Privacy Policy

1. Who we are and how to contact us

PC-24 Study is owned and operated by JLEC Ltd, a limited company registered in Jersey, Channel Islands. JLEC Ltd is the data controller for personal data collected through the PC-24 Study iOS application and the website at pc24study.com.

Contact: support@pc24study.com

We are based in Jersey. Your data is processed in accordance with the Data Protection (Jersey) Law 2018. Where applicable, we also adhere to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 in respect of users based in the United Kingdom, and to EU GDPR in respect of users located in the European Economic Area (EEA).

2. What personal data we collect

We collect only the minimum personal data necessary to provide our service:

• Email address — collected when you create an account using email and password registration.
• Authentication identifier — if you use Sign in with Apple, we receive an anonymised identifier. Apple may optionally provide your name and email address.
• Subscription and purchase data — processed by RevenueCat on our behalf, including your Apple ID account information and purchase history, to verify your subscription entitlement.

We do not collect the following:

• Quiz results, progress data, or study history — these are stored locally on your device only and are never transmitted to us.
• Location data, device identifiers, advertising IDs, or any behavioural tracking data.

3. Legal basis for processing

Under the applicable data protection legislation, we must have a lawful basis for processing your personal data. The table below sets out our processing activities and their lawful basis:

Purpose	Data used	Lawful basis
Creating and managing your account	Email address, authentication identifier	Contract — necessary to provide the service you have requested
Verifying subscription and granting access	Subscription/purchase data via RevenueCat	Contract — necessary to fulfil your subscription agreement
Sending password reset emails	Email address	Legitimate interests — enabling account recovery at your request
Responding to support requests	Email address, information you provide	Legitimate interests — providing customer support

We do not process your personal data on the basis of consent, and we do not use your data for automated decision-making or profiling.

4. Third-party processors

We share personal data with the following third-party processors, who process data on our behalf under appropriate data processing agreements:

Processor	Purpose	Data shared
Supabase Inc.	Authentication, database infrastructure, and account deletion. Your email address and account credentials are stored on Supabase’s servers in the EU region.	Email address, authentication identifier
RevenueCat Inc.	Subscription management and entitlement verification.	User ID, purchase receipts
Apple Inc.	Payment processing via the App Store and Sign in with Apple authentication.	Handled directly by Apple under their own privacy policy

We do not sell, rent, or share your personal data with any third parties for marketing or advertising purposes.

5. International transfers

Supabase Inc. and RevenueCat Inc. are companies based in the United States. Where your personal data is transferred outside Jersey, the UK, or the EEA, we rely on appropriate safeguards to ensure your data remains protected. These include Standard Contractual Clauses (SCCs) and, where applicable, the UK International Data Transfer Agreement (IDTA), as provided under the data processing agreements we hold with each processor.

Supabase stores data in EU-based infrastructure. RevenueCat may process data in the United States and relies on SCCs for transfers from the EEA and the UK IDTA for transfers from the UK.

6. Data retention

• Account data — retained for the duration your account is active.
• Account deletion — we will delete or anonymise your personal data within 30 days of a deletion request, except where retention is required by law.
• Subscription records — may be retained for up to 7 years where required for financial and tax record-keeping obligations under applicable law.

7. Data security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. These include:

• Encrypted data transmission using TLS/HTTPS
• Encrypted data storage at rest via Supabase’s infrastructure
• Access controls limiting who can access your data
• Hashed password storage — we never store your password in plain text

8. Your rights

You have the following rights in relation to your personal data. To exercise any of these rights, please contact us at support@pc24study.com. We will respond within one calendar month. There is no charge for making a request.

• Right of access — you can request a copy of the personal data we hold about you.
• Right to rectification — you can ask us to correct inaccurate or incomplete data.
• Right to erasure — you can ask us to delete your personal data (“right to be forgotten”), subject to certain legal exceptions.
• Right to restriction — you can ask us to restrict processing of your data in certain circumstances.
• Right to data portability — you can request your data in a structured, commonly used, machine-readable format.
• Right to object — you can object to processing based on legitimate interests.
• Right not to be subject to automated decisions — we do not use automated decision-making or profiling.

9. Right to lodge a complaint

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the relevant supervisory authority:

• Jersey Office of the Information Commissioner (JOIC) — the supervisory authority for data protection in Jersey, and our primary authority as a Jersey-registered company. Website: jerseyoic.org
• Information Commissioner’s Office (ICO) — if you are based in the UK. Website: ico.org.uk  •  Phone: 0303 123 1113
• Your local data protection authority — if you are based in the EEA.

10. Cookies and tracking

The PC-24 Study app does not use cookies or any form of tracking technology. The pc24study.com website does not use analytics, advertising cookies, or tracking scripts. No cookie consent banner is required as no cookies are set.

11. Children’s privacy

PC-24 Study is intended solely for professional pilots and aviation students aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has provided us with personal data, please contact us at support@pc24study.com and we will delete it promptly.

12. Changes to this policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will update the date at the top of this page when changes are made. For significant changes, we will notify users via the app or by email where we hold your contact details.

13. Contact us

For any questions, requests, or concerns regarding this privacy policy or our data practices, please contact us at: support@pc24study.com