Privacy Policy

1. Introduction

R&P Fusion ("we", "us", or "our") operates PassMode. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Information You Provide

• Account Information: Email address, name, password (encrypted)
• Payment Information: Processed securely by Stripe; we do not store card details
• Content: Files, documents, audio, and other materials you upload
• Communications: Messages you send to our support team

2.2 Information Collected Automatically

• Usage Data: Pages visited, features used, quiz scores, time spent
• Device Information: Browser type, operating system, device type
• Log Data: IP address, access times, error logs

3. How We Use Your Information

We use your information to:

• Provide, maintain, and improve the Service
• Process your uploaded content to generate quizzes and flashcards
• Process payments and manage subscriptions
• Send service-related communications
• Respond to your inquiries and support requests
• Detect and prevent fraud or abuse
• Comply with legal obligations

4. Legal Basis for Processing (UK GDPR)

We process your personal data based on:

• Contract: To provide the Service you've requested
• Legitimate Interests: To improve our Service and prevent fraud
• Consent: For optional marketing communications
• Legal Obligation: To comply with applicable laws

5. Data Sharing and Disclosure

We may share your information with:

• Service Providers: Third parties that help us operate the Service:
  • Stripe (payment processing)
  • OpenAI (AI content generation)
  • Deepgram (audio transcription)
  • Cloudflare R2 (file storage)
  • Supabase (database hosting)
  • Vercel (application hosting)
  • Resend (email delivery)
  • Sentry (error monitoring)
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets

We do not sell your personal information to third parties.

6. Data Storage and Security

Your data is stored securely using:

• Encrypted database connections (Supabase)
• Secure file storage (Cloudflare R2)
• HTTPS encryption for all data transmission
• Row-level security to ensure users can only access their own data

While we implement strong security measures, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

7. Data Retention

We retain your data for as long as your account is active or as needed to provide the Service. Specifically:

• Account Data: Until you delete your account
• Uploaded Content: Until you delete it or your account
• Payment Records: As required by law (typically 7 years)
• Usage Analytics: Aggregated data may be retained indefinitely

8. Your Rights (UK GDPR)

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we process your data
• Portability: Receive your data in a portable format
• Objection: Object to certain processing activities
• Withdraw Consent: Where processing is based on consent

To exercise these rights, contact us at support@passmode.com

9. International Data Transfers

Your data may be processed by service providers located outside the UK, including:

• United States (OpenAI, Stripe, Deepgram, Vercel, Resend)
• European Union (Supabase)

We ensure appropriate safeguards are in place, such as Standard Contractual Clauses and adequacy decisions, to protect your data in accordance with UK GDPR requirements. All service providers are carefully vetted for data protection compliance.

10. Cookies

We use essential cookies to operate the Service (e.g., authentication). We do not use tracking or advertising cookies. By using the Service, you consent to our use of essential cookies.

11. Children's Privacy

PassMode is not intended for children under 13. We do not knowingly collect personal information from children under 13. If you believe we have collected such information, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last updated" date.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, contact us:

Data Controller: R&P Fusion
Email: support@passmode.com
United Kingdom

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data protection rights have been violated.