Privacy Policy
Effective date: [PLACEHOLDER: date of site launch]
Operator/controller: Phifco Holdings LLC d/b/a Probe Request ("Probe Request", "we", "us")
Contact for all privacy matters: hello@proberequest.com
1. What we collect
- Account data: your email address (used for passwordless magic-link sign-in), account
identifier, and account creation/login timestamps.
- Purchase records: which products you bought, transaction IDs, and refund status.
Card details are never stored by us — payments are processed by a third-party
merchant of record ([PLACEHOLDER: Lemon Squeezy/Paddle — confirm at launch]), which
processes payments and handles tax compliance on our behalf.
- Per-account content seed: a deterministic per-account identifier used to generate
your variant of practice content (see our Terms — this exists for content-integrity and
leak-tracing purposes).
- Usage data: which items you have accessed/completed, quiz scores, and flashcard
scheduling data — used to run the product (progress, spaced repetition).
- Web analytics: standard, aggregated traffic analytics (pages viewed, approximate
region, device type). [PLACEHOLDER: confirm analytics provider at launch.]
We do not sell your personal data, and we do not run advertising networks on the site.
2. Why we process it (legal bases, GDPR)
- To provide the service you purchased (contract): account access, content delivery,
progress tracking, refunds.
- For content integrity and fraud prevention (legitimate interests): per-account
fingerprinting, rate limiting, abuse investigation.
- For service improvement (legitimate interests): aggregated analytics.
- For legal/accounting obligations (legal obligation): purchase records.
3. Sharing
We share only what is necessary with: our merchant of record (payments/taxes), our
hosting and email infrastructure providers, and — when legally compelled — authorities.
We never sell data or share it for third-party advertising.
4. Retention
Account and purchase records are kept for as long as your account exists plus the period
required for tax/accounting law (generally up to 7 years for purchase records). Per-account
content seeds and access marks are retained for content-integrity purposes for the same
period. Analytics are aggregated and retained per the provider's default retention.
5. Your rights
Wherever you live, you can ask us to: access your data, correct it, export it, or delete
it (subject to retention obligations for purchase records). EEA/UK users may also object
to or restrict certain processing and lodge a complaint with a supervisory authority.
California users have CCPA/CPRA rights, including the right to know, delete, and
correct, and the right not to be discriminated against for exercising them; we do not
"sell" or "share" personal information as defined by California law. Email
hello@proberequest.com to exercise any right — we respond within statutory timeframes.
6. Cookies
We use only cookies/local storage strictly necessary to operate the site (authentication
session) plus optional analytics. No advertising cookies, no cross-site tracking.
7. Security and transfers
Data is stored on our managed servers with encryption in transit; access is limited to
the operator. If data is transferred internationally, we rely on appropriate safeguards
(e.g., EU Standard Contractual Clauses where applicable).
8. Children
The Service is not directed to children under 13 (or under 16 in the EEA), and we do not
knowingly collect their data.
9. Changes
Material changes to this policy will be announced on the site before they take effect.
[PLACEHOLDER: confirm final list of processors (hosting, email, analytics, MoR) at launch
and append a "Sub-processors" table if desired.]