Passage

Privacy Policy

Effective date: August 3, 2026

This Privacy Policy explains how chastainco (“we”, “us”, or “our”) handles information in connection with our iOS app (the “App”), available on the Apple App Store.

By using the App, you agree to the collection and use of information in accordance with this policy.

1. Who we are (Data Controller)

Company: chastainco
Contact email: privacy@chastainco.com

If you have any questions about this policy or your personal data, contact us at privacy@chastainco.com.

2. What data we collect

Data you store on your device (we do not collect this)

The App is a local-first exam application. There is no account, no login, and no developer-run servers.

The following data is created and stored only on your device:

Exam content you create, edit, or import (including secure, encrypted exams)
Images attached to exams
Your exam results and history
App settings (e.g., theme, haptics, ad-free status)

This data is stored locally (SwiftData and app storage on your device) and is never transmitted to us. It leaves your device only when you choose to share or export it (for example, by sharing an .exam file).

Data collected automatically by third parties

Google AdMob (advertising). The App displays advertisements served by Google’s AdMob platform. Google may collect mobile advertising identifiers, device identifiers, IP address, and device/usage information to serve ads, measure performance, and prevent fraud. Where required, the App asks for your consent before personalized ads are shown. Google’s privacy policy is available at https://policies.google.com/privacy.
Apple. The App is distributed through the Apple App Store, and in-app purchases are processed by Apple’s StoreKit. Apple handles the transaction and may provide us with non-personal transaction records.

The App does not use third-party analytics or crash-reporting SDKs.

3. How we use data

To provide and operate the App’s features (creating, taking, and reviewing exams)
To display advertisements (personalized with your consent, or non-personalized otherwise)
To measure ad performance and prevent fraud or abuse
To support and respond to your inquiries

For users in the EEA, UK, and Switzerland, we rely on the following legal bases:

Consent (Art. 6(1)(a)): to show personalized ads
Legitimate interest (Art. 6(1)(f)): to show non-personalized ads, prevent fraud, and maintain app security
Contract / performance (Art. 6(1)(b)): to provide the App’s core features at your request

We do not process special categories of personal data.

We share information only as described here:

Google (AdMob) — for advertising (see Section 2)
Apple — for App Store distribution and in-app purchases

We do not sell, rent, or trade your personal information.

6. International transfers

Google may process data outside the EEA, UK, or Switzerland. Where such transfers occur, Google relies on appropriate safeguards, including the EU Standard Contractual Clauses and applicable adequacy decisions. See Google’s privacy policy for details.

7. Data retention

On-device data is retained until you delete it or uninstall the App.
Advertising data is processed by Google in accordance with Google’s own retention policies.

8. Your rights

Depending on your location (e.g., EEA, UK, or Switzerland), you may have the right to:

Access and obtain a copy of your personal data
Rectify inaccurate data
Erase your personal data
Restrict or object to processing
Data portability
Withdraw consent at any time (without affecting the lawfulness of processing before withdrawal)

You can exercise your rights by contacting us at privacy@chastainco.com. You also have the right to lodge a complaint with your local data protection supervisory authority.

For ad consent choices, you can change your choice at any time using the Privacy Options entry in the App’s Settings, or by resetting your device’s advertising identifier.

9. Children

The App is not directed to children under 16 years of age, and we do not knowingly collect personal information from children. If you believe a child has provided us information, contact us at privacy@chastainco.com.

10. Advertising identifiers

The App uses mobile advertising identifiers to serve and measure ads. You can reset or limit this identifier at any time under your device’s Settings → Privacy & Security (e.g., “Tracking” and “Reset Advertising Identifier”). Where consent is required, personalized ads are only shown after you consent via the consent form presented by the App.

11. Security

App data is stored locally on your device. Secure exam content is encrypted on-device using Apple’s cryptography frameworks (AES-GCM via CryptoKit). We cannot guarantee absolute security, but we take reasonable measures consistent with industry practice.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Effective date” at the top of this page. Material changes will be communicated through the App or on this page.

13. Contact

If you have questions about this Privacy Policy or our data practices, contact us at:

chastainco
privacy@chastainco.com