Privacy Policy

Effective date: May 30, 2026 · Last updated: May 30, 2026

This Privacy Policy describes how Praxis Coach: Praxis Exam Prep ("Praxis Coach," "we," "us," or "our") collects, uses, and protects your information. This policy applies to the Praxis Coach mobile application (the "App").

Also see our Terms of Service and Support.

Who We Are

Data Controller: Anton, individual developer
Location: Batumi, Georgia
Contact: support@byanton.dev
Website: byanton.dev

As a small-scale individual developer, we are not required to appoint a Data Protection Officer under GDPR Article 37. For all privacy inquiries, contact us at the email above.

Summary: Praxis Coach helps you study for Praxis® teacher-licensure exams with practice questions, full-length mock exams, and an AI tutor. Your practice progress, stats, and chat history are stored only on your device. When you use an AI feature (answer explanations, a session review, the tutor chat, or written-response scoring), the relevant text is sent to Google Gemini (via our Cloudflare Workers proxy) to generate a reply. We collect no name, email, photos, camera, location, contacts, or tracking identifiers, we require no account, we show no ads, and we never sell your data or use it to train AI models. Praxis Coach is not affiliated with or endorsed by ETS.

1. AI System Disclosure (EU AI Act Article 50)

You are interacting with an artificial intelligence system. Specifically:
Answer explanations, "Review with AI" session summaries, the Praxis AI tutor chat, and scoring/feedback for written (constructed-response) answers are produced by Google Gemini 2.5 Flash-Lite, an AI model from Google LLC, accessed via Google Vertex AI.
AI-generated explanations, study tips, summaries, and essay feedback may contain inaccuracies, omissions, or unexpected outputs. They are study aids only — not a guarantee of any score or of passing, and not a substitute for the official ETS Study Companion or a qualified instructor. Verify important facts against official ETS materials.
Most practice content (the question explanations shown after you answer) is pre-written and stored in the App, shown instantly and offline. The cloud AI is used for the interactive features named above.

2. Information We Collect

2.1 Information You Provide

Data	Purpose	Storage	Retention
Text you send to an AI feature (a follow-up question, a tutor chat message, or your typed written-response answer)	Generating an AI explanation, chat reply, or essay score	On your device (SwiftData); ephemerally in transit to Google Gemini for the duration of the request	Local: until you clear it or delete the App. Cloud: processed in real time, not stored on our servers
Practice activity (answers, correct/incorrect, streak, spaced-repetition schedule, missed questions, stats)	Tracking your progress and scheduling review	On your device only (SwiftData)	Until you delete the App
AI tutor chat history	Showing your past conversation	On your device only (SwiftData)	Until you clear the chat or delete the App
Selected exam & preferences	Showing the right question bank and personalising the experience	On your device only (UserDefaults / SwiftData)	Until you change it or delete the App

2.2 Information Collected Automatically

Anonymous install identifier — a random per-install UUID generated on device, used as a per-user bucket for API rate-limiting and to group anonymous analytics. It contains no name, email, or personal identifier and is not linked to your identity.
Anonymous subscription status — managed by Apple StoreKit (and RevenueCat for entitlement verification) to confirm Premium access. No name or email is associated with it.
Anonymous usage signals — via TelemetryDeck (privacy-first analytics, EU-hosted). No personal data, no device identifiers, no cross-app tracking.
IP address — visible to our Cloudflare Workers proxy only for rate-limit keying. The IP is never stored in our cache, never shared with Google, and never sold or shared with third parties.
Locale and app version — sent as standard request headers (for AI response language and diagnostics). Visible to Cloudflare in request logs (~24 h retention).

2.3 Information We Do NOT Collect

Email address, phone number, name, physical address (unless you choose to email our support)
Camera or photo library — the App never requests camera or photo access
Location (GPS) — we never request location permission
Contacts, calendar, microphone, or health data
Advertising identifiers (IDFA) — we do not use App Tracking Transparency
Browsing history, cookies, or web tracking pixels
We do not create user accounts or require registration; no Apple, Google, or social sign-in

3. Legal Basis for Processing (GDPR Article 6)

Processing Activity	Legal Basis
Sending text to the cloud AI (explanations, chat, summaries, essay scoring)	Performance of a contract / your request — processing happens only when you tap an AI feature
Storing your practice progress locally	Performance of a contract (providing the study features you requested)
Subscription processing	Performance of a contract (via Apple StoreKit and RevenueCat)
Anonymous usage analytics	Legitimate interest (product improvement) — no personal data involved
Rate limiting and abuse prevention	Legitimate interest (service availability and security)

4. Third-Party Services

Apple Guideline 5.1.2(i) Disclosure: The following named third parties may process your data. Text is shared with Google's AI service only when you actively use an AI feature.

Provider	Service	Data Sent	Retention by Provider
Google LLC (Vertex AI — Gemini 2.5 Flash-Lite)	AI answer explanations, session summaries, Praxis AI tutor chat, written-response scoring	Question text + your selected/typed answer, chat messages, or essay text (text only) + locale	Not retained. Not used for model training per Vertex AI / Gemini API enterprise data-usage terms.
Cloudflare, Inc. (Workers)	Secure proxy routing between the App and Google's AI API; per-user/per-IP rate limiting	Encrypted request body (HMAC-SHA256 signed); IP visible to the rate limiter only	Rate-limit counters: short sliding window. Request logs ~24 h. No long-term storage of your text.
Apple Inc. (StoreKit)	In-app purchase / subscription processing	Managed by Apple per Apple's Privacy Policy	Managed by Apple
RevenueCat, Inc.	Subscription receipt validation and entitlement verification	Anonymous install ID, subscription status, country code	Retained per RevenueCat's privacy policy for the subscription lifetime + audit period
TelemetryDeck (Telemetry Deck GmbH, EU)	Privacy-first anonymous usage analytics	Anonymous session signals only — no personal data, no device IDs, no cross-app tracking	Per TelemetryDeck terms, GDPR-compliant, EU-hosted

All cloud data transfers use TLS encryption, HMAC-SHA256 request signing, and a short timestamp anti-replay window. Text you send to an AI feature is transmitted only for the duration of a single request and is not written to disk on the Cloudflare proxy.

5. Data Storage and Retention

Data	Where Stored	Retention Period
Practice progress, stats, streak, review schedule, missed questions, chat history	Your device (SwiftData, app sandbox)	Until you clear it in-app or uninstall the App
Text in transit to the AI provider	Cloudflare Workers (in memory) → Google Cloud (in memory)	Processed in real time, not written to disk by our proxy
Rate-limit counters	Cloudflare Workers	Short sliding window, per user/IP
Subscription data	Apple servers, RevenueCat servers	Managed per their respective privacy policies

Because your study data lives on your device, deleting the App permanently removes all of it. There is no server-side copy of your practice history to request or erase.

6. Children's Privacy

Praxis Coach is a study tool for adult teacher candidates and does not contain content inappropriate for children. However, as a tool that uses cloud AI:

COPPA: We do not knowingly collect personal information from children under 13. If we discover such data was collected, we will delete it immediately.
GDPR Article 8: For users aged 13–15 in EU member states where the digital age of consent is 16 (Germany, Ireland, Netherlands, France, etc.), parental or guardian consent is recommended for using the cloud AI features.
We do not sell, share, or use minors' data for advertising or AI model training.

7. Your Rights

All Users

Access: Your full study history is visible inside the App (Progress, Library, and the AI tutor chat).
Deletion: Clear your AI chat from within the chat screen, and remove all study data by deleting the App. Because the data is on-device, this is immediate and complete.
Subscription: Manage or cancel anytime via Settings → Apple ID → Subscriptions, or restore a prior purchase from the App's Settings screen.

EU/EEA Residents (GDPR)

Right to access, rectification, erasure, restriction of processing, portability, and objection
Right to withdraw consent at any time without affecting prior processing
Right to lodge a complaint with your local data protection authority (e.g., CNIL in France, BfDI in Germany, DPC in Ireland)
Our AI processing is for informational study support only and produces no legal or similarly significant automated decisions

California Residents (CCPA/CPRA)

Right to know, delete, correct, and opt-out of sale/sharing
We do not sell or share your personal information and do not use your data for cross-context behavioral advertising

Brazil (LGPD) · Turkey (KVKK) · Japan (APPI)

Rights to confirmation, access, correction, deletion, portability, and consent withdrawal as provided under each law
We respond to verified data-subject requests within the statutory window (e.g., 15 days LGPD, 30 days KVKK)
Cross-border transfers to the US are conducted under appropriate safeguards (see Section 9)

8. Apple Required Privacy Disclosures

8.1 Required Reasons API (PrivacyInfo.xcprivacy)

Praxis Coach declares the following API usage in its privacy manifest:

API	Reason
UserDefaults	Store app preferences, selected exam, onboarding state, and the anonymous install ID (reason: CA92.1)
File timestamp	Order content and display recency within the App (reason: DDA9.1)

8.2 App Store Privacy Nutrition Label

Data Type	Linked to Identity	Used for Tracking	Purpose
User Content (text you send to the AI)	No	No	App Functionality (explanations, chat, scoring)
Identifiers (anonymous install ID)	No	No	App Functionality (rate limiting, anonymous analytics)
Diagnostics (Crash / Performance Data)	No	No	App Functionality (TelemetryDeck anonymous signals)
Purchases (Subscription Status)	No	No	App Functionality (entitlement verification)

We do not collect any data type not listed above, and we do not engage in tracking as defined by Apple's App Tracking Transparency framework.

9. International Data Transfers

Text sent to AI features is processed in the United States (Google Cloud Platform, Cloudflare). These transfers are protected by EU Standard Contractual Clauses (GDPR Article 46), the Google Cloud Data Processing Addendum, Cloudflare's data processing agreement, the EU-US Data Privacy Framework where applicable, and TLS encryption with HMAC-SHA256 request signing.

10. Data Security

All data in transit encrypted using TLS (HTTPS)
All API requests to our Cloudflare Workers proxy are signed with HMAC-SHA256 and a short timestamp window to prevent tampering and replay attacks, plus a bundle-identifier check and per-user rate limiting
Your study data is stored on your device, protected by iOS sandboxing
Server-side text processing keeps data in memory only — not written to disk on the proxy
No user accounts, no passwords, no saved credentials — minimal attack surface

11. No Tracking, No Advertising

Praxis Coach does not track you across apps or websites
We do not use advertising identifiers (IDFA) or App Tracking Transparency
We do not display advertisements
We do not share data with data brokers or ad networks
We do not sell or share your personal information under any circumstances

12. Data Breach Notification

In the unlikely event of a data breach affecting your personal information, we will notify affected users and relevant supervisory authorities within 72 hours of discovery as required (GDPR, LGPD, KVKK), and take immediate steps to contain and remediate it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through an updated "Last updated" date and, where practicable, an in-app notice. Continued use after changes constitutes acceptance.

14. Not Affiliated with ETS

Praxis Coach is an independent study aid. It is not affiliated with, endorsed by, or sponsored by Educational Testing Service (ETS). PRAXIS is a registered trademark of ETS. All practice questions are original works written to the public ETS content outlines; the App contains no leaked or actual exam questions.

15. Contact Us

Email: support@byanton.dev
Developer: Anton
Location: Batumi, Georgia
Website: byanton.dev