Privacy Policy

This Privacy Policy (the "Policy") describes certain privacy practices of Urban Algorithm LLC ("Urban Algorithm LLC," "we," or "us"). Urban Algorithm LLC operates the Flying Prep test preparation platform. This Policy is intended to explain how we collect, use, and share your information in connection with our websites, including but not limited to the Flying Prep website and any affiliated subdomains, and the services we offer through the websites, including our test preparation tools, study guides, practice tests, and flashcards (collectively, the "Services"). This Policy covers information collected from our Services, from our business partners and service providers, and from other sources. We may also have other privacy policies, set forth separately in writing, specific to certain categories of information or individuals, such as information relating to residents or citizens of certain jurisdictions. Please also refer to our Terms of Service.

1. What Information We Collect

Included below are the types of information collected by Urban Algorithm LLC:

• Contact information, such as your name, address, email address, and telephone number.
• Account login or verification information (including third-party account-verification information if you choose to sign in with a third-party provider).
• Financial information, such as payment card information (e.g., credit or debit card number, CVV code, expiration date) or other financial account information. (Note that this information is stored through our payment processor rather than on Urban Algorithm LLC servers.)
• Internet or other network or device activity, such as information about the browsers and devices you use to access our Services, emails, and advertisements (e.g., device type, browser type and language, hardware model, operating system version, unique device identifiers, and IP address) and how you interact with our Services, emails, and advertisements.
• Location information, including geolocation when using our Services.
• Educational progress information, such as your study progress, quiz scores, practice test results, and learning analytics.
• Mobile device identifiers. When you use the Flying Prep iOS app, we receive Apple's Identifier for Vendor (IDFV), the iOS version, device model, and, if you enable notifications, an Apple Push Notification service (APNs) token. We do not use the Identifier for Advertisers (IDFA) and do not request App Tracking Transparency permission.
• In-app purchase information. When you subscribe through the iOS app, Apple acts as the payment processor through StoreKit and the App Store. We do not receive or store your payment-card information. We do receive an Apple-signed transaction record containing the product identifier, original transaction ID, purchase date, and expiration date so we can grant you access to the subscription you paid for.
• Voice recordings. When you answer a speaking-format language practice question, the iOS app records your spoken response using your device's microphone. The recording is uploaded to our servers so our automated scoring system can return feedback. Recordings are stored only as long as needed to deliver feedback and to improve our scoring (see Section 12, Data Retention). You can decline microphone permission at any time in iOS Settings; the rest of the app works without it.
• Photo uploads. When you choose to report a passed exam score, you can optionally attach a photo of your official score report from your iOS photo library. The image is uploaded to our private storage bucket and linked only to your account; we use it to verify the result you reported and never share it publicly. You can decline photo permission at any time in iOS Settings.
• Push notification token. If you grant notification permission, your device shares an Apple Push Notification service (APNs) token with us. We use this only to deliver notifications you have opted in to (such as study reminders).
• Other information that identifies or can be reasonably associated with you.

2. How We Collect Information

We collect the types of information described above in three ways: (1) when you provide it to us; (2) when we collect it automatically; and (3) when we receive it from other sources.

2.1 Information you provide to us

You provide information to us when you register for an account, use our Services, communicate with us, or otherwise submit or publish your information. For example, when you register for an account, you may provide contact information, account login or verification information, and financial information. When using our Services, you may provide information about your study preferences, educational goals, and learning progress.

2.2 Information we collect automatically

We automatically collect internet or other network or device activity information about your interactions with our Services, emails, and advertisements, even if you are not logged into an account with us.

2.3 Cookies and similar technologies

• Cookies and similar technologies are pieces of information stored directly on the device you are using.
• Cookies allow us to collect information such as browser type, time spent on our Services, pages visited, and language preferences.
• We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your online experience and our marketing and advertising efforts.
• You can choose to accept or decline cookies through your web browser. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you set your browser to reject cookies, parts of our Services may not work for you.

2.4 Analytics and advertising

To better understand how users engage with our Services, we use third-party analytics services that use cookies and similar technologies. We may also use third-party advertising services to provide advertisements for our services.

2.5 Do Not Track requests

Some browsers may transmit "Do Not Track" or "DNT" signals to the websites you visit. Because there is not common agreement about how to interpret DNT signals, we do not take action in response to them.

2.6 Location information

We may collect information about the location of your device, including precise geolocation information from your device and imprecise location from, for example, your IP address. You may be able to adjust the location settings of your device to control whether it communicates location information.

3. How We Use The Information

We will not sell your information to data brokers or other third parties for money. We may use and process the types of information described above to:

• Provide our Services to you and other users. For example, we use your information to provide personalized study recommendations, track your progress across exams, and deliver practice tests and flashcards.
• Maintain, protect, and improve our Services or other products. This may include customizing our Services to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; analyzing how they are used; and evaluating, maintaining, and improving their performance, effectiveness, security, and safety.
• Process payments and transactions through a 3rd party payment processor.
• Communicate and manage our relationship with you. This may include providing you information about our Services or about your transactions with us; responding to your questions, inquiries, or requests; and customizing and improving our communications with you.
• Develop new applications or other products or services.
• Promote our Services or other products. This may include developing and providing promotional and advertising materials about Urban Algorithm LLC that may be of interest to you.
• Address legal issues. This may include obtaining legal advice and establishing, exercising, or defending legal claims; complying with laws, regulatory requirements, contractual obligations, court orders, or other legal process or obligations; and detecting, preventing, and responding to fraud, intellectual property infringement, security issues, violations of our agreements, or violations of law.

We may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such aggregated information will not identify you individually or your organization.

4. How We Share The Information

We will not sell your information to data brokers or other third parties for money. We may, however, share your information as follows:

4.1 Data subprocessors

We may share your information with third parties with whom we work to provide, improve, or develop our Services or other products; to perform other website-related services; or to assist us in analyzing how our Services or other products are used. For example, we may work with vendors providing website hosting; data analysis; other technology services; payment processing; fraud monitoring; services related to product development and maintenance; communications, marketing, and advertising services; and AI services for content generation.

4.2 Legal reasons

We may share your information with third parties when we have a good faith belief that disclosure is necessary to: obtain legal advice or establish, exercise, or defend legal claims; comply with laws, regulatory requirements, contractual obligations, court orders, or other legal process or obligations; detect, prevent, or respond to fraud, intellectual property infringement, security issues, violations of our agreements or law, or other misuse of our Services; protect the safety, rights, welfare, or property of Urban Algorithm LLC, you, or others, as required or permitted by applicable law.

4.3 Business transfers

In the future, we may share your information with third parties in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

4.4 Otherwise with your consent

We may share your information with third parties when we have your consent to do so.

4.5 Anonymized or aggregated information

We may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually or your organization.

5. How You Can Manage Your Information

If you have an account with us, our Services allow you to:

• Change the name associated with your account
• Change the email associated with your account
• Change the password associated with your account
• Delete your account

To delete your account data, please follow the instructions provided within your account settings. If you decide to delete your account, please make sure you first save any information you would like to keep. Please also be aware that, even if you delete your account, we might still maintain and process certain information about you, such as internet or other network or device activity, which may be necessary to provide our Services or to ensure their security.

You may also contact us at [email protected] to request the full deletion of your account data.

6. Where We Process Information

We may process your information in the United States and other locations around the world. The countries in which we process information may not provide the same level of protection for your information as your country. By using our Services or otherwise providing us your information, you acknowledge and understand that your information will be transferred to and processed in the United States and other countries.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Children's Privacy

Our Services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at [email protected] so that we can take appropriate action.

9. Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last updated" date at the top of this Policy. We encourage you to review this Policy periodically to stay informed about how we are protecting your information. Your continued use of our Services after any changes to this Policy constitutes your acceptance of such changes.

10. iOS App, In-App Purchases, and Apple

This section explains how data is handled when you use the Flying Prep iOS app, which is distributed through the Apple App Store.

10.1 Apple is the payment processor for iOS subscriptions

Subscriptions purchased inside the Flying Prep iOS app are processed by Apple through StoreKit and the App Store. We never see or store your credit-card or bank-account information. Apple sends us a signed transaction receipt containing only the product identifier, original transaction ID, purchase date, and expiration date, which we use to grant you access to the tier you paid for and to handle renewals.

10.2 What the iOS app collects from your device

The iOS app receives Apple's Identifier for Vendor (IDFV), which is anonymous to other developers, the iOS version, and the device model. If you enable push notifications, the app receives an Apple Push Notification service (APNs) token used solely to deliver notifications you have opted in to.

10.3 We do not track you across other apps or websites

The Flying Prep iOS app does not use the Identifier for Advertisers (IDFA) and does not request App Tracking Transparency permission. We do not share device identifiers with advertising networks, data brokers, or any other third party for cross-app or cross-site tracking.

10.4 Server-side data we store about your iOS subscription

When you subscribe through the iOS app we store, associated with your Flying Prep account, the App Store product identifier (for example, the monthly or yearly tier), the original transaction ID, the latest transaction ID, and the subscription start and expiration timestamps. This is the minimum needed to determine whether your subscription is active and to honor renewals and cancellations sent to us by Apple's App Store Server Notifications.

10.5 Microphone access (speaking practice)

Language exams that include a speaking section let you record your spoken response so our automated scoring system can return feedback on pronunciation and fluency. iOS will ask for microphone permission the first time you tap Record. The recording is stored locally on your device, then uploaded to our servers for scoring. You can decline or revoke microphone permission at any time in iOS Settings; the rest of the app works without it, you simply will not be able to use speaking-format questions.

10.6 Photo library access (exam score reporting)

When you choose to log a passed exam result, you can optionally attach a photo of your official score report (for example, a CLEP or DSST score sheet) so we can verify the score you reported. iOS will ask for photo-library permission the first time you tap the photo picker. The image is uploaded to our private cloud storage bucket and linked only to your account; we do not share it publicly or with other students. You can decline or revoke photo permission at any time in iOS Settings; the score-reporting form continues to work without an attached photo.

10.7 Push notifications

If you grant push-notification permission, the app obtains an Apple Push Notification service (APNs) token and sends it to our servers. We use the token only to deliver notifications you opt in to (study reminders, exam-prep nudges). We do not share the token with third parties for advertising or analytics. You can disable notifications at any time in iOS Settings.

10.8 In-app account deletion

You can request deletion of your Flying Prep account from inside the iOS app under Settings. Deletion removes your profile, study history, subscription records, recordings, and uploaded score-report photos from our systems. Some information may be retained as required by law or to enforce our Terms of Service (for example, payment records required for tax purposes). If you cancel an active iOS subscription, you must do so separately through your Apple ID subscription settings; deleting your Flying Prep account does not cancel an active Apple subscription.

11. Data Retention

We retain personal information for as long as your account is active, as needed to provide the Services, and as required by applicable law. Specific retention practices:

• Account profile, study progress, and quiz history: retained while the account is active. Deleted within 30 days of an account-deletion request, except where retention is required by law.
• Subscription records (Stripe and Apple): retained for at least seven years after the last transaction to satisfy financial-records retention requirements.
• Voice recordings from speaking practice: retained for up to 12 months to deliver feedback and improve our automated scoring models, then deleted. You may request earlier deletion at any time by emailing [email protected].
• Photo uploads (score reports): retained for the lifetime of the account so we can re-verify your reported scores. Deleted within 30 days of an account-deletion request.
• Server logs and security records: retained for up to 12 months, then anonymized or deleted.

12. Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act and California Privacy Rights Act give you specific rights regarding your personal information:

• Right to know what personal information we have collected about you.
• Right to delete personal information we have collected from you.
• Right to correct inaccurate personal information.
• Right to opt out of the sale or sharing of your personal information. We do not sell or share personal information for cross-context behavioral advertising.
• Right to non-discrimination for exercising these rights.

To exercise any of these rights, email [email protected]. We will verify your identity before fulfilling the request and respond within 45 days.

13. Your European Union and United Kingdom Privacy Rights

If you are located in the European Economic Area, the United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) and equivalent local laws give you the following rights:

• Right of access to your personal data.
• Right to rectification of inaccurate or incomplete data.
• Right to erasure ("right to be forgotten").
• Right to restriction of processing.
• Right to data portability.
• Right to object to certain processing.
• Right to withdraw consent where processing is based on consent.

The legal bases on which we rely include performance of a contract (delivering the Services you requested), legitimate interests (operating and improving the Services, security, fraud prevention), consent (for example, for push notifications and microphone access), and compliance with legal obligations.

To exercise any of these rights, email [email protected]. You also have the right to lodge a complaint with a supervisory authority in your country of residence.

14. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at: