1. Introduction

PCO Direct ("we," "us," or "our") is committed to protecting the privacy of users ("you" or "your") of our SERU Mock Test application (the "App") and website (the "Website"). This Privacy Policy explains how we collect, use, share, and protect your personal information. We are committed to being transparent about our data practices and respecting your privacy rights.

This Privacy Policy applies to both the mobile application and the web application of PCO Direct, accessible at pco-direct.co.uk and through mobile app stores.

2. Information We Collect

We collect the following categories of personal information:

We aim to collect only the personal information that is necessary for the purposes described in this Privacy Policy (data minimization principle). "Personal information" refers to any information that can be used to identify you directly or indirectly.

3. How We Use Your Information

We use your information for the following purposes:

• Providing and Personalizing the App and Website: To provide you with access to the App and Website and all its features, including delivering mock tests, tracking your progress, personalizing your learning experience, and ensuring the App functions correctly.
• Tracking Test Results and Providing Feedback: To monitor your performance in mock tests, calculate scores, provide you with feedback on your strengths and weaknesses, and offer insights to help you improve your test preparation.
• Communication about Your Account and the App: To communicate with you about your account, respond to your inquiries, send service announcements, provide updates about the App, and send important notifications related to your use of the App.
• Improving the App and Website and Developing New Features: To analyze App usage trends, understand user behavior, identify areas for improvement in the App's design and functionality, troubleshoot bugs and errors (using Sentry), and develop new features and content that better meet user needs and preferences. This processing relies on our legitimate interest in continually improving our services.
• Analyzing App Usage Trends: We use Google Analytics to analyze aggregated and anonymized data about how users interact with the App. This helps us understand overall usage patterns, popular features, and areas where users may experience difficulties, enabling us to make data-driven decisions to improve the App.
• Processing Payments: To process payments for any paid features through Stripe.
• Monitoring and Addressing Errors and Bugs: We use Sentry to monitor the App for errors and bugs, helping us to quickly identify and resolve technical issues to ensure the App runs smoothly and reliably.
• Legal Compliance and Protection: We may use and disclose your information if we believe it is necessary to comply with applicable laws, regulations, legal processes, or enforceable governmental requests; enforce our terms of service; detect, prevent, or address fraud, security, or technical issues; or protect against harm to the rights, property, or safety of PCO Direct, our users, or the public as required or permitted by law.

4. Data Sharing

We do not sell, trade, or rent your personal information to third parties. We share your information with the following categories of third-party service providers who assist us in providing and improving the App and Website, only to the extent necessary for them to perform their services:

• Google Analytics: For app analytics and understanding user behavior. Google Analytics helps us analyze how users interact with the App as described in Section 3. Their privacy policy can be found at: https://policies.google.com/privacy. Data Transfer: Google Analytics may transfer data outside of the UK and EEA. Please refer to Google Analytics' privacy policy for information on their data transfer mechanisms and safeguards.
• Stripe: For processing payments securely. Stripe handles all payment processing, and we do not directly access or store your full payment card details. Their privacy policy can be found at: https://stripe.com/gb/privacy. Data Transfer: Stripe may transfer data outside of the UK and EEA. Please refer to Stripe's privacy policy for information on their data transfer mechanisms and safeguards.
• Sentry: For error tracking and reporting. Sentry helps us monitor and resolve technical issues in the App. Their privacy policy can be found at: https://sentry.io/privacy/. Data Transfer: Sentry may transfer data outside of the UK and EEA. Please refer to Sentry's privacy policy for information on their data transfer mechanisms and safeguards.
• Render: For hosting our website and database, ensuring the App and Website are available to you. Their privacy policy can be found at: https://render.com/privacy. Data Transfer: Render may transfer data outside of the UK and EEA. Please refer to Render's privacy policy for information on their data transfer mechanisms and safeguards.
• Brevo: For sending email communications, such as service announcements and account-related notifications. Their privacy policy can be found at: https://www.brevo.com/legal/privacypolicy/. Data Transfer: Brevo may transfer data outside of the UK and EEA. Please refer to Brevo's privacy policy for information on their data transfer mechanisms and safeguards.

We will also disclose your information if required to do so by law, legal process (such as a court order or subpoena), or a legitimate governmental request.

5. Data Retention

We retain your personal data for as long as your account is active and as needed to provide you services. If you choose to delete your account, we will delete your personal information within 30 days of your deletion request, unless we are legally required to retain it for a longer period. You can request deletion of your account and personal data at any time by contacting us at info@pcodirect.co.uk.

Even after you delete your account and your personal data is removed from our active systems, we may retain aggregated and anonymized data derived from your information for analytical and statistical purposes, to improve our services. This aggregated and anonymized data cannot be used to identify you.

6. Your Rights

You have the right to access, correct, or delete your personal information. You can access and update your information through your account settings within the App or Website. To request deletion, please contact us at info@pcodirect.co.uk.

You have the following rights regarding your personal information:

• Right to Access: You have the right to access and obtain a copy of the personal information we hold about you. You can access and update some of your information, such as your name and email address, through your account settings within the App or Website. For a full copy of your data, please contact us.
• Right to Rectification: You have the right to correct any inaccurate or incomplete personal information we hold about you. You can update some of your information through your account settings. For corrections that you cannot make yourself, please contact us.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal information. You can request deletion by contacting us at info@pcodirect.co.uk. We will comply with your request to delete your data as described in Section 5, unless we have a legal obligation to retain it.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal information in certain circumstances.
• Right to Objection to Processing: You have the right to object to the processing of your personal information in certain circumstances, particularly where we are processing your data based on our legitimate interests.
• Right to Data Portability: To the extent applicable (and where technically feasible), you have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Withdraw Consent: If we rely on your consent to process your personal information (which we generally do not for the core functionality of this App), you have the right to withdraw your consent at any time. As we primarily rely on legitimate interests and contractual necessity for processing, this right is less frequently applicable, but you can always contact us with privacy-related concerns.

To exercise any of these rights, please contact us at info@pcodirect.co.uk. We will respond to your request within 30 days.

7. Data Security

We take reasonable technical and organizational measures to protect your information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit and at rest where appropriate.
• Access controls to limit access to personal information to authorized personnel only.
• Regular security assessments and updates to our security practices.

However, please remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

8. Children's Privacy

Our App and Website are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under 13 has provided us with personal information, please contact us at info@pcodirect.co.uk, and we will take steps to delete that information and terminate the child's account.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, services, or legal requirements. We will post any changes on the Website and within the App and update the "Effective Date" at the top of this policy. For significant changes, we may also provide more prominent notice, such as sending an email to registered users or displaying an in-app notification. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the App or Website following the posting of changes constitutes your acceptance of the revised Privacy Policy.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

11. Governing Law

This Privacy Policy is governed by the laws of England and Wales.