Effective Date: 22/03/2025

Jointmind Ltd ("we," "us," "our"), a limited company registered in UK, operates the Pocket Examiner mobile application (the "App"). We are committed to protecting your privacy and complying with data protection laws, including the UK Data Protection Act 2018, the General Data Protection Regulation ("GDPR"), and other applicable privacy laws globally.

This Privacy Policy outlines how we collect, use, disclose, and protect your information when you use our App. By using the App, you agree to the terms outlined in this Privacy Policy.

1. Information We Collect

a. Information You Provide:

Email and Password: We use Firebase Authentication to allow users to log in using their email addresses. Passwords are securely managed by Firebase, and we do not have direct access to or visibility of your passwords.

Nickname: You may optionally create a nickname. This nickname is publicly visible by default to other app users unless you opt out of appearing on the app-wide leaderboard. You must not use personal, sensitive, offensive, or inappropriate text as your nickname.

User-generated Content: Any information, text, audio, custom questions, or responses you submit through the App are transmitted securely via APIs to OpenAI and Google Vertex AI (Google Gemini). Be aware that submitted content may be visible to authorised personnel at OpenAI and Google, as detailed in their respective Privacy Policies and Terms of Service.

Important Notice: Do NOT submit personal, sensitive, or identifiable information when creating questions, responses, or any text-based input within the App.

b. Automatically Collected Information:

Usage Data: We record how many questions you ask per day, token usage per question, your last app usage date/time, and whether your token usage exceeds the fair-use policy limits. We collect your app version, your device's model and your speciality choices e.g. anaesthesia. This data is stored securely in Firebase Firestore and linked to your email address.

Device and App Security: We utilise Firebase App Check and authentication methods to secure the data transmission.

2. How We Use Your Information

We use your information to:

Provide and maintain the App and its functionalities;

Authenticate your login securely;

Monitor usage and enforce fair-use token limits;

Facilitate in-app purchases, subscription services, and token top-ups through RevenueCat;

Analyse app usage to enhance performance and improve user experience;

Comply with legal obligations.

3. Sharing and Disclosure of Your Information

Your information is shared as follows:

Third-party AI Providers (OpenAI and Google Vertex AI/Google Gemini): Your submitted content and custom questions are sent directly to these providers. Refer to their Privacy Policies and Terms of Service for detailed information about their data handling practices.

Firebase (Google): Firebase Authentication and Firestore securely store your login information, usage data, and settings.

RevenueCat: Handles subscriptions and in-app purchases. RevenueCat only processes Firebase-generated user IDs and does not store personally identifiable information.

4. International Data Transfers

We transfer and process data outside of your country of residence. Both OpenAI and Google Firebase have established Standard Contractual Clauses (SCC) agreements covering the secure international transfer of data, in compliance with GDPR and other applicable laws.

5. Security of Your Information

We implement robust security measures, including Firebase security protocols, data encryption, and Firebase App Check, to protect your data from unauthorised access or disclosure.

6. User Rights

Under GDPR and UK data protection laws, you have the following rights:

Access to your personal data;

Correction or updating of your personal data;

Deletion or restriction of processing of your personal data;

Data portability.

To exercise your rights or request further details, please contact us.

7. Data Retention

We retain your data only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by law.

8. Children's Privacy

Our App is not intended for users under the age of 16, and we do not knowingly collect personal information from children under 16.

9. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. Updates will be communicated via the App or by email. Continued use of the App after updates constitutes acceptance of the revised policy.

10. Contact Us

For questions or concerns about this Privacy Policy or our privacy practices, contact:
Jointmind Ltd at jointmindltd@gmail.com

Please also consult the following privacy documents for third-party services used:

OpenAI Privacy Policy

Google Privacy Policy

RevenueCat Privacy Policy

By using our App, you acknowledge you have read and understood this Privacy Policy.