Privacy Policy
Last updated: November 13, 2026
This policy describes how the personal data of users of the Examinons app (the "App") is processed. It is provided under Regulation (EU) 2016/679 ("GDPR") and other applicable data protection laws.
1. Data controller
The data controller is Dante Learning (Riccardo Cristiani), Japan (the "Controller"). Contact: support@examinons.com. The address will be provided without delay upon request.
Representative in the European Union under Article 27 of the GDPR: Riccardo Cristiani, Italy, support@examinons.com.
2. Data processed, purposes, legal bases, and retention
The App does not require an account and does not ask for an email address. If you enter a first name, it stays on your phone and is not sent to the Controller. The Controller does not receive users' names or email addresses from Apple or Google. Study progress is stored on the user's phone and is not transmitted to the Controller.
Phone profile and technical data. Phone code created by the App on first launch, platform, App version, chosen language and level, dates of connection to the service, IP address, technical logs, backups. Purpose: operation of the service, application of the limit on free content, security and prevention of abuse, support. Legal basis: performance of the contract and the Controller's legitimate interest in the security of the service. The code is also stored on the phone and is strictly necessary for the operation of the service. Retention: the phone profile is deleted 12 months after the App last connected to the service, or earlier if the user deletes the data on the phone; technical logs and backups 30 days.
Purchases of levels. Store, product, order number or transaction reference, date and status of the purchase, linked to the phone ID, including the notifications from the provider that manages purchases, which are then deleted or anonymized. Purpose: providing and restoring purchases, applying the limits of the service, support. Legal basis: performance of the contract. Retention: deleted 12 months after the App last connected to the service, or earlier if the user deletes the data on the phone; purchased levels can be recovered from the store with "Restore purchases."
Writing tests submitted for automated correction. Texts submitted by the user, the test and level they refer to, date, outcome, evaluation, and technical processing data, including for requests that failed. Purpose: providing the correction service and applying its limits. Legal basis: the user's consent for sending texts to the artificial intelligence provider; performance of the contract and the Controller's legitimate interest in applying the limits of the service, for storage. Retention: writing tests and corrections are deleted 12 months after the App last connected to the service, or earlier if the user deletes the data on the phone.
Pseudonymous anti-abuse codes. Two pseudonymous codes: the first records the free content already used on the phone; the second, linked to the purchase and not to the phone, records the corrections used for each purchase. Purpose: preventing abuse of the free content and preventing the correction limit from being reset by deleting the data and restoring purchases. Legal basis: the Controller's legitimate interest in preventing abuse. Retention: the free content code until 12 months after the App last connected to the service or, if the data on the phone is deleted, until 12 months after the deletion; the corrections code until 12 months after the last correction.
Usage events. A count of App usage events, such as starting and finishing an exam, viewing the purchase screen, and purchasing, recorded on the Controller's server without names or email addresses, without third-party analytics tools, and without session recording. Purpose: statistics on the use of the App, in aggregate form, to improve it. Legal basis: the Controller's legitimate interest in improving the service. Retention: 12 months from the date of each event.
Correspondence. Messages sent by the user to the Controller, with the phone ID and order number if provided. Purpose: responding to requests. Legal basis: the Controller's legitimate interest in responding to requests. Retention: for the time needed to handle the request.
3. Correction of writing tests with artificial intelligence
With the user's express consent, texts submitted for automated correction are transmitted to a provider of artificial intelligence services based in the United States, which processes them on behalf of the Controller as a data processor. Consent may be withdrawn at any time from Settings in the App or by writing to support@examinons.com; withdrawal does not affect the lawfulness of processing carried out before it. Users are asked not to include third parties' personal data or special categories of data (for example about health, religion or political opinions) in the texts.
Correction is for educational purposes only. The Controller does not make decisions based solely on automated processing that produce legal effects concerning the user or similarly significantly affect the user.
4. Recipients
Data is processed, on behalf of the Controller and on its instructions, by the following categories of providers: IT and data storage services; the artificial intelligence provider referred to in section 3; a provider for the management of in-app purchases; an email service. Apple and Google process data relating to purchases and payments made with their services as independent controllers, under their own privacy policies.
Data is not sold and is not used for advertising. It may be disclosed to authorities where required by law.
5. Transfers to third countries
Data processed by the Controller is stored on servers located in the European Union. The Controller is based in Japan, a country for which the European Commission has adopted an adequacy decision. The provider referred to in section 3 is based in the United States, and other providers referred to in section 4 may process data in the United States or in other countries outside the European Union. These transfers are based on an adequacy decision of the European Commission or on the standard contractual clauses approved by the European Commission, under Articles 45 and 46 of the GDPR. Information on the safeguards adopted may be requested at support@examinons.com.
6. Data deletion
The user may delete the data linked to their phone at any time with the "Delete data on this phone" command in Settings › Data and progress, or as described at https://examinons.com/delete-account. Deletion removes the phone profile, the purchase data linked to the profile, and the writing tests with their corrections. Purchased levels remain associated with the store account and can be recovered with "Restore purchases."
After deletion, of the data linked to the phone, only the two pseudonymous anti-abuse codes referred to in section 2 remain on the server, for up to 12 months, solely to prevent abuse. Backups and technical logs that still contain the deleted data are erased within 30 days; texts already transmitted to the artificial intelligence provider are normally deleted by that provider within 30 days.
7. Rights of the data subject
To the extent provided by applicable law, the user has the right to obtain access to their data, rectification, erasure, restriction of processing, and data portability, and to withdraw consent. Requests should be sent to support@examinons.com and are answered within the time limits set by law; the Controller may ask for the information needed to verify the identity of the person making the request, such as the phone ID.
Right to object. The user may object at any time, on grounds relating to their particular situation, to processing based on legitimate interest, by writing to support@examinons.com.
The user also has the right to lodge a complaint with the competent supervisory authority. Any further rights granted by the law of the user's country of residence are unaffected.
8. Minors
The App is not intended for persons under 16. Persons under 18 may use it only with the permission of a parent or guardian.
9. Changes
The Controller may amend this policy. The updated version is published on examinons.com with the date of last update.
10. Language
This policy is drawn up in Italian and in English.