Who is responsible for your data
Samuel Powell, trading as CeMAP Coach, is the data controller for the personal information described in this policy. CeMAP Coach is an independent UK study platform. Contact the controller at hello@cemapcoach.uk.
What we collect
- Account and contact data: an internal account identifier, and your email address when you save a result, claim an account, sign in or purchase.
- Study data: PassIQ™, practice and mock answers, scores, progress, study-plan activity and any exam result you choose to report.
- Feedback you submit: the yes/no response and optional text you deliberately send through the beta feedback box. It is delivered to the CeMAP Coach support inbox through Resend and is not sent to PostHog.
- Service and security data: necessary session information and technical logs used to operate, secure and diagnose the service.
- Payment records: confirmation, product and billing-contact details supplied by Stripe. CeMAP Coach does not receive or store your full card number.
- Optional analytics: only after you actively allow it, page paths and deliberately defined product events that help us understand use of the service. We disable broad click/text autocapture and session recording, and do not send question answers or Coach message content as analytics events.
Why we use it and our lawful bases
- Contract and steps before a contract: to provide the free beta, your account, study tools, purchases, receipts and refunds.
- Legal obligation: to keep records required for tax, accounting, consumer rights and dispute handling.
- Legitimate interests: to secure the service, prevent misuse, investigate failures and improve reliability in ways that do not require optional device tracking.
- Consent: for optional PostHog analytics and any non-essential storage used for that analytics. You can refuse or withdraw this at any time through Cookie settings in the study app’s More menu, without losing access to the service.
We do not send marketing email merely because you created an account or used the free beta.
Who processes it
We use specialist providers to run the service:
- Supabase — authentication and database hosting for account and study data.
- Cloudflare — website hosting, content delivery and security.
- Stripe — payment processing when paid sales are available.
- Resend — transactional email such as account messages and purchase receipts.
- PostHog — optional product analytics only after consent.
These providers may use infrastructure in the UK, EEA or other countries. Where personal data is transferred internationally, we rely on the provider’s applicable data-processing terms and recognised transfer safeguards. We remain responsible for choosing and reviewing our processors.
How long we keep it
Paid account and study data is retained while needed to provide the paid unit access associated with your account. Free-beta and other account data is retained while the account remains in use or until you ask us to delete it, subject to periodic retention review. Optional analytics is kept only for product-improvement purposes and is reviewed at least annually. Payment, refund and tax records may be retained for up to six years where required.
When you ask us to delete your account, we aim to remove or anonymise personal study data within 30 days, except for information we must keep by law or need to establish, exercise or defend legal claims.
Cookies and similar storage
Necessary cookies or similar storage keep you signed in, protect the service and remember your privacy choice. They are used because the service cannot work securely without them.
PostHog analytics does not load until you select Allow analytics. Selecting Necessary only keeps analytics off. Cookie settings remains available here and in the study app’s More menu, so withdrawing consent is as easy as granting it. We do not use advertising trackers.
Automated scores and recommendations
PassIQ™ and study recommendations are generated from your answers and progress. They are educational feedback, not an official exam result, employment decision, credit decision or other decision that produces legal or similarly significant effects.
Your rights
Depending on the circumstances, you can ask us to access, correct, export or delete your personal data; restrict or object to processing; or withdraw consent. Email hello@cemapcoach.uk. We may need to verify your identity before acting on a request.
You can also complain to the UK Information Commissioner’s Office at ico.org.uk.
Contact
Privacy questions and rights requests: hello@cemapcoach.uk.