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Article 1 - Data Controller
ExamBuddy (accessible via www.exambuddy.nl) is the Data Controller responsible for the processing of personal data described in this Privacy Policy. For inquiries regarding data protection, you may reach our Data Protection Officer directly at exambuddyinfo@gmail.com.
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Article 2 - Personal Data We Collect
We collect and process the following categories of personal data:
• Account Data: Full name, email address, and encrypted (hashed) password.
• Study & Performance Data: Exam sessions, answer choices, Mistake Bank records, domain mastery scores, and study time logs.
• Payment & Invoicing Data: Transaction identifiers, purchased packages, purchase dates, and billing addresses. Sensitive payment card numbers are processed exclusively by certified payment processors (such as Stripe) and are never stored on our servers.
• Technical & Device Data: IP address, browser type, operating system, language preferences, and timestamped interaction logs.
• Support & Inquiries: Communications sent via our Help Center contact forms or support emails.
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Article 3 - Purposes & Legal Bases for Processing
We process your data strictly under the legal grounds established by the GDPR:
• Performance of a Contract (Art. 6(1)(b) GDPR): To grant access to purchased exam simulations, save study progress, and issue receipts.
• Legitimate Interests (Art. 6(1)(f) GDPR): To maintain platform security, prevent fraudulent activity, mitigate account sharing, and enhance our didactic curriculum.
• Legal Obligation (Art. 6(1)(c) GDPR): To fulfill statutory tax retention requirements (7 years for financial billing records under Dutch tax regulations).
• Consent (Art. 6(1)(a) GDPR): For optional communications or personalized study recommendations.
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Article 4 - AI Tutor (Buddy AI) Data Processing
When you interact with the AI Tutor, only question context and instructional queries are transmitted to generate real-time hints and explanations. No personally identifiable data (such as names or payment details) is passed to external AI models, and user data is never used to train public foundation models.
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Article 5 - Third-Party Service Providers (Processors)
We collaborate only with trusted third-party service providers bound by strict Data Processing Agreements (DPAs):
• Authentication & Cloud Hosting: Google Firebase (EU datacenters) and Amazon Web Services (AWS).
• Payment Processing: Stripe Payments Europe Ltd.
• Support & Communication Relays: Encrypted email relays for support dispatches.
We never sell or rent personal information to data brokers or advertising networks.
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Article 6 - Data Security Standards
We implement robust technical and organizational measures to safeguard your information against unauthorized access, loss, or alteration. These include end-to-end SSL/TLS encryption (HTTPS), cryptographic password hashing via Firebase Security, role-based access restrictions, and recurring vulnerability audits.
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Article 7 - Data Retention Periods
Personal data is retained only as long as necessary:
• Account and Study Records: Retained while your account remains active. Upon an account deletion request, personal data is permanently expunged or anonymized within 30 days.
• Invoices and Financial Data: Retained for 7 years pursuant to statutory tax requirements.
• Customer Support Messages: Retained for up to 12 months after resolution.
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Article 8 - Your Rights under the GDPR
Under the GDPR, you have the right to:
• Access (Art. 15 GDPR): Request a copy of the personal data we hold about you.
• Rectification (Art. 16 GDPR): Request correction of incomplete or erroneous records.
• Erasure / Right to be Forgotten (Art. 17 GDPR): Request permanent deletion of your account and study history.
• Restriction & Objection (Arts. 18 & 21 GDPR): Object to or restrict specific data processing activities.
• Data Portability (Art. 20 GDPR): Receive your study metrics in a structured, machine-readable format.
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Article 9 - Cookies & Local Storage
ExamBuddy uses solely essential functional cookies and browser storage (Local Storage / Session Storage). These are necessary to keep you authenticated, remember language settings, and ensure uninterrupted exam sessions. We do not use third-party behavioral tracking cookies.
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Article 10 - Policy Amendments
We may update this Privacy Policy to reflect regulatory evolutions or platform enhancements. The most recent version is always accessible at www.exambuddy.nl/privacy.
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Article 11 - Contact & Supervisory Authority
To exercise your privacy rights or submit questions regarding data protection, please contact us at exambuddyinfo@gmail.com . If you believe your personal data is being processed non-compliantly, you also retain the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).