Privacy policy

Draft 2026-10-09 – have it reviewed before launch.

Controller

Kagan Consulting (Kagan Serhan Ayik, sole proprietorship), Kerselaarlaan 12, 2220 Heist-op-den-Berg, Belgium, VAT BE0748634023. Contact: serkvay13@gmail.com.

What we process

• Anonymous wallet: a random identifier stored in your browser (localStorage) and, on our server, your access end date and learning progress (which practice questions you answered right or wrong, exam scores). No name or account needed. Legal basis: performance of the service (Art. 6(1)(b) GDPR).
• Email (optional): passed to the payment provider for your receipt; we keep only a one-way hash to let you restore access together with your payment reference.
• Payment: processed by Mollie B.V. (Netherlands). We never see card or bank details.
• Abuse protection: daily counters keyed by your IP address, deleted automatically after 2 days.

Processors

Cloudflare, Inc. (hosting, key-value storage); Mollie B.V. (payments).

Retention

Wallet and progress: until you delete them (Account → delete) or 24 months of inactivity. Payment records: as required by Belgian accounting law.

Your rights

Access, rectification, erasure, objection, portability. Complaints: Belgian Data Protection Authority (dataprotectionauthority.be).

Cookies

No tracking or advertising cookies. Only localStorage for your anonymous ID and language.