Privacy Policy
Last updated: October 9, 2026
1. Controller
Kamila Abovian
Hahnenstraße 7, 50354 Hürth, Germany
Email: support.coremoduleprep.com@gmail.com
2. What data we process
Account data: email address and authentication identifiers, collected via our authentication provider, Clerk, when you sign up or sign in.
Usage data: your practice sessions, exam results, and progress statistics, stored so the service can show your history and track your access period.
Payment data: when you purchase a plan, our reseller Paddle collects your billing details and payment method directly. We never receive or store your card number, CVV, or full billing address — we only receive confirmation that a payment succeeded or failed, and an identifier we use to activate your access.
Exam feedback: after a full exam simulation you may fill in a short optional survey. By default your answers are linked to your account email so we can follow up if needed. If you tick "Send anonymously", your email is not shown to us together with your answers. For technical reasons the entry stays linked to your account in our database (so it can be deleted with your account) but is not visible to us in the feedback overview. You can also skip the survey entirely.
3. Purposes and legal basis (Art. 6 GDPR)
Providing the service and managing your account: performance of a contract (Art. 6(1)(b) GDPR).
Processing payments and issuing invoices via Paddle: performance of a contract and compliance with legal obligations (Art. 6(1)(b) and (c) GDPR).
Security, fraud, and trial-abuse prevention (e.g. device-based trial limits): legitimate interest (Art. 6(1)(f) GDPR).
Evaluating optional exam feedback to improve the tasks and the simulation: legitimate interest (Art. 6(1)(f) GDPR). Participation is voluntary.
4. Recipients / processors
Clerk — authentication and account management. Clerk may process data outside the EU/EEA under appropriate safeguards (EU Standard Contractual Clauses).
Vercel — website hosting and infrastructure. Vercel may process data outside the EU/EEA under appropriate safeguards (EU Standard Contractual Clauses).
Paddle.com Market Ltd — payment processing, tax handling, and invoicing, acting as Merchant of Record for all paid orders. See Paddle's own privacy policy at paddle.com/legal/privacy.
We do not use any analytics, advertising, or tracking services at this time.
5. Cookies
We only set strictly necessary cookies required for you to stay signed in (via Clerk) and to complete a purchase (via Paddle). These do not require consent under § 25(2) TDDDG. We do not use any analytics or advertising cookies.
6. Storage duration
Account and usage data are kept for as long as your account exists, and deleted or anonymized within a reasonable period after deletion is requested. Payment records are retained by Paddle and by us as required by German tax law (typically 10 years for invoices, § 147 AO).
7. Your rights
Under the GDPR you have the right to access (Art. 15), rectify (Art. 16), erase (Art. 17), restrict (Art. 18), or port (Art. 20) your data, to object to processing (Art. 21), and to lodge a complaint with a supervisory authority — in North Rhine-Westphalia, the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen. To exercise any of these rights, contact support.coremoduleprep.com@gmail.com.
8. Automated decision-making
We do not use automated decision-making or profiling that produces legal or similarly significant effects on you.