Privacy Notice

Who is responsible

Patrick Kennelly, an individual based in Ireland, is the data controller for personal data processed through Incisive.

What we collect and why

• Account details (email address, login credentials, Google sign-in identifier) — to create and run your account. Basis: contract.
• Practice activity (answers, scores, topics) — to show your progress and provide the service. Basis: contract.
• Access status (plan and expiry date) — to unlock paid content. Basis: contract.
• Technical data (IP address, device and browser details, logs) — for security, fraud prevention and fixing problems. Basis: legitimate interests.
• Support messages — to answer your questions. Basis: legitimate interests.

Who we share it with

• Service providers who host the site, database and sign-in;
• Paddle, our Merchant of Record, for the sale of your plan, payments, tax compliance and invoicing;
• Professional advisers such as accountants and lawyers;
• Authorities, where required by law.

International transfers

Some providers process data outside the EEA. Where they do, we rely on adequacy decisions or Standard Contractual Clauses.

How long we keep it

We keep account and progress data while your account is open, and delete or anonymise it within 12 months of closure unless the law requires longer (for example, records of sales).

Your rights

Under the GDPR you can request access, correction, erasure, restriction, portability, object to processing, and withdraw consent at any time. We respond within one month. You can complain to the Data Protection Commission (dataprotection.ie).

Security

We use appropriate technical and organisational measures, including encryption in transit and access controls on stored data.

Cookies

We use only essential storage needed to keep you signed in. We do not use advertising or analytics cookies.