Privacy Policy

Effective Date: July 25, 2026 Last Updated: August 22, 2026

This Privacy Policy applies to the mobile application distributed by D73 with iOS bundle identifier com.d73.cdl on the Apple App Store, and to any Android version of that same application we publish through Google Play. Throughout this policy that application is called "the App."

Why this policy does not print a product name. The App's store listing and

the name shown on your device may change over time. A bundle identifier does

not: com.d73.cdl identifies this application permanently and unambiguously,

whatever it is called on the day you read this. Naming the App here would mean

this policy could describe a name the App no longer uses, and a privacy policy

that does not match the product it governs is worse than one that is simply

precise. You can confirm the identifier on the App Store listing page.

The App is developed and published by D73 ("we," "our," "us"), an independent developer. The App is a study companion that helps you prepare for the written CDL knowledge tests (general knowledge, air brakes, combination vehicles, and endorsements). It provides reading chapters, practice tests and timed simulators, a personalized study plan, progress analysis, and reminders.

By using the App, you agree to this Privacy Policy. If you do not agree, do not use The App.

1. What This Policy Covers

This Privacy Policy explains what information we collect, how we use it, what we share, how we secure it, and the choices you have. It applies to the App, our backend services, and subscription processing.

2. Important Disclaimer

The App is an independent study aid. It is not an official or certifying service.

The App is not affiliated with, endorsed by, or sponsored by the Federal Motor Carrier Safety Administration (FMCSA), the U.S. Department of Transportation, the American Association of Motor Vehicle Administrators (AAMVA), or any state Department of Motor Vehicles or licensing agency.
The App is a study and practice tool for general exam preparation only. It does not register you for any test, does not issue a commercial learner's permit or a CDL, is not an Entry-Level Driver Training (ELDT) provider, and is not a substitute for your state's official driver manual or a certified training program.
Passing practice tests or simulators in the App is not a guarantee of passing an actual CDL knowledge test.
Content in the App is for educational purposes and may be generated or assisted by artificial intelligence. While we work to keep it accurate and aligned with CDL knowledge-test preparation, we do not warrant that it is error-free or complete. Always verify against your state's official CDL manual.
The App does not provide medical, clinical, legal, or professional advice.

3. Core Privacy Commitments

The App is built with privacy-first defaults:

We do not sell personal information.
We do not share personal information for cross-context behavioral advertising.
We do not show in-app advertisements.
We do not use third-party ad tracking.
We do not collect precise location or GPS data.
We do not access your contacts.
We do not access your microphone, camera, photos, or voice recordings.
We do not collect health or fitness data.
We do not require a traditional email/password login.
We do not store full payment card details.
Payments are handled by Apple, Google Play, and RevenueCat.
Notifications are optional and require operating-system permission.

4. Information We Collect

4.1 Profile Information You Provide

During onboarding and personalization, you may provide:

The CDL class you are pursuing and the tests or endorsements you have selected
Your U.S. state or jurisdiction
Where you are in your CDL journey
Your target exam date, or that you do not yet have one
How many minutes per day you plan to study
Your preferred study time
Your answers to the optional diagnostic questions

We use this information to personalize your study plan, reminders, and recommendations.

4.2 Study Activity and User Content

When you use the App, you may generate:

Chapters or lessons you read and mark complete
Quiz and mock-exam answers, scores, and history
Custom quiz settings and practice activity
Your personalized study plan and progress
Streaks, completion history, readiness, and performance trends

This information is stored on your device and on our servers so the App can show your history, calculate progress, unlock the right features, and personalize your study experience.

4.3 Identifiers

The App uses:

Device ID: A unique app/device identifier used for authentication, data identification, sync, abuse prevention, and account deletion without requiring a traditional login.
Installation secret: A local credential used to help protect your backend account from unauthorized requests.
RevenueCat user identifier: A subscription identifier used by RevenueCat to manage purchases and entitlement status.

The App does not collect advertising identifiers such as Apple's IDFA or the Google Advertising ID.

4.4 Usage Data

To operate and improve the App, we collect:

Learning and quiz events and timestamps
Study-plan state, streaks, and progress
Reminder and notification settings
Feature usage patterns
Screen views, button taps, and interaction events
App version, locale, time zone, device model, and operating system version
Approximate country, region, and city inferred from network IP for analytics

4.5 Technical and Diagnostic Data

We may collect technical data such as:

Crash logs and error reports
Network and API failure information
Device model and operating system version
App version, locale, and time zone
Performance and diagnostic logs needed to maintain stability

In development and testing builds, logs may be more detailed so we can diagnose issues before release. Production logging is limited to what is needed for stability, security, support, and service operation.

4.6 Purchase and Subscription Data

The App offers optional premium subscriptions. If you subscribe:

Payment is processed by the Apple App Store on iOS or Google Play on Android.
We do not receive or store your full payment card details.
Premium may be offered as an auto-renewing subscription, and may include an introductory or free-trial period. Plan lengths and prices are shown on the purchase screen in the App.
After any trial ends, the subscription renews automatically through Apple or Google Play unless cancelled.
RevenueCat manages subscription status, purchase verification, trials, renewals, cancellations, and entitlement state on our behalf.
RevenueCat receives subscription event data, product identifiers, store transaction information, and a RevenueCat user identifier.
Our backend stores subscription state so the App can unlock Premium features and keep frontend/backend access in sync.

RevenueCat and the app stores are the source of truth for paid access. The App does not use static pricing or local-only fake purchase state for production access.

4.7 Notification Permission Status

If you enable reminders, your operating system will ask for notification permission. The App checks whether permission is enabled so it can schedule study reminders and nudges.

4.9 Support Email

Support is handled by email. When you tap the support row in Settings, the App opens your own email application with our address filled in; nothing is sent until you send it, and The App does not store a copy of your message. Once you email us, we hold that message in our mailbox in order to answer you.

5. Information We Do Not Collect

The App does not require or collect:

Precise GPS location
Contacts or address book data
Microphone audio, voice recordings, camera data, or photo library data
Health or fitness data
Advertising identifiers
Cross-app tracking data
Biometric data
Full payment card details
Browsing or search history outside the App

6. How We Use Information

6.1 Core Functionality

We use information to:

Identify your app data using your Device ID and installation secret
Show chapters, quizzes, mock exams, study plan, and progress
Calculate readiness, scores, coverage, streaks, and trends
Personalize your study plan and recommendations
Save onboarding and study history
Sync your subscription status between the App, RevenueCat, and our backend

6.3 Notifications and Reminders

We use reminder settings to schedule local study reminders and nudges if you grant notification permission.

6.4 Premium Subscriptions

We use subscription data to:

Verify purchases and restorations
Unlock Premium features for active subscribers
Manage free-trial status, renewals, cancellations, and expiration
Keep paid access synchronized across the App, backend, and RevenueCat

6.5 Analytics and App Improvement

We use anonymized or limited usage analytics to understand feature usage, improve the App, measure stability, fix bugs, and plan future improvements.

We do not send your full quiz content or payment card details to Mixpanel.

Your choice. Analytics are enabled by default when the App starts. You can turn them off at any time under Settings > Privacy > Share app analytics, without losing access to any App functionality. Turning the setting off stops further analytics from this installation; it does not delete analytics already received.

6.6 Safety, Security, and Support

We use information to prevent abuse, rate-limit excessive requests, protect backend services, troubleshoot issues, provide customer support, enforce our terms, and comply with legal obligations.

6.7 Advertising

The App shows no advertisements and does no ad tracking or ad attribution. We do not build advertising profiles about you or share your data with ad networks or data brokers.

7. How Data Is Linked to You

Core app data is linked to your Device ID and app account record so the App can show your progress, subscription state, and study plan.

Analytics events are minimized and do not include full payment card details or advertising identifiers.

8. Third-Party Services

We share information only as needed to operate the App. We do not sell personal information.

8.1 Apple App Store and Google Play

Purpose: Payments, subscriptions, refunds, purchase history, and subscription management.

Apple Privacy Policy: https://www.apple.com/legal/privacy/
Google Privacy Policy: https://policies.google.com/privacy

8.2 RevenueCat, Inc.

Purpose: Subscription management, purchase verification, entitlement status, trial tracking, renewal status, and webhook events.

Data shared: Subscription events, product identifiers, transaction metadata, store information, and a RevenueCat user identifier.

Data not shared: Support messages, full study history, or payment card details.

RevenueCat acts as a service provider/processor on our behalf.

8.3 Mixpanel, Inc.

Purpose: Product analytics and app improvement.

Data shared: Limited usage events such as screen views, taps, feature interactions, device model, operating system version, app version, locale, approximate country, region, and city inferred from network IP, and performance signals.

Data not shared: Precise GPS location, payment card details, support messages, or full quiz content.

8.4 Fly.io

Purpose: Hosting our backend API service.

Our backend receives and processes requests from the App, including account registration, onboarding sync, quiz and study activity, and subscription sync routing. No artificial-intelligence provider is in this path.

8.5 Google Cloud / Firebase

Purpose: Database and server-side storage.

Firebase/Google Cloud stores backend app data such as your Device ID, account record, onboarding profile, study activity, quiz history, study plan, derived progress scores, and subscription state.

Firebase Privacy and Security: https://firebase.google.com/support/privacy
Google Privacy Policy: https://policies.google.com/privacy

9. How We Share Information

9.1 Service Providers

We use service providers for hosting, database storage, analytics, subscription management, and payment processing. These providers process information only as needed to provide their services to us and are expected to protect it under their own security and privacy obligations.

9.2 Legal Reasons

We may disclose information if required by law, legal process, court order, or government request; to protect the rights, safety, and security of the App, users, or the public; to prevent fraud or abuse; or to enforce our Terms of Use.

9.3 Business Transfers

If the App is acquired, merged, financed, reorganized, or transferred, information may be transferred to the successor entity as part of that transaction.

10. Data Storage and Security

10.1 On-Device Storage

Some information is stored locally on your device, such as cached profile data, onboarding state, recent activity, settings, notification preferences, premium status cache, and study progress needed for fast loading.

10.2 Server-Side Processing

Some information is processed by our backend and stored using Firebase/Google Cloud. This includes account records, study activity, quiz history, study plan, derived scores, subscription state, and other data needed to operate the App.

10.3 Security Measures

We use industry-standard safeguards such as HTTPS/TLS transmission, access controls, backend authentication using device credentials, rate limiting, security headers, data minimization, and secure infrastructure practices. However, no method of storage or transmission is 100% secure, and we cannot guarantee absolute security.

11. Data Retention

On-device data remains until you delete the App or clear app data.
Server data is retained while your account is active and for a reasonable period afterward for backup, recovery, legal, or operational purposes.
Study activity is retained to calculate progress, streaks, scores, readiness, and recommendations.
Emails you send us are retained in our mailbox so we can answer and follow up.
Deleted-account data is deleted from active systems within a reasonable period, generally within 30 days, unless retention is required by law, security, fraud prevention, or backup processes.
Some records may remain in backups for a limited period before deletion cycles complete.

12. Your Rights and Choices

12.1 In-App and Device Controls

Notifications on iOS: iOS Settings > Notifications > (the App)
Notifications on Android: Android Settings > Apps > (the App) > Notifications
Subscription management on iOS: iOS Settings > Apple ID > Subscriptions
Subscription management on Android: Google Play > Profile > Payments & subscriptions > Subscriptions
Delete local data: uninstall the App or clear app data where your operating system allows it

12.2 Account Deletion, Access, Correction, and Export

The App contains a "Delete my data" control in Settings. Using it permanently deletes your account record and the server-side data associated with it — onboarding profile, study plan, study activity, quiz and simulator history, chapter completions, bookmarks, and subscription state held by us. It also clears the App's local data and any scheduled reminders on your device. No email, no form, and no request to us is required.

Server-side deletion needs an internet connection. If you start a deletion while offline, or you would like written confirmation, email us and we will complete it.

You can also contact us to access, correct, export, or delete data we hold about you.

Deleting your data does not cancel an active subscription, and it does not delete purchase records held by Apple, Google, or RevenueCat. Cancel a subscription through your app-store account.

We aim to respond within 30 days and will comply with applicable data protection laws.

12.3 Privacy Rights by Region

Depending on your location, you may have rights under laws such as GDPR, CCPA/CPRA, and other regional laws. These rights may include access, deletion, correction, portability, restriction, and objection.

California residents: We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA.

13. Children's Privacy

The App is intended for adults preparing for a professional certification and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will delete it promptly. If you believe a child under 13 has provided information to us, contact us at connectstillalive@gmail.com.

14. International Users

If you use the App outside the country where our service providers operate, your information may be transferred to, stored, or processed in other countries, including the United States, where data protection laws may differ. Where required by law, we use appropriate safeguards for international transfers.

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, features, vendors, legal requirements, or improvements. We will update the "Last Updated" date above. For material changes, we may provide additional notice, such as an in-app notice. Continued use of the App after changes means you accept the updated policy.

16. Contact Us

Developer / Publisher: D73

Application: the mobile application with iOS bundle identifier com.d73.cdl

iOS Bundle ID: com.d73.cdl

Email: connectstillalive@gmail.com

Response Time: 24-72 hours for support messages where possible; privacy requests are generally handled within 30 days.

For data access, correction, export, or deletion requests, please include your Device ID or display name and a description of your request.

17. Additional Legal Documents

Terms of Use: https://cdl-prep-api.fly.dev/legal/terms
Support Page: https://cdl-prep-api.fly.dev/legal/support
Apple Standard EULA: https://www.apple.com/legal/internet-services/itunes/dev/stdeula/

The App is an independent study aid. It is not affiliated with, endorsed by, or sponsored by the Federal Motor Carrier Safety Administration (FMCSA), the U.S. Department of Transportation, the American Association of Motor Vehicle Administrators (AAMVA), or any state Department of Motor Vehicles or licensing agency. Those names are used only to identify the tests this App helps you study for.