FRM Exam Prep: Part 1 & 2 — Privacy Policy
Effective date: October 11, 2026
FRM Exam Prep: Part 1 & 2 ("FRM Prep", "the app") is published by Vitalii Haliuk, an individual developer ("we", "us"). This policy explains what personal data the app and this website handle, why, who receives it and what choices you have.
In short
- Your study data stays on your device. We cannot see it.
- There are no accounts, no advertising, no tracking and no analytics tools in the app.
- The app sends nothing about you to us. Purchases are handled by Apple, and the only thing you send us is what you choose to write to us.
Who is responsible
Vitalii Haliuk is the controller of the personal data described below. You can reach us at exampass.support@gmail.com.
What we handle, why, and for how long
Study data on your device
Your answers, review schedule, bookmarks, notes, exam simulations, settings, exam dates, retake settings, calculator choice and Error DNA profile are stored only on your device. Part I and Part II keep separate records. The app does not sync them to any server or to iCloud, we never receive them and we have no access to them. They are included in your device's own backups (iCloud or computer) according to your device settings, which Apple controls.
You can delete the data at any time with Settings > Your data > Reset progress, or by deleting the app.
To keep a time-limited pass from being stretched by setting the clock back, the app also keeps the latest date and time confirmed by Apple's purchase servers in your device's Keychain. It is a single timestamp with no personal information, it never leaves your device, and iOS may keep it after the app is deleted.
Purchases and subscriptions
Purchases and subscriptions are processed by Apple. We never receive your name, email address or payment details, and the app does not send purchase data to us or to any service of ours: it asks Apple's StoreKit what you have bought, on your device. Apple gives us aggregated sales and subscription reports that do not identify you.
When you write to us
If you email us, including with "Report a problem" on a question, we receive your email address, your message and anything you include. The "Report a problem" email also contains the question identifier, the question bank version, and the app and iOS versions, so that we can find the question you mean. We use this only to answer you and to correct questions. Our legal basis is our legitimate interest in supporting users (and, if you have bought a plan, performance of the contract). We keep correspondence for as long as needed to resolve it and for up to 24 months afterwards, unless the law requires longer. Our mailbox is hosted by Google (Gmail).
Widgets, Siri shortcuts and Spotlight
To show your countdown, readiness and streak on the Home Screen and Lock Screen, the app writes a small summary (days to your exam, readiness, streak, today's progress) into a storage area shared only between the app and its own widgets on your device (an App Group). Nothing in it leaves your device. The Siri shortcut "How many days until my exam" reads the same summary on your device. The app also adds the names of formulas and curriculum readings to Spotlight on your device so that you can find them; Spotlight keeps this index on your device. You can remove the widgets at any time, and turn off the app's Spotlight results in iOS Settings > Siri & Search.
Reminders
If you turn on study reminders, the app schedules local notifications on your device. No notification data is sent to us or to anyone else. You can change this at any time in iOS Settings.
This website
This website consists of static pages. It uses no cookies, no analytics and no tracking. It is hosted by Cloudflare, which, as our hosting provider, processes technical data such as your IP address and request logs to deliver and protect the pages.
What we do not do
- No accounts or sign-in.
- No analytics, no crash-reporting service and no advertising or attribution SDKs, and no tracking across other companies' apps or websites.
- No access to your location, contacts, photos, camera or microphone.
- No profiling or automated decisions about you.
- We do not sell or share your personal information.
Who receives data
- Apple, for the App Store, payments and device backups, under Apple's own privacy policy.
- Google (email) and Cloudflare (website hosting).
We do not share personal data with anyone else, except where the law requires it.
Transfers outside your country
Google and Cloudflare operate globally. Where personal data of people in the European Economic Area or the United Kingdom is transferred outside those areas, it is protected by the safeguards the law requires, such as the contractual protections in our providers' data processing terms.
Your rights and choices
Depending on where you live (for example under the GDPR in the EU/UK or the CCPA/CPRA in California), you may have the right to access, correct, delete or restrict the use of your personal data, to receive a copy of it, and to object to its processing. Where we rely on your consent, you can withdraw it at any time (notification permission is managed in iOS Settings).
To use these rights, email exampass.support@gmail.com. We will reply within 30 days, or tell you if the law allows us a longer period. We may need to verify that a request is yours. We hold no purchase records of our own, so for purchases please contact Apple (https://reportaproblem.apple.com). Study data never leaves your device, so you control it directly.
If you think we handled your data unlawfully, you can complain to a data protection authority. In Poland this is the President of the Personal Data Protection Office (UODO, https://uodo.gov.pl); you may also contact the authority in your own country.
California residents: we do not sell or share personal information as those terms are defined in California law, and we do not use it for targeted advertising.
Children
The app is intended for adults and students preparing for a professional certification exam. It is not directed to children under 13 (or under 16 where the law of your country sets that age), and we do not knowingly collect their personal data. If you believe a child has sent us personal data, contact us and we will delete it.
Security
Purchase and support communications use encrypted connections. Your study data is protected by your device's own security (passcode and encryption). No method of storage or transmission is completely secure, so we cannot guarantee absolute security.
Changes
If we change this policy, we will update the effective date above and, for significant changes, tell you in the app.
Contact
Vitalii Haliuk
exampass.support@gmail.com