Privacy Policy

1. Introduction

Test Apps Limited ("we," "us," "our," or "Company") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy applies to all our mobile applications and related services, including but not limited to:

1.1 Controller Information

Test Apps Limited is the data controller for the personal information collected through our applications. We are incorporated in New Zealand and operate under New Zealand privacy laws, while also complying with international privacy regulations including GDPR, CCPA, and other applicable privacy laws.

1.2 Scope of This Policy

This Privacy Policy covers:

• Information collection practices across all our applications
• How we use, process, and store your personal information
• Your rights regarding your personal information
• Our data security measures and retention policies
• Information sharing and disclosure practices
• Compliance with international privacy laws

2. Information We Collect

We collect various types of information to provide and improve our services. The information we collect falls into several categories:

2.1 Information You Provide Directly

2.2 Information Collected Automatically

2.3 Information from Third Parties

We may receive information from third-party services integrated with our applications:

• Apple App Store: Purchase information, subscription status (processed by Apple)
• Analytics Services: Aggregated usage statistics and performance metrics
• Advertising Partners: Limited advertising identifiers for personalized ads (with your consent)
• Social Media Platforms: If you choose to connect social accounts (with explicit permission)

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Primary Service Provision

• Assessment Delivery: Processing your test responses and generating personalized results
• Account Management: Creating and maintaining your user account
• Content Personalization: Customizing content and recommendations based on your preferences
• Progress Tracking: Storing your test history and progress over time

3.2 Service Improvement and Development

• Analytics: Understanding how users interact with our applications
• Feature Development: Developing new features based on user needs and usage patterns
• Quality Assurance: Testing and improving application performance
• Research: Conducting anonymized research to improve assessment methodologies

3.3 Communication and Support

• Customer Support: Responding to your inquiries and providing technical assistance
• Service Updates: Notifying you about important changes or new features
• Educational Content: Providing relevant health and wellness information (where applicable)
• Marketing Communications: Sending promotional content (only with your explicit consent)

3.4 Legal and Compliance

• Legal Obligations: Complying with applicable laws and regulations
• Safety and Security: Protecting against fraud, abuse, and security threats
• Dispute Resolution: Resolving conflicts and enforcing our terms of service

4. Information Sharing and Disclosure

We do not sell your personal information to third parties. However, we may share your information in the following limited circumstances:

4.1 Service Providers

We work with trusted third-party service providers who assist us in operating our applications:

4.2 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal process, court orders, or government requests
• Enforce our Terms of Service or other agreements
• Protect our rights, property, or safety, or that of our users
• Investigate potential violations of law or our policies

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of the transaction. We will:

• Provide notice before your information is transferred
• Ensure the acquiring party agrees to protect your information under terms no less protective than this Privacy Policy
• Give you the opportunity to opt-out if the new privacy practices are materially different

4.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. This may include:

• Statistical reports about app usage trends
• Research findings based on anonymized assessment data
• Industry benchmarks and insights

5. Data Security

We implement comprehensive security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

5.1 Technical Safeguards

• Encryption: All data is encrypted in transit using TLS 1.3 and at rest using AES-256 encryption
• Access Controls: Multi-factor authentication and role-based access controls for our systems
• Network Security: Firewalls, intrusion detection systems, and regular security monitoring
• Secure Development: Security-by-design principles in our application development process
• Regular Updates: Timely security patches and system updates

5.2 Organizational Safeguards

• Staff Training: Regular privacy and security training for all employees
• Access Limitation: Information access limited to employees who need it for their job functions
• Confidentiality Agreements: All staff and contractors sign confidentiality agreements
• Incident Response: Documented procedures for responding to potential security incidents
• Regular Audits: Periodic security assessments and vulnerability testing

5.3 Data Breach Response

In the unlikely event of a data breach, we will:

• Investigate and contain the breach immediately
• Assess the scope and impact of the incident
• Notify affected users within 72 hours where required by law
• Report to relevant supervisory authorities as required
• Implement additional measures to prevent future incidents
• Provide support and guidance to affected users

6. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes for which it was collected or as required by law.

6.1 Retention Periods

6.2 Secure Deletion

When we delete your personal information:

• Data is permanently removed from our active systems
• Backup copies are systematically purged according to our retention schedule
• Physical media containing your data is securely destroyed
• We maintain logs of deletion activities for compliance purposes

6.3 Account Deletion

You can request account deletion at any time by contacting us. Upon account deletion:

• Your account becomes immediately inaccessible
• Personal information is deleted according to our retention schedule
• Some information may be retained for legal compliance or legitimate business purposes
• Anonymized or aggregated data may be retained for analytical purposes

7. Your Privacy Rights

You have various rights regarding your personal information, depending on your location and applicable privacy laws.

7.2 How to Exercise Your Rights

To exercise any of these rights:

1. Contact Us: Email us at hello@testapps.com with your request
2. Verification: We may need to verify your identity to protect your privacy
3. Processing Time: We will respond within 30 days (or as required by applicable law)
4. No Fee: Exercising your rights is generally free of charge

7.3 Limitations

Some rights may be limited in certain circumstances:

• Legal obligations may require us to retain certain information
• Legitimate interests may justify continued processing
• Technical limitations may affect how quickly we can process requests
• Rights of others may limit what information we can provide or delete

8. International Data Transfers

As a global service, we may transfer your personal information to countries outside of your residence. We ensure all transfers are protected by appropriate safeguards.

8.1 Transfer Locations

Your personal information may be transferred to and processed in:

• New Zealand: Our primary operations base
• United States: Cloud hosting and analytics services
• European Union: Data processing and support services
• Other Countries: As necessary for service provision with appropriate safeguards

8.2 Transfer Safeguards

We implement the following safeguards for international transfers:

• Adequacy Decisions: Transfers to countries recognized as providing adequate protection
• Standard Contractual Clauses: EU-approved contractual protections for data transfers
• Binding Corporate Rules: Internal policies ensuring consistent protection
• Certification Schemes: Third-party certifications demonstrating privacy compliance
• Codes of Conduct: Industry standards for privacy protection

8.3 Your Rights Regarding Transfers

You have the right to:

• Obtain information about the countries where your data is processed
• Request copies of the safeguards protecting your data during transfers
• Object to transfers in certain circumstances
• Lodge complaints with supervisory authorities about international transfers

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and analyze usage patterns.

9.1 Types of Cookies We Use

9.2 Managing Cookies

You can control cookies through:

• App Settings: Cookie preferences within our applications
• Device Settings: Browser or device-level cookie controls
• Opt-out Tools: Industry opt-out mechanisms for advertising cookies
• Contact Us: Request specific cookie management assistance

9.3 Other Tracking Technologies

We may also use:

• Web Beacons: Track email engagement and app usage
• Device Fingerprinting: Identify devices for security purposes
• Analytics SDKs: Collect usage statistics and performance data
• Advertising IDs: Deliver personalized advertisements (with consent)

10. Third-Party Services and Integrations

Our applications integrate with various third-party services to provide enhanced functionality.

10.1 Apple Services Integration

As iOS applications, we integrate with various Apple services:

• App Store: App distribution and in-app purchases
• Apple ID: Authentication and account management (optional)
• HealthKit: Health data integration (with explicit permission)
• CloudKit: Data synchronization across devices (optional)
• Push Notifications: App notifications and updates

10.2 Analytics and Performance Services

• Firebase Analytics: Usage analytics and crash reporting
• App Store Analytics: App performance and user acquisition metrics
• Custom Analytics: Internal analytics for service improvement

10.3 Advertising and Marketing Services

With your consent, we may use:

• Apple Search Ads: Advertising attribution and measurement
• Third-party Ad Networks: Personalized advertising delivery
• Marketing Platforms: Email marketing and user engagement

10.4 Third-Party Privacy Policies

Third-party services have their own privacy policies:

• Apple Privacy Policy
• Google Privacy Policy (Firebase)
• Other third-party services as integrated and disclosed within our applications

11. Children's Privacy

We are committed to protecting the privacy of children and comply with applicable children's privacy laws.

11.1 Age Restrictions

• Minimum Age: Our applications are intended for users 17 years and older
• Parental Consent: Users under 18 must have parental permission
• No Children Under 13: We do not knowingly collect information from children under 13

11.2 If We Learn of Child Data Collection

If we discover we have collected information from a child under 13:

• We will delete the information immediately
• We will terminate any associated accounts
• We will notify parents if we have their contact information
• We will implement additional measures to prevent future collection

11.3 Parental Rights

Parents have the right to:

• Review any personal information we have collected about their child
• Request deletion of their child's personal information
• Refuse to allow further collection or use of their child's information
• Contact us with questions about our children's privacy practices

12. Health Data and Sensitive Information

Some of our applications collect health-related information. We handle this sensitive data with extra care and protection.

12.1 Types of Health Data

Our health-related applications may collect:

• Assessment Responses: Answers to mental health screening questions
• Symptom Information: Self-reported symptoms and experiences
• Progress Data: Changes in assessment results over time
• Wellness Goals: Personal health and wellness objectives

12.2 Special Protections for Health Data

• Enhanced Encryption: Additional encryption layers for health information
• Limited Access: Strict access controls for health-related data
• Explicit Consent: Clear consent for health data collection and use
• Professional Standards: Adherence to healthcare privacy standards

12.3 Health Data Usage

We use health data only for:

• Providing assessment results and recommendations
• Tracking your progress over time (with your consent)
• Improving our assessment tools (using anonymized data)
• Complying with applicable health privacy laws

12.4 HealthKit Integration (iOS)

If you choose to integrate with Apple HealthKit:

• You control what data is shared
• Data remains encrypted and secure
• You can revoke access at any time
• We follow Apple's HealthKit privacy requirements

13. California Privacy Rights (CCPA/CPRA)

California residents have additional privacy rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

13.1 Categories of Personal Information

*Limited sharing for advertising purposes with your consent

13.2 Your California Rights

• Right to Know: Request information about personal information collection and use
• Right to Delete: Request deletion of personal information
• Right to Correct: Request correction of inaccurate information
• Right to Opt-Out: Opt-out of sale or sharing for advertising
• Right to Limit: Limit use of sensitive personal information
• Right to Non-Discrimination: Equal treatment regardless of exercising rights

13.3 Exercising California Rights

California residents can exercise their rights by:

• Emailing us at hello@testapps.com
• Using our online request form (if available)
• Contacting us through our applications

13.4 Verification Process

We may need to verify your identity by requesting:

• Email verification
• Account credentials
• Additional identifying information

14. European Privacy Rights (GDPR)

Individuals in the European Economic Area (EEA), UK, and Switzerland have additional rights under the General Data Protection Regulation (GDPR).

14.1 Legal Basis for Processing

14.2 Your GDPR Rights

• Right of Access: Obtain confirmation and details about processing
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion ("right to be forgotten")
• Right to Restrict Processing: Limit how we process your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for consent-based processing

14.3 Data Protection Officer

You can contact our Data Protection Officer at:

• Email: hello@testapps.com
• Subject Line: "GDPR / Data Protection Inquiry"

14.4 Supervisory Authority

You have the right to lodge a complaint with your local supervisory authority if you believe we have not handled your personal data properly. Contact details for EU supervisory authorities are available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

15.1 Notification of Changes

When we make changes, we will:

• Update the Date: Change the "Last Updated" date at the top of this policy
• In-App Notification: Notify users through our applications for significant changes
• Email Notification: Send email notifications for material changes (if we have your email)
• Website Notice: Post notices on our website

15.2 Types of Changes

• Minor Changes: Clarifications, formatting, or non-substantive updates
• Material Changes: Significant changes to data practices or your rights
• Legal Updates: Changes required by new laws or regulations

15.3 Your Options

When we make material changes:

• You can continue using our services under the new terms
• You can contact us with questions or concerns
• You can exercise your rights to access, correct, or delete your data
• You can stop using our services if you disagree with the changes

16. Contact Information

We're here to help with any privacy questions or concerns you may have.