Privacy Policy
Last updated:
This policy explains what personal data PPL Questions collects when you use the website (pplquestions.eu), the web app and the PPL Questions apps for Android and iOS. It also explains why we collect it, who we share it with, how long we keep it and what your rights are.
1. Who we are
The controller of your personal data is:
JTP S.R.L., limited liability company (societate cu răspundere limitată), trading as PPL Questions
Bulevardul Republicii 116, bl. 210, ground floor, ap. 3, room 1, 100286 Ploiești, Prahova, Romania
Trade Register no. J29/1053/2019, CUI 40675708
Contact for privacy questions: contact@pplquestions.eu
We have not appointed a Data Protection Officer, because the law does not require one for an operation of our size. Privacy requests are handled directly by the owner.
2. What we collect
2.1 Account data
When you create an account (on the website or in an app) we collect:
- your email address, first name and surname;
- your password, stored only as a salted one-way hash (never readable by us);
- on the website sign-up also: country, city and (optionally) street address, used for invoices;
- an internal account identifier derived from your email address;
- your language and theme settings, and an optional nickname, avatar and short bio;
- account status: plan, subscription type, activation and expiry dates, and whether mock exams are unlocked;
- security information: when you last logged in, failed login attempts, temporary account locks and, if you switch it on, your two-factor authentication secret.
2.2 Purchase data
We do not receive or store your card details. Payments are handled by the payment providers listed in section 4. We keep:
- order and transaction identifiers, the plan bought, the amount, currency, discount or referral code used and the payment status;
- customer and subscription identifiers at Stripe or Revolut, and transaction identifiers from the Apple App Store. Apple does not give us your name, email address or Apple ID;
- the IP address and browser information at the time of purchase, to prevent fraud;
- invoices (name, address, plan, amount);
- on the website: the time you agreed that your access starts immediately and that you lose the right of withdrawal (see the Terms of Use, section 7).
2.3 Study data
To run the service and show your progress, we store:
- your answers to practice questions, quiz and mock exam results, and per-subject progress;
- saved questions, personal notes, flashcards and spaced-repetition review data;
- study plans and your exam date, if you set them;
- real exam results you choose to enter and, optionally, a proof file you upload;
- question reports, feedback messages and ratings or testimonials you send us. If you allow it, we may publish a testimonial with a short display name, for example "John D.".
2.4 Technical and security data
- IP address: stored when you sign up, at your last login, in our security audit log (logins, password changes and similar events), for short-term rate limiting (deleted after 1 hour) and in server error logs.
- Browser and device information (user agent), stored with login sessions, "remember me" tokens and security events.
- App sessions: a login token stored with a generic device label such as "android app" or "ios app".
- Trusted devices for two-factor authentication: a hash of your browser fingerprint, a device name, IP address and user agent.
2.5 Website and web-app usage statistics (our own)
We measure how visitors use the website and web app with our own tool. Nothing in this section is sent to an analytics company. We record:
- a random visitor ID, stored in a cookie and in local storage for 1 year;
- pages viewed, time on page, scroll depth, the page you came from (referrer) and campaign tags (for example utm_source);
- device type, browser and preferred language;
- your IP address and an approximate location (country and city). We work out the location on our own server from a local database; the IP address is not sent to a third party for this;
- steps in the sign-up funnel (for example "started sign-up" or "checkout started").
2.6 Advertising measurement
Marketing trackers require your consent. Only if you accept marketing cookies, we load on the website and in the web app:
- the Google Ads conversion tag (Google Ireland Limited), and
- the TikTok Pixel (TikTok Technology Limited, Ireland).
These tell us whether our ads lead to visits and purchases. They set their own cookies and send data such as your IP address, browser information and the pages you visit to Google or TikTok.
When a purchase made on the website is completed, we also send a purchase event to TikTok's Events API from our server: the order value, the order ID and a hashed (SHA-256) version of your email address. We do this only if you accepted marketing cookies.
2.7 Communications
- Emails we have to send (service emails): welcome, payment confirmation and invoice, password reset, account unlock, two-factor and security notices, subscription expiry and renewal reminders.
- Study reminder and "come back" emails: if you have not studied for a while we may send a short reminder. You can switch these off in your profile, and every such email carries an unsubscribe link.
- Push notifications (apps): if you allow notifications, the app registers a device token with us so we can send study reminders and review-due notices. You can switch them off in the app's notification settings or in your phone's settings; the token is deleted when you log out or delete your account.
- Demo discount: if you give your email address in the demo to receive a discount code, we store the email address, the code, your IP address and browser information.
- Support: messages you send us through the feedback form, contact form, live chat or support tickets, together with your email address.
2.8 Social features
The Service may offer social features: a feed, forum, friends, direct messages (including voice messages), study groups, public profiles, online status and related notifications. When they are available, the content you post and your public profile (nickname, avatar, bio, progress badges you choose to show) are visible to other users, and you can limit what is shown in your privacy settings. These features are currently switched off on pplquestions.eu and in the current apps; we will update this policy before enabling them.
2.9 Flight schools
If you join PPL Questions through a flight school, that school can see your name, your progress and your results in its school dashboard, so it can follow your preparation. The school decides for its own purposes how it uses this information and is responsible for that use; we provide the dashboard. You can limit what the school sees in your privacy settings.
2.10 What we do not collect
We do not collect your date of birth, ID documents, card numbers, precise (GPS) location, contacts, photos or microphone recordings. The exception is a real exam proof file, which you choose to upload.
3. Why we use your data, and our legal basis
We process your data on the following legal bases (GDPR Article 6(1)):
- Create and run your account, give access to what you paid for, sync between web and apps, show progress and unlock mock exams (account, purchase and study data): performance of a contract.
- Take payments, issue invoices, handle renewals, cancellations and refunds (account and purchase data): performance of a contract.
- Keep invoices and accounting records (purchase data, invoices): legal obligation under tax and accounting law.
- Security: prevent account sharing, brute-force attacks, scraping and payment fraud; keep an audit log (technical and security data): our legitimate interest in protecting the Service and our content.
- Fix errors and keep the Service running (technical data, error logs): legitimate interest.
- Our own usage statistics (section 2.5): our legitimate interest in understanding and improving the website and web app.
- Advertising measurement (section 2.6): your consent, which you can withdraw at any time.
- Study reminder, "come back" emails and push notifications: legitimate interest in communicating with you about a service you use (emails), and your consent (push notifications). You can opt out at any time.
- Demo discount email: your consent.
- Answering support requests (messages, email): performance of a contract or legitimate interest.
- Publishing testimonials (rating, comment, display name): your consent.
- Defending or bringing legal claims (the data relevant to the claim): legitimate interest.
Where we rely on legitimate interest, you can object (section 8).
4. Who we share data with
We do not sell your personal data. We share it only with the following service providers (processors, or independent controllers where noted), and only as far as each one needs it:
- Opticnet-Serv S.R.L. (Ducadu Cloud), Romania: hosting of the servers that run the website, the apps' backend, the database and our own mail server (mail.pplquestions.eu), from which all our emails are sent. Data: all data we hold. Location: Romania (EU).
- Revolut (Revolut Bank UAB / Revolut Ltd): card payments and monthly subscriptions on the website and from the Android app. Data: name, email address, order details. Location: EEA / UK.
- Stripe Payments Europe Ltd: card payments and monthly subscriptions on the website. Data: name, email address, order details. Location: EEA, with transfers to the USA.
- Apple Distribution International Ltd: purchases in the iOS app (Apple acts as seller and is a separate controller) and delivery of push notifications to iPhones. Data: Apple shares only transaction identifiers with us; for notifications, a device token. Location: Ireland / USA.
- Google Ireland Limited: Firebase Cloud Messaging, which delivers push notifications to the apps (device token, notification content); distribution of the Android app through Google Play (Google is a separate controller for your Play account); the Google Ads conversion tag, only with your consent (cookies, IP address, browser data, pages visited); and Google Fonts on the website (IP address). Location: EU / USA.
- TikTok Technology Limited, Ireland: TikTok Pixel and purchase events, only with your consent. Data: cookies, IP address, browser data, order value, hashed email address. Location: EU / USA / other countries where TikTok processes data.
- Cloudflare, Inc. (Turnstile): bot protection on sign-up, login, purchase and contact forms. Data: IP address, browser signals. Location: EU / USA.
- Public script and font libraries: cdnjs (Cloudflare), jsDelivr, unpkg, Google Fonts: loading page scripts, styles, flag icons and fonts on the website and web app. Data: IP address, browser data. Location: worldwide content delivery networks.
- Anthropic PBC, USA: an AI service we use to write and translate question explanations. It receives only question text, never data about you.
- Flight schools (only if you joined through one): see section 2.9. Data: name, progress, results. Location: EEA.
- Authorities, courts and professional advisers: when the law requires it or to defend legal claims. Data: as required.
5. International transfers
Our servers are in Romania. Some providers (Stripe, Apple, Google, TikTok, Cloudflare, Anthropic and the content delivery networks) may process data outside the European Economic Area, mainly in the USA. When they do, the transfer is protected by:
- the EU–US Data Privacy Framework, for providers certified under it, and/or
- the European Commission's Standard Contractual Clauses, plus extra safeguards where needed.
You can ask us for a copy of the relevant safeguards at contact@pplquestions.eu.
6. How long we keep data
We keep personal data only as long as needed for the purposes above:
| Account, study data and settings | while your account exists; deleted when you delete your account (see section 8) |
|---|---|
| Inactive accounts (access expired, no renewal) | deleted 24 months after your access expired, with an email warning before deletion |
| Invoices and accounting records | 10 years, as Romanian accounting law requires; kept even after account deletion |
| Payment transaction log (order, amount, IP address, browser) | same as invoices; the IP address and browser information are removed after 12 months |
| Web login session | up to 30 days |
| "Remember me" token | 30 days, renewed while you use the site; expired tokens deleted daily |
| App login token | 30 days (15-minute access tokens) |
| Two-factor trusted device | 30 days |
| Rate-limit records (IP address) | 1 hour |
| Live visitor presence | 24 hours |
| Visitor page history | 30 days |
| Visitor ID cookie | 1 year |
| Other visitor statistics (engagement scores, funnel steps, IP location cache) | 12 months |
| App sync receipts | 90 days |
| Security audit log (logins, IP address, browser) | 12 months |
| Server error and debug logs (contain IP addresses) | 30 days, rotated automatically |
| Support chat, tickets, feedback and contact messages | 24 months after the conversation is closed |
| Demo discount leads | 12 months, or until you use the code |
| Password reset links | valid for a short time; records deleted after 24 hours |
| Push notification device tokens | until you log out, delete your account or the token becomes invalid |
| Backups | rolling, kept at most 30 days |
7. Data on your device (apps)
The PPL Questions apps store data on your phone so you can study offline:
- Offline database: the question bank and images, and your own study data (answers, saved questions, notes, review cards, mock exam sessions, practice history, and changes waiting to sync).
- Secure storage (Android Keystore / iOS Keychain): your login tokens and, during sign-up, a temporary sign-up token. Your password is never stored on the device.
- App settings: your email address (to show who is signed in), your account ID, your exam date, last practised subject, question language, theme, auto-advance and notification settings.
When you log out, delete your account, or a different user logs in, the app deletes your personal study data and tokens from the device. The downloaded question bank and device settings (language, theme) stay. Uninstalling the app removes everything.
Permissions: the apps ask only for internet access and, if you accept, permission to show notifications. They do not use the camera, microphone, location, contacts or photos.
Push notifications are delivered through Firebase Cloud Messaging (Google) and, on iOS, Apple's push service. We store the device token with your account and delete it when you log out or delete your account.
In-app purchases (iOS): purchases go through your Apple ID. We receive a signed transaction from Apple to confirm the purchase and link it to your PPL Questions account.
Apart from Firebase Cloud Messaging, the apps contain no third-party analytics, advertising or crash-reporting SDKs.
8. Your rights
You have the right to:
- Access: get a copy of the personal data we hold about you.
- Rectification: correct inaccurate data. You can edit most of it yourself in your profile.
- Erasure: have your data deleted (see "Deleting your account" below).
- Restriction: ask us to pause using your data while a complaint is checked.
- Portability: receive the data you gave us in a common machine-readable format (JSON or CSV). Exports are provided on request by email.
- Objection: object to processing based on legitimate interest, including reminder emails. You can always object to direct marketing.
- Withdraw consent at any time, for example by changing your cookie choice, switching off notifications or emails. This does not affect processing that already happened.
- Complain to a data protection authority. Our supervisory authority is the Romanian National Supervisory Authority for Personal Data Processing, ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal, www.dataprotection.ro). You can also complain to the authority in the EU country where you live or work.
To use any right, email contact@pplquestions.eu from the address on your account. We reply within one month. We may ask you to confirm your identity.
Deleting your account
You can delete your account yourself at any time:
- Apps: Settings → Delete account (confirm with your password). This also works when your access has expired.
- Website: Profile → Delete account.
When you delete your account we:
- cancel any monthly subscription you have through Stripe or Revolut, so you are not charged again. We cannot cancel App Store subscriptions: cancel those in your Apple ID settings (Settings → [your name] → Subscriptions) before you delete your account;
- permanently delete your account and profile, your answers and statistics, quizzes and mock exams, saved questions, notes, review data, study plans, real exam result entries, notification settings, push tokens, login tokens and devices, and your Stripe and Revolut customer records held by us.
We keep the following, for the reasons shown:
| Invoices, payment records and subscription history | legal obligation (tax and accounting law), 10 years |
|---|---|
| App Store purchase records, with the link to your account removed | to keep Apple's purchase ledger consistent and to prevent the same purchase being claimed twice |
| Security audit log entries | legitimate interest in security and fraud prevention, for the period in section 6 |
| Referral reward records | accounting for rewards already granted |
| Content you published for other users (posts, comments, forum messages and files attached to them, where social features are available) | other users' conversations depend on it; it is no longer connected to an account. Delete it yourself before deleting your account, or ask us to remove it |
| Real exam proof files you uploaded | kept as evidence that the results behind our statistics and testimonials were genuine (legitimate interest). You can ask us to delete your proof files at any time |
| Support tickets, feedback and contact messages, question comments and votes | kept for their retention periods in section 6 (support messages 24 months after closing); after deletion they are no longer tied to your account |
You can also ask for a copy of your data before deleting your account.
9. Cookies and similar technologies
We use the following cookies and storage. Cookies marked "consent" are set only after you accept them in the cookie banner.
| PHPSESSID (us) | keeps you logged in; 30 days; strictly necessary |
|---|---|
| remember_token (us) | "remember me" login; 30 days; necessary, you choose it |
| 2fa_trusted (us) | remembers a trusted device for two-factor login; 30 days; necessary |
| ppl_language, ppl_website_lang (us) | remembers your language; 1 year; necessary |
| ppl_consent (cookie, us) | remembers your cookie choice; 12 months; necessary |
| cookieConsent (local storage, us) | remembers your cookie choice; until cleared; necessary |
| ppl_visitor_id (cookie and local storage, us) | our own usage statistics (section 2.5); 1 year; legitimate interest, you can object |
| Google Ads cookies, for example _gcl_* (Google) | ad conversion measurement; up to 90 days; consent |
| TikTok cookies, for example _ttp (TikTok) | ad conversion measurement; up to 13 months; consent |
| Cloudflare Turnstile (Cloudflare) | bot protection on forms; session; necessary (security) |
You can change your choice at any time in the cookie banner, by clearing your browser's site data (which shows the banner again), or by emailing us. If you decline, the Google and TikTok tags are not loaded and no purchase event is sent to TikTok. Cookies that Google or TikTok set on their own domains before you declined cannot be removed by us; you can delete them in your browser settings.
We do not use Google Analytics.
10. Children
PPL Questions is for people aged 16 and over. We do not knowingly collect data from younger children. If you believe a child under 16 has created an account, contact us and we will delete it.
11. Security
We protect your data with:
- encrypted connections (HTTPS) for the website, web app and apps;
- passwords stored only as a salted one-way hash, never readable by us;
- optional two-factor authentication, account lockout after repeated failed logins, and rate limiting;
- one active web session per account, revocable app tokens, and secure storage on phones;
- access to the database and admin tools limited to authorised staff.
No system is perfectly secure. If a breach puts your data at risk, we will tell you and the supervisory authority as the law requires.
12. Changes to this policy
We will update this policy when our practices change. If the changes are significant, we will tell you by email or in the app before they take effect. The date at the top shows the latest version.
13. Contact
Questions about this policy or your data: contact@pplquestions.eu. Post: JTP S.R.L., limited liability company (societate cu răspundere limitată), Bulevardul Republicii 116, bl. 210, ground floor, ap. 3, room 1, 100286 Ploiești, Prahova, Romania.
Email: contact@pplquestions.eu