DRAFT – for review by ThinkMaster Inc's lawyer / Data Protection Officer before publication. Placeholders are in [brackets].
Privacy Policy
Effective [date of publication] · applies to the ThinkMaster website and the ThinkMaster apps for iOS and Android.
ThinkMaster Inc (“ThinkMaster”, “we”) respects your privacy and complies with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations and issuances of the National Privacy Commission (NPC).
1. Information we collect
| Data | Why |
|---|---|
| Name, email address, password (stored only as a one-way hash) | To create and secure your account and to contact you about it |
| Study data: chapters studied, test and mock-exam answers, scores, time taken | To provide the review course, track your progress and show your results |
| Subscription and payment records (date, amount, method, status, store transaction id). Card, GCash, Maya, Apple and Google account details are processed by the payment provider / Apple / Google and are not stored by us | To activate your subscription and for accounting and tax obligations |
| Content-protection data: a watermark ID derived from your account, which is shown on screen over study materials; screenshot / screen-recording attempts reported by the app (date, type, device platform) | To protect copyrighted review materials and to investigate leaks |
| Technical data: session cookie, device/browser type, IP address in server logs; offline-access licence data stored on your device | To keep you logged in, secure the service and make offline mode work |
We do not sell your personal data, show third-party ads, or track you across other companies' apps and websites.
2. Offline mode
If you save chapters for offline use, they are stored encrypted on your device and can only be opened in the app while your offline licence (max 7 days) and subscription are valid. Logging out, removing offline data or the end of your subscription erases them.
3. Sharing
We share personal data only with service providers that help us run ThinkMaster, under contracts that protect your data: hosting provider [name]; payment providers (PayMongo for QR Ph payments) and, for in-app subscriptions, Apple, Google and RevenueCat (subscription verification); and when required by law or a lawful order.
4. Retention
We keep your account data while your account is active. When you delete your account, your personal and study data are erased within [30] days, except de-identified payment records we must keep under tax and accounting laws (up to [10] years), and backups that are overwritten within [30] days.
5. Your rights
Under RA 10173 you have the right to be informed, to access, to object, to erasure or blocking, to rectification, to data portability, to damages and to file a complaint with the National Privacy Commission (privacy.gov.ph). You can delete your account at any time in the app (Account → Delete account) or at /delete-account.
6. Security
We use HTTPS, hashed passwords, access controls and encrypted offline storage. No system is 100% secure; we will notify you and the NPC of a personal data breach as required by law.
7. Children
ThinkMaster is intended for adults preparing for the Civil Service Examination and is not directed to children under 18.
8. Contact – Data Protection Officer
[Data Protection Officer name], ThinkMaster Inc, [Business address, City, Philippines] · [email protected]
9. Changes
We will post any changes on this page and, for important changes, notify you in the app or by email.