Privacy Policy

01 Information We Collect

We collect the minimum information necessary to provide the App's services. We collect information in the following categories:

A. Information You Provide

• Google Account Data: When you sign in using Google OAuth, we receive your full name, email address, profile photo URL, and a unique Google user ID. We use this information solely to authenticate your identity and associate your subscription with your account.
• Payment Information: When you subscribe, payment is processed through Google Play Billing (on Android) or Stripe's secure checkout (on the web). LNR never receives, processes, or stores your full credit card number, CVV, or banking credentials. Google Play or Stripe provides us only with a confirmation of payment and a customer identifier.

B. Information Collected Automatically

• Subscription Status: We store whether your subscription to this App is active or inactive in Google Firestore, associated with your user ID and email address.
• Device & Technical Data: Standard web server logs may record your IP address, browser type, operating system, referring URLs, and pages visited for security and operational purposes. This data is not linked to your personal identity.

C. Information We Do NOT Collect

02 How We Use Your Information

We do not use your personal information for advertising, marketing profiling, or sale to data brokers.

03 Legal Basis for Processing

For users in the European Economic Area (EEA) and United Kingdom, we process personal data under the following lawful bases as defined by the General Data Protection Regulation (GDPR):

• Contractual Necessity: Processing your login credentials and subscription status is necessary to provide the service you subscribed to.
• Legitimate Interests: We have a legitimate interest in maintaining the security of our systems, preventing fraud, and providing technical support.
• Legal Obligation: We may retain certain records to comply with applicable tax, accounting, and legal requirements.

04 Data Sharing & Third Parties

We do not sell, rent, trade, or otherwise disclose your personal information to any third party for commercial purposes. We share data only with the following service providers, strictly for the purpose of operating the App:

We may disclose your information if required to do so by law, court order, or governmental authority, or if we believe in good faith that such disclosure is necessary to protect our rights, your safety, or the safety of others.

05 Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy:

• Account & Subscription Data: Retained for the duration of your active subscription, plus up to 3 years after cancellation for legal and accounting purposes.
• Payment Records: Google Play and Stripe retain payment records per their own retention policies and applicable financial regulations.
• Server Logs: Automatically deleted after 90 days.

You may request early deletion of your data at any time by contacting us (see Section 14). Upon verified request, we will delete your Firestore records within 30 days, subject to any legal retention obligations.

06 Data Security

We take the security of your personal information seriously and implement multiple layers of protection:

• Authentication: Google OAuth 2.0 — industry-standard, no passwords stored by us.
• Database Security: Google Firestore with role-based security rules ensuring users can only access their own records.
• Payment Security: Google Play Billing and Stripe are PCI DSS Level 1 certified — the highest level of payment security certification.
• Transport Security: All data is transmitted over HTTPS/TLS encryption.
• Access Controls: Only authorized LNR personnel have access to production systems and databases.

While we implement these safeguards, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security but commit to notifying affected users promptly in the event of a data breach (see Section 12).

07 Your Rights

Depending on your location, you may have the following rights regarding your personal data:

To exercise any of these rights, contact us at info@lnrcs.com. We will respond within 30 days. We may need to verify your identity before processing your request.

08 California Residents — CCPA Rights CCPA

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you specific rights regarding your personal information:

• Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months.
• Right to Delete: You have the right to request deletion of personal information we have collected, subject to certain exceptions.
• Right to Opt-Out of Sale: We do not sell your personal information. However, you may submit a "Do Not Sell My Personal Information" request and we will confirm our non-sale policy.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To submit a CCPA request, email us at info@lnrcs.com with the subject line "CCPA Request."

09 Children's Privacy COPPA

This App is not directed to, and is not intended for use by, children under the age of 13 in the United States, or under the applicable age of digital consent in other jurisdictions (16 in the EEA). We do not knowingly collect personal information from children under these ages.

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us immediately at info@lnrcs.com. Upon verification, we will promptly delete such information from our systems.

10 International Data Transfers

LNR Consulting Services LLC is based in the United States. If you access the App from outside the United States, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your country.

For users in the European Economic Area (EEA) or United Kingdom, we rely on Standard Contractual Clauses (SCCs) and the data processing agreements of our service providers (Google and Stripe) to ensure adequate protection of your data when transferred internationally.

11 Cookies & Tracking Technologies

The App uses the following limited tracking technologies:

• Firebase Authentication Cookies: Used to maintain your login session. These are strictly necessary for the App to function and cannot be disabled.
• Local Storage: Used to temporarily store your study session state (e.g., which card you are on). No personal data is stored in local storage.

We do not use advertising cookies, third-party tracking pixels, Google Analytics, Facebook Pixel, or any behavioral advertising technology. We do not serve advertisements.

12 Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, LNR Consulting Services LLC will:

• Notify affected users via email within 72 hours of becoming aware of the breach (where feasible).
• Notify relevant supervisory authorities as required by applicable law.
• Provide a description of the nature of the breach, the data affected, and the steps we are taking to address it.
• Recommend steps you can take to protect yourself.

13 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. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Post a notice within the App notifying users of the change.
• For significant changes affecting your rights, send an email notification to your registered address.

Your continued use of the App after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically.

14 Contact Us