Privacy Policy
Last updated: March 2026
This privacy notice for Eelavan Ltd (“Company”, “we”, “us” or “our”) describes how and why we might collect, store, use and/or share (“process”) your information when you use our services (“Services”), such as when you:
- Download and use our mobile application, Pass Life in the UK Test, or any other application of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@eelavan.co.uk.
Summary of Key Points
What personal information do we process? When you visit, use or navigate our Services, we may process personal information depending on how you interact with the app, the choices you make and the features you use.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.
When and with whom do we share personal information? We may share information in specific situations and with specific third parties as described in this notice.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by contacting us at privacy@eelavan.co.uk. We will consider and act upon any request in accordance with applicable data protection laws.
Table of Contents
- What Information Do We Collect?
- How Do We Process Your Information?
- What Legal Bases Do We Rely On to Process Your Personal Information?
- When and With Whom Do We Share Your Personal Information?
- How Long Do We Keep Your Information?
- Do We Collect Information from Minors?
- What Are Your Privacy Rights?
- Controls for Do-Not-Track Features
- Do We Make Updates to This Notice?
- How Can You Contact Us About This Notice?
- How Can You Review, Update or Delete the Data We Collect from You?
1. What Information Do We Collect?
Personal information you disclose to us
In short: We collect personal information that you voluntarily provide to us.
We collect personal information that you voluntarily provide to us when you use the app or otherwise contact us. This includes:
- Profile information. When you set up your profile during onboarding, you may provide your first name, your planned test date and your first language. This information is used to personalise your experience and is stored in our database.
- Support communications. If you contact us for support, we may collect your name, email address and the content of your message.
Sensitive information
We do not process sensitive personal information.
Payment data
We may collect data necessary to process your payment if you make in-app purchases. All payment processing is handled by Apple (via the App Store), Google (via Google Play) and RevenueCat. We do not store your full payment card details. You may find their privacy notices here:
- Apple: https://www.apple.com/legal/privacy/
- Google: https://policies.google.com/privacy
- RevenueCat: https://www.revenuecat.com/privacy/
Information automatically collected
In short: Some information — such as your device characteristics and usage data — is collected automatically when you use our Services.
We automatically collect certain information when you use the app. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information. This information is primarily needed to maintain the security and operation of our app and for our internal analytics and reporting purposes.
The information we collect automatically includes:
- Device data. We collect device information such as your device type, operating system, unique device identifiers, device settings, app version and crash data. This data is collected through Firebase Analytics and Firebase Crashlytics.
- Usage data. We collect information about how you use the app, such as features accessed, screens viewed, session duration and other diagnostic data. This data is collected through Firebase Analytics in aggregated form.
- Push notification tokens. If you opt in to push notifications, we collect a device token to deliver notifications such as study reminders. You can opt out at any time through your device settings.
Third-party SDKs
Our app uses the following third-party services that may collect data:
| Service | Purpose | Data collected |
|---|---|---|
| Firebase Analytics | App analytics and usage reporting | Device info, app usage data, crash logs |
| Firebase Crashlytics | Crash reporting and diagnostics | Device info, crash traces, app state |
| RevenueCat | Subscription management | Purchase history, subscription status, anonymous user ID |
| Apple/Google Push Services | Push notifications | Device push token |
2. How Do We Process Your Information?
In short: We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To provide and maintain our Services. We process your information to deliver the app’s features, manage your account and handle in-app purchases.
- To personalise your experience. We use your profile information (name, test date, first language) to tailor the app experience to your needs.
- To send push notifications. We may send you study reminders, progress updates or other notifications related to the app. You can opt out at any time through your device settings.
- To improve our Services. We use analytics data to understand how the app is used, identify issues and improve functionality.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including crash monitoring and fraud prevention.
- To comply with legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
3. What Legal Bases Do We Rely On to Process Your Personal Information?
In short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:
- Performance of a contract. We process your profile information and purchase data to provide you with the Services you have requested.
- Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your information to analyse how our Services are used so we can improve them, to diagnose problems and prevent fraudulent activities, and to send push notifications about your study progress.
- Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us.
- Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency.
4. When and With Whom Do We Share Your Personal Information?
In short: We may share information in specific situations described in this section and with the following third parties.
We may need to share your personal information in the following situations:
- Service providers. We share data with third-party service providers who perform services on our behalf, including Firebase (analytics and crash reporting), RevenueCat (subscription management) and Apple/Google (payment processing and push notifications). These providers only have access to the information necessary to perform their functions and are contractually obligated to protect your data.
- Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
- Legal requirements. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order or legal process.
We do not sell your personal information to third parties. We do not share your personal information with third parties for their direct marketing purposes.
5. How Long Do We Keep Your Information?
In short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. Do We Collect Information from Minors?
In short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@eelavan.co.uk.
7. What Are Your Privacy Rights?
In short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right:
- To request access and obtain a copy of your personal information
- To request rectification or erasure of your personal information
- To restrict the processing of your personal information
- To data portability, if applicable
- To object to the processing of your personal information
You can make such a request by contacting us at privacy@eelavan.co.uk. We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection authority. In the UK, this is the Information Commissioner’s Office (ICO): https://ico.org.uk/make-a-complaint/
Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us at privacy@eelavan.co.uk. This will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Managing push notifications. You can opt out of receiving push notifications at any time by adjusting the notification settings on your mobile device.
8. Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
9. Do We Make Updates to This Notice?
In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Last updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
10. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may contact us at:
Eelavan Ltd
Email: privacy@eelavan.co.uk
11. How Can You Review, Update or Delete the Data We Collect from You?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information or delete it. To request to review, update or delete your personal information, please contact us at privacy@eelavan.co.uk.