6(1)(c)). Study data stored only on your device displays your progress and is not sent to us for syncing.
- We do not sell personal data or use your study data for advertising or to train AI models.
3. Recipients and transfers outside the EU/EEA
Our service providers—Cloudflare, Adapty, Google and Apple—process relevant data to provide hosting, support email and purchases. Some data may be processed outside the EU/EEA. Applicable safeguards, including standard contractual clauses, are described in the provider policies and agreements linked below. Contact us for information or copies of the safeguards applicable to your data.
4. Retention and deletion
Study progress and settings stay locally until you remove the app data or uninstall the app, subject to device backups and platform behaviour. We cannot delete data that exists only on your device. We delete support emails within 30 days after the case is resolved, unless further handling or a legal obligation requires us to retain them longer. You can ask us to delete your emails; we will do so unless we need to retain them for a legal obligation or to establish, exercise or defend legal claims. Cloudflare retains technical data as needed to provide and protect its services and meet legal obligations. Adapty processes data for the duration of its service agreement, followed by return or deletion, subject to legal retention requirements and backup cycles. Contact us to request deletion of data processed for Passa.
5. Your rights under GDPR
If you are in the EU/EEA and GDPR applies to the processing, depending on the circumstances you may have the right to:
- Access personal data we process about you.
- Correct inaccurate data.
- Request erasure of your data.
- Restrict or object to certain processing.
- Receive data in a structured format where the right to data portability applies.
- Withdraw consent where processing is based on consent.
- Lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY).
How to exercise your rights
Email the address in section 10 to request access, correction or deletion, and describe your request. Send only what is needed to understand and handle it. We may need to verify your identity before disclosing information. We normally respond within one month. Data stored only on your device is managed on that device.
6. Children
Passa has no set minimum age. We do not ask users to create accounts or give their age. If you believe a child sent us personal information by email, contact us so we can assess a deletion request.
7. Automated decisions
We do not use study data for profiling or automated decisions with legal or similarly significant effects.
8. Cookies and similar technology
Passa does not use first-party analytics or advertising cookies on the website. Cloudflare may use technically necessary cookies to protect and deliver the service.
9. Changes
We update this policy when processing changes. The date above shows when it was last revised. Material changes will be announced in the service where possible.
10. Contact
Yury Barysenka is the data controller for Passa.
Passa
113 65 Stockholm, Sverige
Email: [email protected]