Privacy Policy

1. Who we are

The data controller for the purposes described in this policy is JET CREATIVE LTD (“we”, “us”), a company registered in England and Wales under company number 07591183, registered office: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF — publisher of the Learn with Leo mobile app.

Privacy enquiries: contact@jetcreative.co.uk.

2. The basic principle

The app is built to work without an account. There is no sign-up, no login, and no user profile. In ordinary use of the app we receive no information that could identify you.

3. What data is involved

4. Data that stays on your device

The following is stored only on your device (in the app's storage and in the app group it shares with the Apple Watch app and the widgets):

• your study history: answers, whether they were right, and when;
• your review queue and the spaced repetition schedule;
• exam mode results;
• study streaks, statistics and per-course progress;
• settings, such as shuffle and reminders;
• downloaded study material, so revision works offline.

None of this is sent to our servers. Deleting the app removes it from the device.

5. iCloud sync

5.1. If you are signed in to an Apple Account with iCloud enabled, the app can sync your study progress and settings between your devices using Apple's iCloud Key-Value Store.

5.2. That data goes to your own private iCloud storage, tied to your Apple Account. We cannot access it — we run no sync server and hold no database of anyone's progress.

5.3. Sync covers study history, the review queue, exam results, completed material and settings. It does not cover your purchase status (that belongs to Apple and is restored through the App Store) or scheduled local reminders.

5.4. If you are signed out of iCloud, or iCloud Drive is off, syncing simply does not happen and the app works normally in local mode.

5.5. Apple's handling of iCloud data is governed by the Apple Privacy Policy.

6. Talking to our server

6.1. The app connects to our content server to download and update study material (flashcards, quizzes, images), informational messages and notice of a newer app version.

6.2. These connections are one-way content downloads. The app does not send your answers, results, statistics, or any user or device identifier with them.

6.3. Requests carry only the technical data needed to serve an HTTPS connection: IP address, timestamp, the address of the resource requested, and an app client key shared by every installation, which identifies the app rather than a person. Standard server logs are kept for at most 30 days for security and diagnostics.

6.4. An IP address is personal data under the UK GDPR. We process it only to deliver content and keep the service secure, on the basis of our legitimate interests (Article 6(1)(f)). We do not link IP addresses to study activity.

7. Payments and subscriptions

7.1. All payments are handled by Apple, through the App Store and StoreKit.

7.2. We never receive or process payment data — we do not see your card number, billing address or identity. The app only reads whether an active subscription entitlement exists on the device.

7.3. Entitlement checks happen between your device and Apple. The aggregated sales reports Apple gives us contain no personal data about purchasers.

8. Notifications and reminders

8.1. The app can show local notifications (study reminders) if you allow them in iOS.

8.2. Those notifications are scheduled and shown by iOS on your device. We do not use server-sent push notifications and we store no notification tokens.

8.3. You can withdraw permission at any time in iOS Settings, or turn reminders off inside the app.

9. No tracking, no ads

9.1. The app contains no analytics, advertising or tracking SDKs — no Google Analytics, no Firebase, no Meta SDK, no AppsFlyer, nothing of that kind.

9.2. We do not track you in Apple's sense, and the app therefore does not show an App Tracking Transparency prompt: we do not follow you across other companies' apps or websites.

9.3. We do not sell, rent or trade data with anyone.

10. Lawful bases

11. Who we share data with

• Apple Inc. — app distribution, payments, iCloud and system notifications. Apple acts as an independent controller for its own services.
• Our hosting provider — as a processor, for technical logs and serving content.

Beyond that, we share data with no one.

12. International transfers

12.1. We are based in the United Kingdom, and our content server is operated within the UK/EEA.

12.2. Apple may process data outside the UK and EEA under the UK International Data Transfer Addendum, standard contractual clauses and its own compliance mechanisms — see the Apple Privacy Policy.

13. How long we keep things

• Data on your device — until you delete the app or clear the data in its settings.
• Data in iCloud — until you delete it in your iCloud settings; you control it, not us.
• Server logs — at most 30 days.
• Email correspondence — up to 24 months after a matter is closed, unless the law requires longer.

14. Your rights

For data where we are the controller, you have the right to:

• be told about, and get a copy of, your data (Art. 15);
• have inaccurate data corrected (Art. 16);
• have data erased (Art. 17);
• restrict processing (Art. 18);
• data portability (Art. 20);
• object to processing based on legitimate interests (Art. 21);
• withdraw consent at any time, without affecting processing already carried out.

Send requests to contact@jetcreative.co.uk. We respond without undue delay and within one month.

You can also complain to the supervisory authority. In the UK that is the Information Commissioner's Office (ico.org.uk); in the EU, your national data protection authority.

Because the app collects nothing that identifies you, in many cases we cannot link a request to any data at our end (Art. 11) — there is simply nothing held to disclose or erase.

15. How to delete your data

1. In the app: open Settings in the app and clear your progress, or delete the app from your device.
2. In iCloud: iOS → Settings → your name → iCloud → Manage Storage → Learn with Leo → delete the data.
3. Subscription: cancel it in your Apple subscription settings. Deleting the app does not cancel it.
4. Correspondence: email us and we will delete the thread.

16. Users under 18

16.1. The app is aimed at people studying professional accountancy qualifications, and it collects no personal data from anyone, of any age.

16.2. We do not profile users, show adverts, or run marketing directed at children.

16.3. App Store purchases by a minor need the account holder's consent; a parent or guardian can enable Ask to Buy and Screen Time restrictions.

17. Security

• all communication with our server uses HTTPS/TLS;
• data on the device is protected by iOS encryption and the app sandbox;
• data in iCloud is protected by Apple's infrastructure and your Apple Account;
• we keep collection to a minimum — the best-protected data is the data never collected.

18. App Store privacy labels

As declared in App Store Connect, Learn with Leo:

• collects no data linked to your identity;
• collects no data not linked to your identity;
• does not use data for tracking in Apple's sense.

That declaration matches what this policy describes. If the processing ever changes, we will update the App Store labels and this document together.

19. Changes to this policy

19.1. We may update this policy, for instance when features are added. The current version always lives at learnwithleo.co.uk/privacy.html.

19.2. We will give at least 14 days notice in the app of any material change. The version number and effective date are at the top of this page.

20. Contact

Privacy questions, data protection requests and problem reports: contact@jetcreative.co.uk.