This Privacy Policy explains how Stockimg AI Yazılım Teknolojileri A.Ş ("Stockimg AI", "we", "us" or "our"), based in Türkiye, handles information in connection with the K53 Learners Test mobile application (the "App"). The App helps you prepare for the official South African Learner's Licence test, which is based on the K53 system, as administered at Driving Licence Testing Centres (DLTCs).

We built the App to be private by design: it works without an account, and your study data lives on your device. Please read this policy together with our Terms of Service.

Summary

• You can use the App without creating an account and without giving us your name, email address or phone number.
• Your study progress, answers, chosen region, vehicle type and exam date are stored only on your device.
• We use analytics and crash-reporting tools (Google Firebase) to understand how the App is used and to fix problems. This involves limited, mostly de-identified technical data.
• If you buy a subscription or lifetime upgrade, the purchase is handled by Apple/Google and RevenueCat; we never receive your card number.
• We do not sell your personal information and we do not show third-party ads.

Who we are

The data controller responsible for your information is:

Stockimg AI Yazılım Teknolojileri A.Ş
Türkiye
Email: support@stockimg.ai

Information stored only on your device

The following is created as you use the App and is kept in local storage (an on-device SQLite database and key-value store). It is not transmitted to us and we cannot see it:

• Your answers, quiz attempts, scores, "mistakes" list and lesson progress.
• Your onboarding choices: selected country/region, vehicle type, daily goal and target exam date.
• App preferences such as whether onboarding is complete.

This data is removed when you delete the App (subject to your device's backup settings, which are controlled by you and by Apple/Google).

Information collected automatically (analytics & diagnostics)

To keep the App reliable and improve it, we use Google Firebase — specifically Firebase Analytics, Firebase Crashlytics and Firebase Remote Config. These tools collect a limited set of technical information, which may include:

• App events and usage, such as screens viewed, features used, quizzes started/completed and session activity.
• Device and technical data: device model, operating-system version, app version, language and region settings, and a randomly generated app-instance / installation identifier.
• Approximate, coarse location derived from your IP address (typically country or region level) — we do not collect GPS or precise location.
• Diagnostic and crash data: when the App crashes or errors, Crashlytics records a crash log, stack trace, and the device state at the time, to help us find and fix the bug.

Remote Config is used to fetch configuration values (for example to enable a feature or run an experiment) and uses an installation identifier to deliver the right configuration. We use this data to operate, secure, debug and improve the App — not to build advertising profiles about you.

Purchase information

Premium features are sold as in-app purchases. Payment is processed by Apple App Store or Google Play, and entitlements are managed through RevenueCat, Inc., our subscription infrastructure provider. In connection with a purchase we (via RevenueCat) may process: an anonymous app-user identifier, your subscription/entitlement status, product identifiers, purchase and renewal dates, country of the store account, and the platform receipt or transaction token.

We never receive or store your full payment-card number or bank details — those are handled solely by Apple or Google.

Information we do not collect

We do not ask for or collect your name, email address, postal address, phone number, contacts, photos, microphone or camera data, or precise (GPS) location. We do not require you to sign in, and we do not track you across other companies' apps or websites for advertising.

How we use information

We use the limited information described above to:

• Provide and operate the App and its features.
• Remember your settings and study progress on your device.
• Process and restore your purchases and unlock premium content.
• Diagnose crashes, fix bugs and keep the App secure and stable.
• Understand aggregate usage so we can improve content and the learning experience.
• Configure features and run product experiments via Remote Config.
• Comply with our legal obligations and enforce our Terms.

Our justification for processing

Under POPIA, we process personal information where it is necessary to perform our contract with you (premium features), to pursue our legitimate interests in operating and improving the App, to comply with the law, or with your consent where required.

How we share information

We share information only with the service providers that make the App work, and only as needed:

• Google (Firebase) — analytics, crash reporting and remote configuration. See Google's Privacy Policy at https://policies.google.com/privacy and Firebase's data-handling at https://firebase.google.com/support/privacy.
• RevenueCat, Inc. — purchase and subscription management. See https://www.revenuecat.com/privacy.
• Apple and Google — app distribution and payment processing for in-app purchases.

We may also disclose information where required by law, to enforce our Terms, or to protect the rights, safety and security of our users, the public or Stockimg AI. If our business is involved in a merger, acquisition or asset sale, information may be transferred as part of that transaction. We do not sell your personal information.

International data transfers

We are based in Türkiye, and our service providers (including Google and RevenueCat) primarily process data on servers in the United States and other countries. This means your information may be transferred to, and processed in, countries whose data-protection laws differ from those in South Africa. Where required, such transfers are protected by appropriate safeguards (for example, the relevant standard contractual clauses or an equivalent mechanism).

Data retention

On-device data remains until you delete it or uninstall the App. Analytics and diagnostics data is retained by our providers for a limited period in line with their standard retention controls (for example, Firebase Analytics data is retained according to the retention period configured in our Firebase project, after which it is deleted or aggregated). Purchase records are retained for as long as needed to provide your entitlement and to meet legal, tax and accounting obligations.

Security

We use reasonable technical and organisational measures to protect information, including transport encryption (HTTPS/TLS) for data in transit to our providers and the security controls offered by Apple, Google and RevenueCat. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Your rights and choices

Depending on where you live, you may have rights over your personal information under the Protection of Personal Information Act, 2013 ("POPIA"). These may include the right to:

• Access — request confirmation of, and access to, the personal information we hold about you.
• Correction & deletion — request that we correct or delete personal information that is inaccurate, irrelevant, excessive or out of date.
• Objection — object, on reasonable grounds, to the processing of your personal information.
• Withdraw consent — withdraw consent where our processing relies on it.
• Complain — submit a complaint to the Information Regulator.

You can exercise many of these choices directly: you can reset or remove on-device data by clearing or uninstalling the App, and you can manage subscriptions in your Apple/Google account. To make a formal request about information held by us or our providers, contact us at support@stockimg.ai. We will respond within the time required by law. You also have the right to lodge a complaint with the Information Regulator (South Africa) (https://inforegulator.org.za).

Children's privacy

Under POPIA, a child is a person under 18. The app is intended for users aged 18 and older (the minimum age to apply for a learner's licence) and is not directed to children. We do not knowingly process the personal information of a child without the consent of a competent person. We do not knowingly collect personal information from children below that age. If you believe a child has provided us with personal information, please contact us at support@stockimg.ai and we will take appropriate steps to delete it.

Advertising and tracking

The App contains no third-party advertising and we do not use advertising identifiers (such as the IDFA) to track you across other apps and websites. Because we do not track you in that sense, the App does not request App Tracking Transparency permission for advertising. Analytics is used solely to operate and improve the App as described above.

Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date above and, where appropriate, provide a more prominent notice in the App. Your continued use of the App after an update means you accept the revised policy.

Contact us

If you have questions or requests about this policy or your information, contact us at:

Stockimg AI Yazılım Teknolojileri A.Ş
Email: support@stockimg.ai