Consent to Personal-Data Processing and Cross-Border Transfers

1. Operator and data subject

The operator is Товарищество с ограниченной ответственностью "Цедра Груп", БИН 230140044071. The data subject is the individual authenticating through Sign in with Apple and using Тестмейт. The operator’s contact details appear at the end of this consent.

2. Action expressing consent

Proceeding through Sign in with Apple from the sign-in screen to use Тестмейт expresses consent to the described processing and cross-border transfers to the extent this method is permitted by law. If the law requires a separate action for a particular purpose, the company must obtain it before that processing.

3. Data list

• internal UUID, Apple identifier, authentication results, and email address, including Apple Private Relay;
• first and last name, nickname, language, account, onboarding, premium-access and deletion statuses, and creation, update, and deletion dates;
• optional telephone number, city, grade, selected subjects, daily study target, and preferences;
• questions and tasks accessed, selected answers, correctness, AI marker, scores, points, rank, activity, progress, topics, and subjects;
• feedback, reports, complaints, comments, their status, and correspondence;
• RevenueCat identifier, product and entitlement, store, environment, period type, subscription and renewal status, purchase and expiry dates, synchronization, webhooks, delivery, errors, and audit;
• events, screens, app and service versions, platform and environment, device and installation identifiers, lifecycle, performance, crashes, and diagnostics;
• IP address, user agent, request method and path, error context, stack trace, response details, and UTM source, medium, campaign, and related parameters.

4. Purposes and operations

Consent covers collection, recording, organization, storage, updating, retrieval, use, matching, transfer to approved recipients, anonymization, restriction, and deletion for authentication, account operation, study, progress, subscriptions, support, security, diagnostics, analytics, chosen leaderboard participation, chosen marketing, legal compliance, and claim defense.

5. Duration

Consent applies from the moment it is expressed until withdrawal or the end of the relevant purpose. Active-account data is kept while needed for the Service. After a verified request, account-linked personal data will within 30 days be deleted or irreversibly anonymized, subject only to lawful retention exceptions. Website analytics and UTM attribution are kept for 12 months. Backups are protected and covered by the same deletion outcome. Mandatory records remain only for the applicable lawful period.

6. Recipients and providers

• Apple — authentication, distribution, billing, subscription management, and refunds;
• DigitalOcean — infrastructure in Bangalore, India;
• RevenueCat — purchases, subscription status, and entitlements;
• PostHog EU and AppMetrica / Yandex — optional product and website analytics;
• Firebase / Google — minimized essential crash and performance diagnostics;
• Telegram — operational error notifications;
• Anthropic — back-office educational-content generation without direct user requests or prompts;
• public authorities and others — only where transfer is required by law or needed for a lawful claim.

7. Cross-border transfers

The user consents to cross-border transfers to India, where the principal production systems are in DigitalOcean’s Bangalore region, and to other countries where approved providers lawfully process data. This is not a statement that the primary database is localized in Kazakhstan. The company uses available contractual and technical measures and respects mandatory restrictions in the user’s country.

8. Public disclosure

Data is not published under this general consent. Only after separate voluntary leaderboard participation may nickname, points, and rank be disclosed to other authenticated users. Email, first name, and last name are not permitted public fields.

9. Separate marketing choice

Marketing is a separate voluntary choice for specific available channels; refusal of marketing or later withdrawal does not affect an account, core functions, or paid access. Transactional, security, and mandatory Service messages continue where necessary.

10. Analytics choice

PostHog and AppMetrica are optional analytics that may be objected to through the privacy contact. Firebase Crashlytics and Performance are minimized essential diagnostics for stability, security, and errors, distinct from optional product analytics. There is currently no separate user-facing switch.

11. Withdrawal

Consent or an optional choice may be withdrawn at any time by email to [email protected] or through the other unified contact details. Identify the account connection and scope of withdrawal. Withdrawal does not operate retroactively and does not make processing already performed on a valid basis unlawful.

12. Necessary processing that may continue

After withdrawal, the company may continue processing needed to perform the contract until account closure, protect security, prevent abuse, meet a legal obligation, respond to a lawful request, maintain accounting records, or defend an unresolved claim. Such processing is limited to the relevant purpose and period.

13. Consequences of refusal or withdrawal

Refusal of necessary processing makes sign-in and account operation impossible. After a verified request, account-linked personal data will within 30 days be deleted or irreversibly anonymized, subject only to lawful retention exceptions. Refusal of marketing, optional analytics, or leaderboard participation affects only that function. Deletion does not cancel an Apple subscription.

14. Contact details

Товарищество с ограниченной ответственностью "Цедра Груп", БИН 230140044071. Address: Kazakhstan, Almaty city, Bostandyk district, Radostovets Street, building 189, apartment 37, postal code 050060. Email: [email protected]. Telephone: +7 706 645 56 37. These details may be used to withdraw consent, object to analytics, request deletion, or exercise another available right.