Last updated: July 2026
Freetops Studio ("we", "us", "our") operates citizenship test preparation mobile applications. This policy applies to all our apps globally, including users in Canada, the United Kingdom, the European Union, and Australia.
This Privacy Policy applies to the following mobile applications operated by Freetops Studio:
Freetops Studio is the brand operated by Willy Gilbert, the Google Play developer account holder, and is the developer and operator of these applications.
Freetops Studio
Developer and operator of the applications listed in this Privacy Policy
Account holder: Willy Gilbert
Location: Canada
Contact: freetops.studio@gmail.com
| Data | Source | Purpose | Legal Basis (GDPR) |
|---|---|---|---|
| Name, email | Google/Apple Sign-In | Account identity, sync | Contract (Art. 6(1)(b)) |
| Study progress, scores, streaks | App usage | Learning functionality | Contract (Art. 6(1)(b)) |
| Device identifier (anonymous UUID) | Auto-generated | Anti-abuse, session management | Legitimate interest (Art. 6(1)(f)) |
| Advertising identifiers (GAID/IDFA) | Google AdMob SDK | Show relevant ads (free users) | Consent (Art. 6(1)(a)) |
| Subscription status | Apple/Google stores | Premium feature access | Contract (Art. 6(1)(b)) |
We do NOT collect: location, contacts, camera, health data, financial/payment card information, or content of your messages.
Free users see ads via Google AdMob. Before showing personalized ads, we request your consent via a consent form (Google UMP). If you decline, you will see non-personalized ads or no ads.
On iOS, we request App Tracking Transparency (ATT) permission before any ad-related tracking. You can change this at any time in your device Settings.
Premium subscribers see no ads at all.
Your data is stored on servers in the United States (Google Cloud, Iowa region). Data is encrypted in transit (TLS) and at rest (Google-managed encryption).
International transfers: If you are in the UK or EU, your data is transferred to the US under Google Cloud's Standard Contractual Clauses (SCCs) and Data Processing Agreement. Google Cloud is certified under the EU-US Data Privacy Framework.
Regardless of where you live, you have the right to:
If you are in the UK or European Economic Area, you also have the right to:
Our apps are intended for users aged 16 and older. We require age confirmation during onboarding. We do not knowingly collect data from anyone under 16. If you believe a child under 16 has provided us data, contact us and we will delete it.
| Provider | Purpose | Data Shared |
|---|---|---|
| Google (AdMob) | Advertising | Ad identifiers, device info (with consent) |
| Google (OAuth) | Sign-In | Email, name (you authorize this) |
| Apple (OAuth) | Sign-In | Email (optional), name |
| Google Cloud | Hosting | All account data (as processor) |
| Apple/Google Stores | Payments | Transaction IDs only (they handle payment cards) |
We do not sell your personal data. We do not share data with data brokers.
We protect your data with: HTTPS encryption in transit, encryption at rest, bcrypt password hashing, rate limiting, and secure token storage (iOS Keychain / Android Keystore).
We may update this policy. Material changes will be communicated via an in-app notice. The "Last updated" date above reflects the most recent revision.
For privacy questions, data requests, or complaints:
freetops.studio@gmail.com
If you are in the UK and wish to contact the ICO: ico.org.uk
If you are in the EU: contact your national data protection authority.