Privacy Policy
1. Who we are
The app is published by Horizon Lab Studios ("we", "us"). For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, we are the data controller for the personal data described in this policy, except where a third party acts as an independent controller (explained below).
Contact: vkhorizon.lab@gmail.com
App ID: com.horizonlabstudios.lifeinuk
2. Data kept on your device
The app has no accounts, no sign-in and no registration. It does not ask for your name, email address, phone number, contacts, photos or precise location.
To work, the app stores the following in a local database (SQLite) and app settings on your device only. We do not receive a copy:
- your test attempts, answers, scores, time per question and flagged questions;
- your per-question learning statistics (used to choose which questions to show you again) and bookmarks;
- your study plan: test date (for the countdown), daily goal and reminder time;
- your daily progress, used for streaks;
- app preferences such as light or dark mode, and whether you own Premium (so the app works offline);
- the downloaded question bank and study notes;
- a copy of any question report you make (see section 7.3).
Read aloud uses your device's built-in text-to-speech voice. The text is spoken on your device and we do not send it anywhere, although your device maker's speech service may follow its own settings.
This data is removed when you uninstall the app or clear its storage. Your device's own backup service (for example iCloud or Google backup) may include it in a backup under your account with that provider.
3. Advertising (Google AdMob)
The free app is funded by ads from Google AdMob: banner ads (including a collapsible banner), native ads shown among the content, full-screen ads shown between screens (for example after a mock exam), and optional reward videos that you can choose to watch to unlock an extra.
Consent. When you open the app, it uses Google's User Messaging Platform (UMP) to show a consent message where the law requires one, including in the UK and the European Economic Area. Ads are only requested after this step. You can change your choice at any time in Settings → Privacy options.
iPhone and iPad. After the consent message, iOS asks whether the app may track you through Apple's App Tracking Transparency prompt. If you choose "Ask App Not to Track", the app cannot access your device's advertising identifier (IDFA). You can change this later in iOS Settings → Privacy & Security → Tracking.
What Google may collect through the AdMob SDK includes: your device's advertising identifier (Android advertising ID or iOS IDFA, where allowed), IP address and the approximate location derived from it, device and operating system information, app information, and how you interact with ads (views and taps). Google uses this to serve, measure and cap the frequency of ads, prevent fraud and, if you consent, personalise ads. If you do not consent, Google may still show non-personalised or limited ads, which use data only for purposes such as delivery, measurement and fraud prevention.
Google acts as an independent controller for much of this processing. See How Google uses information from sites or apps that use its services and the Google Privacy Policy.
Premium and ads. Premium removes video ads and full-screen ads. Banner and native ads are still shown to Premium users.
4. Premium purchases
Premium is a one-off purchase made through the Apple App Store or Google Play. We never see or store your card or payment details; Apple or Google handles payment under their own terms and privacy policies.
The app asks the store on your device whether you own Premium, so it can switch it on and restore it on a new device signed in to the same store account. We do not run our own purchase server and do not receive your name or email from the store.
5. Content updates
To fix and improve questions and study notes without an app update, the app checks for new content at most about once a day. It downloads files over an encrypted HTTPS connection from a server we control and checks each file against a security hash before using it. The request contains no personal information beyond what any internet request carries (your IP address and basic technical details such as the time of the request), which the hosting provider may record in its server logs.
6. Daily reminders
If you turn on daily study reminders, the reminder is scheduled as a local notification on your device. No data is sent to us or to a push notification service. Your device asks for your permission first, and you can turn reminders off in the app or in your device's notification settings.
7. Crash reports, usage statistics and question reports
Sections 7.1 and 7.2 apply to the Android app. The iPhone app does not send crash reports or usage statistics yet.
7.1 Crash reports (Firebase Crashlytics)
If the app crashes, it sends a crash report to Google Firebase Crashlytics so we can fix the bug. A report contains the error and the code where it happened, device model, operating system and app version, free memory and disk space, whether the app was in the foreground, and a random installation identifier. It does not include your answers, your name or anything you type. Crash reports are on by default, and you can turn them off at any time in Settings → Send crash reports.
7.2 Usage statistics (Google Analytics for Firebase)
Usage statistics are off unless you turn them on in Settings → Share anonymous usage statistics. If you do, the app sends a small set of events so we can see which features help people prepare: which screens are opened, finishing a test (with the test type, score and whether it was a pass) and buying Premium. Firebase also records an app instance ID, device and app information, standard events such as the first open and app updates, and approximate location (country or region) derived from your IP address. We do not send your name, email, any free text or your advertising ID, and this data is not used for advertising. You can turn it off again at any time.
7.3 Question reports and feedback (email)
This feature is live today and works by email. If you report a question or send feedback, the app opens your own email app with a pre-filled message to vkhorizon.lab@gmail.com. Nothing is sent unless you press send. If you do, we receive your email address, your message (the question's ID and text, the reason you picked and any note) and anything you add. We use it only to fix the content and to reply to you. Our email is hosted by Google (Gmail). A copy of each question report is also kept on your device. In future, reports may instead be sent anonymously, without your email address, to our database in Google Firebase (Cloud Firestore) Planned.
For Firebase, Google acts as our processor. See Privacy and Security in Firebase and the Google Privacy Policy.
8. Purposes and lawful bases
| Purpose | Data | Lawful basis (UK GDPR Art. 6) |
|---|---|---|
| Personalised ads, and reading or storing identifiers on your device for ads | Advertising ID, device and ad interaction data, IP address | Consent (Art. 6(1)(a)), and consent under the Privacy and Electronic Communications Regulations (PECR) |
| Non-personalised or limited ads, ad measurement and fraud prevention | Device and ad interaction data, IP address | Legitimate interests (Art. 6(1)(f)): funding a free app and keeping ads safe. Where PECR requires consent to access your device, we rely on your consent choice. |
| Selling and restoring Premium | Anonymous app user ID, purchase receipt and transaction details | Performance of a contract (Art. 6(1)(b)); keeping records for tax and accounting is a legal obligation (Art. 6(1)(c)) |
| Downloading content updates | IP address and request details in server logs | Legitimate interests (Art. 6(1)(f)): keeping the questions accurate and the service secure |
| Crash reports | Crash and device data, installation ID | Legitimate interests (Art. 6(1)(f)): finding and fixing bugs that stop the app working. You can turn this off in Settings. |
| Usage statistics (only if you turn them on) | Usage events, app instance ID, device data, approximate region | Consent (Art. 6(1)(a)) |
| Question reports and feedback (email) | Your email address, the question ID and text, reason, your message | Legitimate interests (Art. 6(1)(f)): correcting the content when you ask us to |
Where we rely on legitimate interests, we have weighed them against your rights and kept the data to a minimum. You can object at any time (see section 13). We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
9. Third parties
- Google (AdMob and the User Messaging Platform): ads and consent. Privacy Policy · How Google uses data from apps · Advertising
- Apple (App Store payments, App Tracking Transparency). Privacy Policy
- Google Play (Play payments). Privacy Policy
- Google (Gmail): hosts the email address that receives question reports and feedback. Privacy Policy
- Google Firebase (Crashlytics, Analytics, Hosting for content updates). Privacy and Security in Firebase
- Our content hosting provider, which serves content update files.
We do not sell your personal data. We may disclose information if the law requires it.
10. International transfers
Google may process data outside the UK, including in the United States. Where they do, the transfer is protected by safeguards recognised under UK law, such as the UK Extension to the EU-US Data Privacy Framework, the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, or the UK International Data Transfer Agreement.
11. How long data is kept
- Data on your device: until you uninstall the app or clear its storage.
- Advertising data: kept by Google under its own retention policy. See How Google retains data.
- Purchase records (Google Play or Apple): for as long as needed to provide and restore Premium, and for up to 6 years after the end of the tax year of purchase, for tax and accounting.
- Content server logs: up to 30 days.
- Crash reports: up to 90 days.
- Usage statistics: up to 14 months.
- Question reports and feedback emails: up to 24 months, then deleted. You can ask us to delete them sooner.
12. Children
The app is a study aid for people preparing for the Life in the UK Test, which is taken by adults applying for settlement or British citizenship. It is not directed at anyone under 18. We do not knowingly collect personal data from children. If you believe a child has given us personal data, contact us and we will delete it.
13. Your rights and choices
Under UK data protection law you have the right to:
- be informed about how your data is used (this policy);
- access the personal data we hold about you;
- have inaccurate data corrected;
- have your data erased;
- restrict how we use your data;
- object to processing based on legitimate interests;
- data portability, for data you gave us under consent or a contract;
- withdraw consent at any time, without affecting processing done before you withdrew it.
Useful controls:
- Settings → Privacy options in the app: change your ad consent (shown in the UK and EEA).
- Settings → Send crash reports and Share anonymous usage statistics: turn crash reports and usage statistics on or off.
- iOS Settings → Privacy & Security → Tracking: allow or stop tracking.
- Android Settings → Privacy (or Google) → Ads: delete or reset your advertising ID.
- Uninstall the app or clear its storage to delete everything stored on your device.
Because there are no accounts, we usually cannot link data to you by name. To help us find data about you (for example a purchase), we may ask for details such as your store order number. We will reply within one month.
14. Complaints
Please contact us first and we will try to help. You also have the right to complain to the UK Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint, telephone 0303 123 1113. If you live in the EEA, you can complain to your local data protection authority.
15. Changes to this policy
We may update this policy, for example when a planned feature goes live. We will change the effective date at the top and, for significant changes, tell you in the app or in the store release notes.
16. Contact
Horizon Lab Studios
Email: vkhorizon.lab@gmail.com