Privacy notice
Effective 25 September 2026. Version 2026-09-25. Read archived policy versions.
This notice explains the personal information used by the free guides, accounts and paid question banks.
About the study service
Independent study guide with exam-style practice questions. Not affiliated with, endorsed by or sponsored by IAPP.
The service uses published certification outlines and primary sources. Released question banks exclude retained source blocks labelled as third-party practice material.
Who is responsible
Victor Humenhuk is the controller responsible for personal information used to operate the study service. The contact address is Allenby Street 38, Tel Aviv-Yafo, Israel. Email studyguides@thesmios.com.
Paddle acts separately for checkout, payment, tax, fraud prevention and buyer support under its own privacy notice.
Information we use
- Account information, including your email address, authentication records and security metadata.
- Study information, including a saved diagnostic plan, weekly study hours, question progress and completed sessions.
- Purchase information, including the Paddle transaction reference, product entitlement, status and relevant timestamps. We do not receive full card details.
- Necessary technical information in security and hosting logs, such as request time, route, IP address and browser information.
- Support messages and the information you choose to include.
Free use and local storage
You may read the guide and complete the diagnostic without an account. The browser stores only information needed for a selected theme, local study progress and an unsaved diagnostic plan. You can remove it using your browser's site-data controls.
We use cookie-free aggregate analytics to count page views and three conversion events: checkout opening, a generic checkout-start failure and verified access. The event data contains only the guide, a fixed page placement, a checkout mode or a generic failure category. It does not include email addresses, transaction IDs, IP addresses or payment information. We do not use advertising trackers or persistent visitor identifiers. We do not sell personal information.
The iPhone and iPad app
The AIGP Prep app works without an account. Your study progress, such as answers, review schedule, lessons read, bookmarks, notes and results, is stored on your device. When you are signed in to iCloud, the app also keeps a copy in your private iCloud storage so progress syncs between your devices. Apple provides iCloud under its privacy policy, and we cannot read that copy.
Apple processes in-app purchases. We do not receive your name, email address or payment details, only the aggregate sales reports Apple provides to developers. The app has no analytics, advertising or tracking, and daily reminders are scheduled on your device. To delete app data, use Reset progress in the app's settings, or delete the app and its iCloud data in your device settings.
Why we use information
- To create and secure an account, save progress and provide purchased access.
- To fulfil a purchase, handle refunds and keep accounting records.
- To answer support requests and exercise or defend legal claims.
- To prevent misuse, investigate incidents and maintain service security.
- To comply with tax, accounting, consumer and privacy law.
Depending on the context and applicable law, these purposes rely on contract, steps requested before a contract, legal obligations and legitimate interests in operating and protecting the service.
Providers and international transfers
Paddle handles checkout as merchant of record and applies its privacy notice. Neon provides database and authentication infrastructure under its privacy notice. Vercel provides website and serverless-function hosting, together with cookie-free aggregate page-view and conversion statistics, under its privacy notice. If you choose Google sign-in, Google handles that sign-in under its privacy policy.
These providers may process information outside Israel or your country. We use their contractual and technical safeguards and rely on transfer mechanisms required by applicable law.
Security
We use access controls, signed payment notifications, limited data collection and provider security controls to protect account and purchase records. No internet service can promise absolute security.
Retention
- Free accounts may be deleted after 24 months without activity.
- Abandoned checkout claims expire after 24 hours.
- Removed after the entitlement is provisioned.
- Paid entitlement records remain While the purchased question bank operates, unless the buyer requests deletion or law requires a different period.
- A minimal transaction reference is Retained only as needed for accounting, disputes, refunds and fraud prevention.
- Security logs and support records are retained only for the period needed for security, support or legal obligations.
Your choices and rights
You can export structured account data or request account deletion from the account page. You may also ask for access, correction, deletion, restriction, portability or objection where the applicable law provides that right. We respond within the period required by the law that applies to the request.
Deletion can remove saved progress and access. Some transaction records may remain where accounting, dispute, fraud-prevention or legal duties require them.
Automated processing
Diagnostic and readiness results use your study answers to show areas for review. They do not make decisions that produce legal or similarly significant effects.
Children
Accounts and purchases are only for adults aged 18 or over. The service is not directed at children.
Complaints and contact
Send a privacy request or complaint to studyguides@thesmios.com. You may also complain to the privacy or data-protection authority that has jurisdiction over your concern.
Hosting for this website
Added October 2, 2026. Cloudflare serves the new Humenhuk website. The existing Neon authentication, database and Paddle purchases remain in use. The existing backend remains hosted by Vercel. This version does not load Vercel Web Analytics on the new website.
Cloudflare processes connection information to deliver and secure website requests. Read Cloudflare’s privacy policy. The original policy and contact details above remain available.