PlanEx is a flashcards and study application available on iOS and the web.
PlanEx is designed to collect only the Personal Data reasonably necessary to provide, secure, support, and improve the Service.
This summary is provided for convenience. The complete Privacy Policy below explains our practices in more detail.
This Privacy Policy ("Policy") explains how Anastasiia Borodulina, Individual Entrepreneur (sole proprietor) ("PlanEx", "we", "us", or "our"), as the operator of the PlanEx flashcards and study application for iOS and the web service available at planexwithyou.web.app (together, the "Service"), collects, uses, stores, discloses, transfers, and otherwise processes Personal Data relating to users of the Service ("you" or "User").
The web version uses the same PlanEx account and is available to users with the applicable PlanEx Pro entitlement. Purchases are currently made through the iOS application and Apple App Store, not through the web version.
Your use of PlanEx is also governed by our Terms of Use, which set out the contractual terms applicable to your use of the Service.
Anastasiia Borodulina, an Individual Entrepreneur registered in the Republic of Armenia, is the data controller responsible for the processing of Personal Data described in this Policy.
We process Personal Data primarily in accordance with the Law of the Republic of Armenia "On Protection of Personal Data" No. HO-49-N of 18 May 2015, as amended ("Armenian Data Protection Law"). Depending on your location and the circumstances in which the Service is offered or used, additional laws may apply, including the EU General Data Protection Regulation ("EU GDPR"), the United Kingdom GDPR and Data Protection Act 2018 ("UK GDPR"), the Swiss Federal Act on Data Protection ("Swiss FADP"), the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL"), the U.S. Children’s Online Privacy Protection Act ("COPPA"), and applicable U.S. state privacy laws.
PlanEx is made available globally. The availability of the Service in a jurisdiction does not by itself mean that every privacy law of that jurisdiction applies in every circumstance. Where an applicable law gives you additional or stronger rights, those rights are not limited by this Policy.
This Policy describes processing for which PlanEx acts as a controller. Service Providers may process Personal Data on PlanEx’s behalf, while certain platform providers may also process information independently under their own privacy policies and terms.
By using the Service, you acknowledge that this Policy has been made available to you and that you have had an opportunity to review it. Where PlanEx relies on consent as the legal basis for a particular processing activity, we request that consent separately where required by applicable law. Accepting the Terms of Use or acknowledging this Policy does not, by itself, constitute consent where separate consent is legally required.
The data controller is:
Anastasiia Borodulina
Individual Entrepreneur (sole proprietor)
Registered address:
2 Nar-Dos Street
Yerevan 0018
Republic of Armenia
Privacy and support e-mail:
Phone:
+374 98 012 511
You may use this e-mail address for privacy questions, requests to exercise your rights, account-related privacy matters, or complaints.
Where applicable law requires PlanEx to appoint a representative in another jurisdiction, the representative’s details will be made available through this Policy or the Service.
"Personal Data" means information relating to an identified or identifiable natural person.
"Processing" means any operation performed on Personal Data, including collection, recording, organisation, storage, use, alteration, disclosure, transfer, restriction, deletion, or destruction.
"Card" means an individual study card within PlanEx.
"Module" means a collection of Cards.
"Folder" means an organisational group of Modules.
"User Content" means Cards, Modules, Folders, notes, text formatting, images, and other study materials that you create, edit, upload, or store through PlanEx.
"PlanEx Content" means pre-made study Modules made available by PlanEx through the PlanEx Cards catalogue. A PlanEx Module may contain multiple Cards and may be added to your account, edited for study, and exported where the Service permits. Intellectual-property rights in PlanEx Content are addressed in the Terms of Use.
"Service Provider" or "Processor" means a third party that processes Personal Data on behalf of or in connection with providing services to PlanEx.
"Data Subject" means the individual to whom Personal Data relates.
The Personal Data PlanEx processes depends on the features you use and the technical services necessary to provide those features.
PlanEx currently supports Google Sign-In and Sign in with Apple. We may process:
PlanEx does not receive your Google or Apple password. Google and Apple also process information independently under their own privacy policies and platform terms.
When you create, edit, upload, save, or study content through PlanEx, we may process:
PlanEx Cards provides pre-made PlanEx Content in the form of Modules. If you add a PlanEx Module to your account, information about that addition, your edits, and your study activity may become part of your account and study data. The intellectual-property status of the underlying PlanEx Content is governed by the Terms of Use.
User Content is private by default and is not made public merely because you create or save it. PlanEx does not currently provide direct public sharing of User Content inside the Service. If you export content as a file and share that file outside PlanEx, the exported copy is outside PlanEx’s control.
PlanEx is a study tool and is not intended to be used as a repository for highly sensitive or special-category Personal Data about identifiable real people. You should not upload another person’s medical records, government identifiers, biometric information, financial credentials, or similarly sensitive personal information unless you have a lawful right and a genuine need to do so. If such information is nevertheless included in User Content, PlanEx does not use it to build advertising profiles or infer sensitive characteristics for marketing.
If you contact PlanEx for support, privacy, account, or other assistance, we may process your name, e-mail address, message content, attachments you voluntarily provide, and information reasonably necessary to investigate and respond to your request.
PlanEx sends promotional or marketing e-mails only where you have separately opted in, such as through an optional marketing choice presented in connection with a purchase or another clear consent mechanism. We may retain the e-mail address, the marketing preference, and information necessary to record when and how the preference was given or withdrawn. You can withdraw marketing consent at any time using the unsubscribe method provided in the message or by contacting planexhelp@outlook.com. Withdrawing marketing consent does not affect your ability to use PlanEx or maintain a paid subscription.
Operational communications necessary to provide or secure the Service, respond to your support request, manage your account or entitlement, or notify you of important legal or service changes are not marketing communications.
PlanEx uses Firebase Analytics to understand how the Service is used and Firebase Crashlytics to identify crashes, errors, and technical problems. Depending on the platform and feature, PlanEx and its Service Providers may process:
PlanEx does not use this information to track you across apps or websites owned by other companies for advertising purposes. We may use aggregated or de-identified analytics to understand our audience, evaluate product and marketing performance, and plan advertising campaigns intended to reach prospective users. We do not use User Content, study history, account information, e-mail addresses, UIDs, or other identifiable Personal Data to create advertising audiences or remarket to individual users.
If you choose a study reminder time, PlanEx may store that preference as part of your account or settings. Study reminders on iOS are currently scheduled locally on your device using iOS notification functionality. Your device operating system controls whether notification permission is granted. PlanEx does not use study reminders for advertising.
Current PlanEx purchases are made through the Apple App Store. The web Service does not currently process purchases. After you sign in to the corresponding PlanEx account, a qualifying PlanEx Pro entitlement purchased through the iOS application may also be recognised in the web Service.
Apple processes payment credentials and billing information under its own privacy policy and legal terms. PlanEx does not receive or store your full payment-card number, card security code (CVV), or other complete payment-card credentials.
PlanEx may receive and store limited information necessary to verify purchases and manage access to paid features, including:
Limited transaction information required for legal, tax, accounting, refund, fraud-prevention, or payment-reconciliation purposes may be retained separately from ordinary User Content and study data where reasonably practicable.
Under Armenian law, PlanEx processes Personal Data on a basis permitted by applicable legislation, which may include consent, processing necessary for the agreement with you and the Service you request, or processing permitted or required by law. Where processing is based on consent, you may withdraw that consent in accordance with applicable law without affecting processing lawfully carried out before withdrawal.
Where the EU GDPR or UK GDPR applies, the table below summarises the principal purposes and legal bases. Equivalent or different legal grounds may apply under other laws.
| Processing activity | Personal Data | Purpose | EEA / UK legal basis |
|---|---|---|---|
| Account creation and sign-in | Name, e-mail/private relay address, account IDs, authentication provider, session identifiers, account settings | Create and maintain your account, authenticate you, keep sessions secure, and provide cross-device/web access | Performance of a contract |
| User Content and study functionality | Cards, Modules, Folders, notes, images, schedules, study progress, settings | Store, synchronise, organise, display, edit, export, and study content; maintain learning progress and requested features | Performance of a contract |
| Study reminders | Chosen reminder/study time and related settings | Provide reminder functionality you choose to use | Performance of a contract / requested feature |
| Purchases and PlanEx Pro | Transaction IDs, product, entitlement, trial, renewal, expiration, cancellation or refund status | Verify purchases, provide paid features, maintain entitlement, reconcile refunds and subscriptions | Performance of a contract; legal obligation where records must be retained |
| Customer support | Contact details, support messages, attachments, relevant account/technical data | Investigate and respond to requests, troubleshoot problems, and provide support | Performance of a contract where related to the Service; otherwise legitimate interests in providing support |
| Security and abuse prevention | Account, session, IP/network, device, technical and relevant activity data | Protect accounts, prevent fraud and abuse, investigate incidents, enforce Terms, and maintain service integrity | Legitimate interests; legal obligation where applicable |
| Analytics and diagnostics | Usage events, app/device/browser data, installation or technical identifiers, crash/error data, approximate region where applicable | Understand Service use, identify errors, measure performance, troubleshoot, and improve the Service | Legitimate interests where permitted; consent where applicable law requires consent for optional analytics or similar technologies |
| Marketing e-mails | E-mail address, marketing preference and consent record | Send PlanEx news, product updates, or promotional offers you have chosen to receive | Consent |
| Legal, tax, and regulatory compliance | Transaction, account, security, correspondence, or other records relevant to the obligation | Meet accounting, tax, consumer-protection, legal-claims, regulatory, or security obligations | Legal obligation; legitimate interests in establishing, exercising, or defending legal claims where applicable |
If PlanEx relies on legitimate interests, the interests include operating and securing the Service, preventing fraud and abuse, supporting users, understanding performance, and improving product reliability and usability. We consider the nature of the data, the reasonable expectations of users, and the impact on users, with particular care where a user may be under 18. Where your rights override those interests, we will not rely on legitimate interests for that processing.
The iOS application does not use browser cookies. The web Service may use cookies, local storage, or similar technologies that are necessary for authentication, account security, session continuity, requested preferences, and operation of the Service.
Firebase Analytics and related technical services may also use app or browser identifiers and similar technologies for analytics and diagnostics. Where applicable law requires consent before an optional analytics, storage, or access technology is activated, PlanEx will request the required consent before activating that technology. Where applicable, you may withdraw or change optional choices through controls provided by the Service or through browser or device settings.
PlanEx does not use cookies or similar technologies for third-party behavioural advertising or cross-app or cross-site advertising tracking.
PlanEx does not sell Personal Data. We disclose Personal Data only where reasonably necessary for the purposes described in this Policy.
Current providers include:
These providers receive or process information only to the extent reasonably necessary for the relevant service or as otherwise permitted by their own terms where they act independently. Where required, PlanEx uses contractual, organisational, or other measures designed to require processors to protect Personal Data and process it for authorised purposes.
We may disclose information where reasonably necessary to comply with applicable law, a binding court order or lawful regulatory request, cooperate with the Personal Data Protection Agency at the Ministry of Justice of the Republic of Armenia or another competent authority, establish, exercise, or defend legal claims, investigate fraud or security incidents, or protect the rights, property, safety, or security of PlanEx, users, or others.
If PlanEx or substantially all relevant business assets are reorganised, transferred, acquired, or sold, Personal Data may be transferred as part of that transaction where legally permitted. Any successor that becomes the controller of Personal Data will remain subject to applicable data-protection obligations.
We may disclose Personal Data where you specifically request, direct, or consent to the disclosure.
PlanEx is operated by a data controller established in the Republic of Armenia. The Service uses Google Firebase, Google Cloud, Apple, and Microsoft infrastructure. Personal Data may therefore be processed in Armenia, the United States, and other countries in which those providers or their subprocessors operate.
Certain current PlanEx backend Cloud Functions are deployed in the Google Cloud us-central1 region in the United States. Other Firebase products use configured resource locations or global infrastructure depending on the service. Resource locations and provider infrastructure may change as the Service develops, subject to applicable law and contractual safeguards.
Where Armenian law applies, PlanEx transfers Personal Data to another state only on a basis permitted by Article 27 of the Armenian Data Protection Law. Transfers to states recognised by the authorised body as ensuring an adequate level of protection may occur where the statutory conditions are met. Where a transfer requires prior authorisation from the competent Personal Data Protection Agency, PlanEx will obtain that authorisation before making the relevant transfer. This Policy itself does not constitute such authorisation.
Where the EU GDPR, UK GDPR, or Swiss FADP applies to an international transfer, PlanEx uses a legally recognised transfer mechanism where required, such as an adequacy decision or recognised data-protection framework, approved standard contractual protections, a UK addendum or equivalent safeguard where applicable, or another legally recognised mechanism or statutory derogation. Google’s Firebase data-processing terms include contractual mechanisms intended to support lawful international transfers where applicable.
Where the UAE PDPL applies to a cross-border transfer, PlanEx will handle the transfer in accordance with the applicable UAE requirements for transferring and sharing Personal Data outside the UAE.
You may request additional information about relevant international-transfer safeguards by contacting planexhelp@outlook.com.
PlanEx retains Personal Data only for as long as reasonably necessary for the purposes for which it was collected, subject to legal retention requirements, dispute or security needs, and the technical deletion cycles of Service Providers.
Account information, Cards, Modules, Folders, notes, uploaded images, study schedules, settings, progress, and other account-linked User Content and study data are generally retained while your account remains active, unless a shorter period applies to a particular item or you delete it through available Service controls.
When you confirm an account-deletion request, PlanEx permanently closes the account immediately, makes the account and User Content unavailable through the Service, deletes or anonymises Personal Data from PlanEx-controlled active systems where it is no longer required, and initiates deletion with relevant processors. Account deletion is permanent and cannot be reversed; PlanEx cannot recover or restore the deleted account, Cards, Modules, Folders, study progress, or other deleted User Content.
Residual copies may remain temporarily in routine backups, security systems, or processor systems. These residual copies are not available through PlanEx, are not used by PlanEx for ordinary product purposes, and are not used to recover or restore a deleted account. Under Google’s current Firebase Data Processing and Security Terms, Customer Data that has been validly instructed for deletion is removed from Google systems as soon as reasonably practicable and within a maximum period of 180 days, unless applicable law requires storage.
Certain transaction, accounting, tax, refund, settlement, fraud-prevention, or payment-reconciliation records may be retained after account deletion where required or permitted by applicable law. Documents necessary for calculation of the tax base, tax reporting, and substantiation of income, expenses, and taxes are retained for at least five (5) years starting from the relevant reporting period, or for any longer period required by applicable law.
PlanEx retains only the information reasonably necessary for those purposes. This does not mean that the contents of a deleted PlanEx account, including Cards, Modules, Folders, or study history, are retained for five years.
Support, complaint, and privacy-request correspondence may generally be retained for up to twelve (12) months after the matter is resolved, unless longer retention is reasonably necessary for an unresolved dispute, security incident, legal claim, regulatory matter, or legal obligation.
Marketing contact details are used while you remain opted in. If you withdraw consent or unsubscribe, PlanEx stops sending marketing communications and may retain a limited suppression record or evidence of your consent and withdrawal for as long as reasonably necessary to respect your preference, demonstrate compliance, or resolve a legal issue.
Analytics, Crashlytics, diagnostic, and technical information is retained according to the configured retention settings of the relevant Firebase or Google service and for no longer than reasonably necessary for analytics, troubleshooting, security, and product improvement. PlanEx periodically reviews those settings and aims to minimise retention of identifiable or device-linked analytics. Aggregated or irreversibly de-identified reports may be retained for longer because they no longer identify or reasonably relate to an individual.
Where information is relevant to an ongoing legal claim, investigation, regulatory request, fraud or security matter, or other legal obligation, the relevant information may be retained for as long as reasonably necessary to resolve that matter and comply with applicable law.
Information that has been irreversibly anonymised so that it no longer identifies or can reasonably be linked to an individual may be retained for statistical, research, security, audience-insight, and product-improvement purposes.
You may initiate account deletion from within the PlanEx application through the account or settings controls. We may ask you to re-authenticate or otherwise confirm the request to protect the account from unauthorised deletion.
When you confirm a deletion request, PlanEx permanently closes the account immediately. There is no recovery or grace period, and the deletion cannot be reversed or undone. PlanEx initiates deletion of associated Personal Data at that time.
PlanEx deletes or anonymises, where no longer required, the account and profile information, User Content, Cards, Modules, Folders, notes, uploaded images, study progress and learning history, schedules, settings and preferences, PlanEx-controlled account identifiers, and other account-linked Personal Data that no longer has a lawful or necessary retention purpose.
After the account is permanently closed, neither the account nor its deleted Cards, Modules, Folders, study progress, settings, or other deleted User Content can be recovered or restored through PlanEx. Any residual copies that may temporarily remain in processor backup or recovery systems are not used to restore the deleted account. If you later register using the same e-mail address or sign-in provider, the registration is treated as a new account and previously deleted User Content, study progress, and settings will not be restored or automatically linked to the new account.
Certain limited transaction, accounting, tax, refund, settlement, security, legal, or regulatory records may be retained where required or permitted by applicable law. Residual processor copies may also remain temporarily for the periods or criteria described in Section 9.
If you authenticated through Sign in with Apple, PlanEx will handle the related authorisation relationship in accordance with applicable Apple requirements when the account is permanently closed.
You may contact planexhelp@outlook.com if you have difficulty using account deletion or wish to exercise another privacy right.
Where the Armenian Data Protection Law applies, you may have the right to obtain information about whether PlanEx processes your Personal Data, access Personal Data relating to you, obtain information about the purposes, grounds, sources, recipients, and time limits of processing, request correction or blocking of qualifying data, request destruction where statutory conditions are met, withdraw consent where processing is based on consent, challenge unlawful processing, complain to the authorised Personal Data Protection Agency, and seek judicial protection where provided by law.
Requests may be submitted to planexhelp@outlook.com. We may need to verify your identity before acting on a request.
For written requests covered by Article 20 of the Armenian Data Protection Law, information on the availability of Personal Data or an opportunity to review it must generally be provided within five (5) working days. Where unlawful processing is identified, statutory corrective measures must be taken within the periods required by law. A reasoned written refusal of a qualifying written request will be provided within the statutory period. Where consent is validly withdrawn in circumstances covered by Armenian law, processing based solely on that consent will cease and relevant data will be handled as required by law unless another lawful basis permits or requires continued processing.
Where the EU GDPR or UK GDPR applies, you may, subject to applicable conditions and exceptions, have rights to access, correction, deletion, restriction, objection, data portability, withdrawal of consent, and complaint to a competent supervisory authority. You may also have rights concerning solely automated decisions that produce legal or similarly significant effects.
PlanEx does not currently use Personal Data to make solely automated decisions that produce legal or similarly significant effects on users.
Right to object: where PlanEx relies on legitimate interests, you may have the right to object to that processing based on your particular situation. You may also object to direct marketing at any time.
Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Withdrawal should be as easy as giving consent where applicable.
Where the Swiss FADP applies, you may exercise the rights available under Swiss law, including requesting information concerning the processing of your Personal Data, requesting correction, and seeking other remedies provided by law. International transfers subject to Swiss law will be handled using an applicable lawful transfer mechanism where required.
Where the UAE PDPL applies, you may have rights, subject to statutory conditions and exceptions, to receive information about processing, obtain or transfer certain Personal Data, request correction or erasure, request restriction or cessation of certain processing, withdraw consent where consent is the basis for processing, and object to certain automated processing or direct marketing. You may also have the right to complain to the competent UAE authority where provided by law.
UAE privacy requests may be submitted to planexhelp@outlook.com. PlanEx may need to verify your identity and will respond within the period required by applicable UAE law.
Depending on your state of residence and whether the relevant privacy law applies to PlanEx, you may have additional rights to access or confirm processing, request correction or deletion, obtain a portable copy of certain information, opt out of certain processing, and appeal certain privacy-request decisions where applicable.
As of the Effective Date, PlanEx does not sell Personal Data for money and does not use identifiable Personal Data for third-party targeted advertising or share Personal Data for cross-context behavioural advertising as those concepts may be defined under applicable U.S. state privacy laws. If that business model changes, PlanEx will update this Policy and provide any notice, opt-out, or opt-in mechanism required before the new processing begins.
Applicable U.S. privacy requests may be submitted to planexhelp@outlook.com.
PlanEx is a general-audience study application and has chosen, as a Service eligibility rule, to make the Service available only to users aged 16 and older. This Service rule is separate from any lower or different age thresholds that may apply under local privacy or contract law.
PlanEx does not currently require users to provide a date of birth as part of standard registration. Eligibility rests on the user’s representation under the Terms of Use. If you are 16 or older but have not reached the age at which you may independently enter into the Terms where you live, you must have any parent or legal-guardian permission required by applicable law.
PlanEx does not knowingly permit a person under 16 to create or use a PlanEx account and does not offer a parental-consent mechanism for under-16 accounts. Under Armenian law, where consent is required for processing Personal Data of a minor under 16, consent is provided by the minor’s legal representative. Other jurisdictions may use different child-consent thresholds or impose additional protections.
Because PlanEx may be used by users aged 16 or 17, PlanEx seeks to use privacy-protective defaults appropriate to the Service, including no third-party targeted advertising, no public-by-default User Content, and no advertising profiles built from User Content or study history.
If PlanEx becomes aware that Personal Data of a person under 16 has been collected in circumstances that do not comply with applicable law or the Terms, we will take appropriate steps, which may include restricting the account and deleting Personal Data that cannot lawfully continue to be processed. A parent or legal representative may contact planexhelp@outlook.com if they believe a person under 16 has provided Personal Data to PlanEx.
We use reasonable technical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful processing. Measures may include HTTPS/TLS encryption in transit, authentication controls, restricted administrative access, access management, secure cloud infrastructure, monitoring and diagnostics, and use of established platform providers for payment credentials.
No method of electronic transmission or storage is completely secure, so absolute security cannot be guaranteed. If a Personal Data incident occurs, PlanEx will take the measures and make the notifications or disclosures required by applicable law.
PlanEx may contain links to third-party websites or integrate services provided by third parties, including Google and Apple. This Policy does not govern independent processing carried out by those third parties. We encourage you to review their privacy policies before providing information directly to them.
As of the Effective Date, PlanEx does not operate an advertising business based on Personal Data. We do not sell Personal Data, sell User Content or study history, provide User Content to advertisers for their independent use, use identifiable account or study data to create Custom Audiences or similar advertising lists, remarket to individual users based on their PlanEx activity, or track users across apps or websites owned by other companies for targeted advertising purposes.
PlanEx may use aggregated or de-identified analytics to understand broad audience patterns, evaluate product and marketing performance, identify markets or features that perform well, and plan advertising campaigns intended to reach prospective users. For example, PlanEx may use non-identifying insights about broad geography or product usage to decide where to advertise. We do not provide advertisers with your Cards, Modules, Folders, study history, e-mail address, UID, or other identifiable Personal Data for that purpose.
If PlanEx later introduces user-level remarketing, cross-app or cross-site advertising tracking, Custom Audience or similar advertising uploads, or a sale or sharing of Personal Data as defined under applicable law, PlanEx will update this Policy before the new processing begins and will implement any legally required consent, opt-out, objection, or platform permission mechanism, including Apple platform requirements where applicable.
We may update this Policy from time to time to reflect changes in PlanEx functionality, data practices, technology, Service Providers, legal requirements, or regulatory guidance. The current version will display its Effective Date at the top.
If a change materially affects how we process Personal Data, we will provide appropriate notice before the change takes effect where required by applicable law, such as through the application, website, or e-mail. Where new consent is legally required for a new processing activity, continued use of PlanEx alone will not substitute for that consent.
If you have questions, concerns, complaints, or requests concerning this Privacy Policy or PlanEx’s processing of Personal Data, contact:
Anastasiia Borodulina
Individual Entrepreneur (sole proprietor)
2 Nar-Dos Street
Yerevan 0018
Republic of Armenia
E-mail:
Phone:
+374 98 012 511
Terms of Use: https://planexwithyou.web.app/terms.html