Privacy Policy — UK Driver Licence Prep

Publisher: Bisai Technologies (Bisai Technologies, LLC, a Delaware limited liability company), 131 Continental Dr, Suite 305, Newark, DE 19713, United States Contact: contact@bisaitechnologies.com Effective date: 28 September 2026 · Version: 1.0 Hosted at: https://bisaitechnologies.com/legal/uk_driver_prep/privacy

UK Driver Licence Prep ("the app") is an independent study aid for the Transport for London SERU assessment, the TfL Topographical Skills assessment and council taxi and private-hire knowledge tests. This policy explains what data the app processes, why, for how long, and what rights you have under the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) and, for users in the European Union, the EU GDPR. It is written for the app as it is built: there is no account, no login and no email address anywhere in the app.

1. Who is responsible

Bisai Technologies is the data controller for the processing described here.

You can reach our Privacy Officer at contact@bisaitechnologies.com. Put "Privacy" in the subject line.

2. The short version

• The app never asks for your name, email address, phone number, photo, licence number or location.
• Your only identifier is an anonymous app user ID created on your device by the RevenueCat SDK when you first open the app (it looks like $RCAnonymousID:…). It is not linked to your identity.
• Your study progress (answers, scores, flashcards, notes, exam date, streak, licence journey checklist) is stored on your device only. You can erase it at any time in Settings > Data > Reset app data.
• Data leaves your device for exactly six purposes: subscriptions, usage analytics, crash reports, question problem reports, the "explain it differently" AI feature, and exam outcome logging for the pass guarantee. Each is described in section 4.
• We do not sell personal data, we do not show ads, and we do not use advertising trackers.

3. Your anonymous ID

When you first open the app, the RevenueCat SDK generates a random identifier and stores it on your device. This ID:

• is sent with every request to our server (header X-User-Id) so that daily limits, rate limits and the pass guarantee can work without an account;
• is the identifier under which your subscription is recorded by RevenueCat;
• is the identifier under which analytics events are recorded by PostHog.

If you delete the app and reinstall it, a new ID is generated. Use Restore purchases to re-attach an active subscription to the new ID. You can view and copy your current ID in Settings > About > Your anonymous ID; you will need it if you ask us to delete server-side data (section 8).

4. What we process, why, and on what legal basis

4.1 Study data — on your device only

Answers given, per-section scores, spaced-repetition schedule, mock test sessions and results, diagnostic results, sentence-completion (cloze) trainer progress, map trainer progress, flagged questions, notes, chosen route (TfL SERU, TfL Topographical or a named council test), explanation language, test date, reminder time, streak, licence journey checklist state (DBS, medical, safeguarding course, English test, booking), readiness status, and settings.

• Where: a local SQLite database and local preferences on your device. Included in your device's normal OS backup if you have backups enabled (Apple iCloud backup / Google backup), under Apple's or Google's terms.
• Map trainer: the map images and place data used for Topographical and council points-of-interest questions are bundled inside the app's content packs. The app makes no live requests to OpenStreetMap or any map tile server.
• Legal basis: performance of the contract (providing the study features you asked for). This data is not transmitted to us except as described in 4.4 (aggregated answer statistics) and 4.7 (exam outcome).
• Retention: until you reset app data or uninstall the app.

4.2 Subscriptions and purchases

Payments are made through Apple's App Store or Google Play. We never see your card number, bank details or billing address. Subscription state is managed for us by RevenueCat.

• Data: anonymous app user ID; store receipt or purchase token; product identifier (uk_driver_prep_weekly or uk_driver_prep_monthly); price, currency and store country; purchase, renewal, cancellation and refund dates; entitlement status; device platform, OS version and app version.
• Recipients: Apple Inc. or Google LLC (as independent controllers of the payment, under their own privacy policies); RevenueCat, Inc. (our processor, United States); our server, which checks your entitlement when you use the AI feature and caches the result for ten minutes.
• Legal basis: performance of the contract (Art. 6(1)(b) UK GDPR).
• Retention: subscription records are kept by RevenueCat while your anonymous ID exists and are deleted on request (section 8). Our entitlement cache expires after ten minutes. Aggregated revenue reports contain no personal data and are kept for accounting purposes for 10 years.

4.3 Usage analytics (PostHog)

We measure how the app is used so we can fix confusing screens, balance question difficulty and decide which council packs to build next.

• Data: event names (for example app_started, diagnostic_completed, practice_answered, mock_completed, paywall_viewed, purchase_completed); event properties (route, section, question ID, whether an answer was correct, time taken, screen name, paywall variant shown, plan selected); person properties (app ID, whether you are a subscriber, plan, route, test date); device model, OS version, app version, app language, time zone and screen size; a session identifier; your anonymous app user ID. Your IP address is received by PostHog to deliver the request and to derive a country-level location; PostHog is configured to discard the IP address itself.
• Feature flags: PostHog also decides at random which paywall layout you see (paywall_variant) and records which variant was shown.
• Recipient: PostHog, Inc. (our processor), hosted on PostHog Cloud EU in Frankfurt, Germany.
• Legal basis: our legitimate interest in understanding and improving the app (Art. 6(1)(f) UK GDPR). The analytics SDK stores its identifiers on your device; under PECR you are told this here and can stop it at any time. Analytics is switched on by default. You can turn it off at any time in Settings > Privacy > Share usage analytics; from that moment no further events are sent.
• Retention: 12 months from collection, then deleted.

4.4 Aggregated answer statistics

To calibrate question difficulty, the app sends batches of {question ID, correct or not, time taken, mode} to our server.

• Data stored: per-question totals only (attempts, correct answers, average time). The batch is processed and not kept; your anonymous ID appears in the request header for rate limiting and remains only in server access logs (30 days).
• Legal basis: legitimate interest in maintaining accurate content.

4.5 Crash reports

If the app crashes or hits an unexpected error, a report is queued on the device and sent to our server when a connection is available.

• Data: error message, stack trace, app version, platform, OS version, the last screens and actions before the error (breadcrumbs), and your anonymous app user ID.
• Legal basis: legitimate interest in keeping the app working.
• Retention: 90 days.

4.6 Question problem reports

Every question has a Report a problem button.

• Data: question ID, content pack ID and version, the reason you select, any free text you type, app version and your anonymous app user ID. Please do not include personal data in the free-text field; if you do, we delete it when we process the report.
• Legal basis: legitimate interest in correcting content, based on a report you choose to send.
• Retention: until the report is resolved, then 12 months, and never longer than 24 months.

4.7 "Explain it differently" (AI explanations)

Subscribers can ask for an alternative explanation of a question. The request is served by our server, which uses Google Cloud Vertex AI (Gemini models) to generate the text.

• Data sent by the app to our server: question ID, content pack ID, requested mode (simpler, different, translate), language, and your anonymous app user ID (used to enforce the daily cap and check your subscription).
• Data sent by our server to Google: the question text, answer options and existing explanation, loaded from the content pack by question ID. No user identifier and no personal data is sent to Google. Google Cloud processes this as our processor and does not use it to train its models.
• Data stored by us: a daily counter per anonymous ID (deleted after 30 days) and, optionally, the generated explanation cached against the question ID with no user link.
• Legal basis: performance of the contract (a feature you request).

4.8 Exam outcome and the pass guarantee

After your SERU assessment, Topographical assessment or council knowledge test you can log the result (pass or fail) in the app. This is optional.

• Data: route, test date, pass or fail, the readiness status the app had assigned before the test, and your anonymous app user ID.
• If you make a guarantee claim by email, you will send us your official result notification. It contains your name and result. We use it only to verify the claim, store it in our support mailbox, and delete it 90 days after the claim is closed.
• Legal basis: performance of the contract (the pass guarantee in our Refund Policy).
• Retention: 24 months.

4.9 Redeem codes

If you enter a promotional code, including a code issued by a private-hire operator, driver union or training school, the code and your anonymous app user ID are recorded to prevent reuse. Retention: 36 months. The organisation that issued the code is told only how many of its codes were redeemed, never which ID redeemed them.

4.10 Remote configuration and content updates

The app periodically downloads its configuration and updated question packs (including new council packs) from our server. Each request carries the app ID, your anonymous app user ID, app version, platform and preferred language. Our web server keeps standard access logs (IP address, time, requested path, user agent) for 30 days for security and troubleshooting.

4.11 On-device features that involve no data transfer

• Daily reminder: a local notification scheduled on your device. We do not use push notifications and hold no device token.
• Audio (text-to-speech): questions and explanations are read aloud by your device's own speech engine, subject to your device settings. We send nothing.
• Sentence-completion trainer and licence journey checklist: run entirely on your device.
• Offline use: every study feature works without a network connection.

4.12 Links to other websites

The app links to official pages (TfL licensing pages, council licensing pages, GOV.UK, DBS and medical guidance, booking pages) and to the sources of each question. These open in your browser and are governed by those sites' own privacy policies.

5. Who receives data (processors)

We have a data processing agreement with each processor. We do not sell personal data and we do not share it with advertisers, data brokers, licensing authorities, operators or insurers.

6. International transfers

RevenueCat and PostHog are US companies; Google Cloud is a US group. Where personal data leaves the United Kingdom or the European Economic Area, we rely on the UK International Data Transfer Agreement or the European Commission's Standard Contractual Clauses with the UK International Data Transfer Addendum, and on the providers' technical safeguards. Copies of the relevant clauses are available on request.

7. Retention summary

8. Your rights

Under the UK GDPR (and the EU GDPR if you live in the EU) you have the right to access, rectify, erase, restrict and port your personal data, to object to processing based on legitimate interest, and to withdraw consent where processing is based on consent. Because we hold no identity data, we handle requests using your anonymous app user ID:

1. Erase data on your device: Settings > Data > Reset app data. This deletes the local database and preferences.
2. Erase data on our systems and at our processors: copy your ID from Settings > About > Your anonymous ID and email it to contact@bisaitechnologies.com with the subject "Delete my data". We delete the matching records at RevenueCat, PostHog and on our server within 30 days and confirm by reply. Deleting the RevenueCat record ends access to any active subscription on that ID; cancel the subscription in your store settings first if you do not want to be billed again.
3. Access or portability: email your ID and we send you the data we hold against it in a machine-readable format within 30 days.
4. Stop analytics: Settings > Privacy > Share usage analytics.

We do not verify identity beyond possession of the ID, because the ID is the only link between you and the data.

You may lodge a complaint with the Information Commissioner's Office (Wycliffe House, Water Lane, Wilmslow SK9 5AF; ico.org.uk; 0303 123 1113). If you live in the European Union you may instead complain to the supervisory authority of the country where you live.

9. Users in California (CCPA/CPRA)

In the past 12 months we have collected these categories of personal information: identifiers (anonymous app user ID), commercial information (subscription purchase records), internet or other electronic network activity (in-app interactions, crash data). We collect them for the business purposes described in section 4. We do not sell personal information and we do not share it for cross-context behavioural advertising. We do not collect sensitive personal information. You have the right to know, delete and correct, and the right not to be discriminated against for exercising these rights. Exercise them by emailing contact@bisaitechnologies.com with your anonymous ID.

10. Children

The app is intended for adults applying for a taxi or private-hire driver licence. It is not directed to anyone under 16, and we do not knowingly process data from children under 16. If you believe a child under 16 has used the app and data has been sent to us, email us with the anonymous ID and we will delete it.

11. Security

All traffic between the app and our server, RevenueCat and PostHog uses TLS. Content packs are signed (Ed25519) and hash-verified before use. Our server is protected by rate limits per anonymous ID, and administrative access requires authentication. No system is perfectly secure; if a breach affecting your data occurs, we will notify the ICO (and any other competent authority) and, where required, affected users through the app.

12. Changes to this policy

When we change this policy we update the version number and effective date at the top, publish the new text at the URL above, and, for material changes, show a notice in the app. Continued use after the effective date means the new version applies.

13. Contact

Bisai Technologies — Privacy Officer 131 Continental Dr, Suite 305, Newark, DE 19713, United States contact@bisaitechnologies.com