Tutor
Tutor collects no personal data. The app makes no network connections of any kind. It contains no analytics, no advertising, no tracking, no crash reporting, and no accounts. Everything you do in the app stays on your device. We operate no servers and receive no information about you.
The one exception is your purchase, which is handled entirely by Apple as the seller.
Who is responsible
The controller for the purposes of the General Data Protection Regulation (GDPR) is:
C-Media
Lange Poten 5A
2511 CL The Hague
The Netherlands
info@c-media.nl
Chamber of Commerce (KvK) 28109880
We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 GDPR.
What this policy covers
This policy applies to the iOS application Tutor. It does not cover Apple's own processing of your data, which is described in the Apple Privacy Policy.
Data we collect
We do not collect, receive, store, or process any personal data about you. Specifically, Tutor does not:
- require or offer an account, registration, login, or email address;
- contain any analytics, measurement, or attribution software;
- contain any advertising or any advertising identifier;
- collect crash reports or diagnostic data on our behalf;
- read your contacts, photos, location, calendar, microphone, or camera;
- use cookies, web beacons, or any comparable technology;
- collect device identifiers, IP addresses, or usage statistics;
- track you across apps or websites owned by other companies.
We operate no servers and maintain no database of users.
Data stored on your own device
Tutor stores your learning progress, review schedule, and app settings locally on your device so that the app can function between sessions. This information:
- remains on your device;
- is not transmitted to us or to anyone else;
- is not accessible to us in any form;
- is protected by the security of your device.
If you have enabled encrypted device backups through iCloud or a computer, this local data may be included in your own backup. That backup belongs to you and is governed by Apple's terms.
Deleting the app from your device deletes this data.
No network connections
Tutor functions entirely offline. All content is bundled with the app itself. The app does not contact any server operated by us or by any third party, which means no IP address or connection metadata about you is generated by using it.
Your purchase
Tutor offers a single one-time in-app purchase that unlocks all content.
Apple is the merchant of record. The entire transaction, including payment, billing, receipts, refunds, and any purchase-related correspondence, is carried out by Apple with you directly. Apple acts as an independent controller for that processing, under the Apple Privacy Policy.
As a result:
- we don't see nor receive your name, email address, Apple Account details, payment card, or billing address;
- your entitlement is verified on your device by iOS; no verification request is sent to us;
- restoring a previous purchase on a new device is handled by Apple through your Apple Account, without our involvement;
- the only information we receive from Apple is aggregated sales and financial reporting, which shows totals by territory and period and does not identify individual purchasers.
If you need a refund, a receipt, or a change to your purchase, please contact Apple Support.
Sharing and international transfers
We share nothing, because we don't hold any personal data. We use no processors, no cloud services, no software development kits, and no subcontractors in connection with the app, and we therefore carry out no transfers of personal data to countries outside the European Economic Area.
Legal basis and retention
Because we do not process personal data, we do not rely on any legal basis under Article 6 GDPR, and we have no personal data to retain, delete, or secure. Data held locally on your device is kept for as long as you keep the app installed and is under your control at all times.
Your rights
Under the GDPR you have the right of access, rectification, erasure, restriction of processing, objection, and data portability, as well as the right not to be subject to automated decision-making.
These rights apply to personal data held by a controller. Since we hold no personal data about you and cannot identify you, we are generally unable to act on such a request, and Article 11(2) GDPR provides that we are not obliged to obtain additional information in order to identify you. In practice, you can exercise full control over all data associated with the app by deleting the app from your device.
You are welcome to contact us at info@c-media.nl with any question about this policy, and we will respond within one month.
If you believe your data protection rights have been infringed, you may lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens, or with the supervisory authority of your country of residence.
To exercise rights in respect of your purchase, please address Apple, as described in the section on your purchase.
Children
Tutor is not directed at children and is not offered in the App Store Kids Category.
Security
Information created by the app rests on your device and is protected by the encryption and access controls built into iOS.
Changes to this policy
We may update this policy if the app changes. The effective date on this page always reflects the current version.
If we ever introduce a feature that processes personal data, for example synchronising your progress across devices, we will update this policy and make it available before that feature is released, and we will describe the change in the App Store release notes.
Contact
C-Media
Lange Poten 5A
2511 CL The Hague
The Netherlands
info@c-media.nl
KvK 28109880