Privacy Policy

Effective: 31 October 2026

Clearway is a product of Nice Dijital Teknolojiler Yazılımları Limited Şirketi, a company registered in Türkiye ("we", "us", "our"). This policy explains what data the Clearway app ("App") collects, why, and the choices you have. We are the data controller for the data described here.

1. What we collect

Information you give us during onboarding

• The licence category you are studying for
• Your test date (if you enter one), how many minutes a day you want to study, and how confident you feel
• The test centres you pick for cancellation alerts (if you use that feature)

Study activity

• Which practice questions you answered, whether you got them right, and when
• Your mock test scores and how long each one took

Collected automatically

• A random identifier created by the App on your device. It is not linked to your device hardware or advertising ID.
• Your platform (iOS, Android or web)
• A push notification token, only if you allow notifications
• Your subscription status and purchase events, sent to us by our payments provider, Adapty

What we do not collect

• Your name, email address, phone number or postal address. Clearway has no accounts or passwords.
• Your location, contacts, photos or browsing history
• Your device's advertising identifier (IDFA/GAID). We do not track you across other companies' apps or websites.
• Your card or payment details. Payments are handled entirely by Apple or Google.

2. How we use it

• To build your study plan and show your progress and readiness score
• To unlock Clearway Pro when you subscribe or buy lifetime access
• To send notifications you have agreed to, such as study reminders and test-cancellation alerts
• To assess pass-guarantee refund requests
• To improve the questions and the App, using aggregated statistics

Our legal bases under the GDPR are performance of our contract with you (providing the App and your purchases), your consent (notifications), and our legitimate interest in improving the App.

3. Who we share it with

We do not sell your data or share it for advertising. We use these service providers, who process data only on our instructions:

• Adapty: subscription and purchase management (privacy policy)
• Apple App Store / Google Play: payments and push notification delivery
• Railway: hosting for our server and database
• Expo (650 Industries): relays push notifications to Apple and Google; it receives your push token and the message text

We may also disclose data if the law requires it, or to protect our rights.

4. Where your data is stored

Most of your study data stays on your device, and the App works offline. A copy is kept on our servers, which may be outside the European Economic Area. Where data leaves the EEA we rely on the European Commission's Standard Contractual Clauses or an adequacy decision. Data is encrypted in transit (TLS).

5. How long we keep it

• Data on your device: until you delete the App
• Study activity and onboarding answers on our servers: up to 24 months after your last use of the App, then deleted
• Purchase records: as long as tax and accounting law requires
• Push tokens: until they stop working or you turn off notifications

6. Your rights

Under the GDPR you can ask to access, correct, delete or export your data, object to or restrict how we use it, and withdraw consent at any time. You can turn off notifications in your device settings. To make a request, email support@settlescout.app. Because we have no accounts, tell us your device model and roughly when you installed or bought Clearway so we can find your data.

You can also complain to the Irish Data Protection Commission (dataprotection.ie) or your local data protection authority.

7. Children

Clearway is meant for people preparing for a learner permit, so it is for users aged 16 and over. We do not knowingly collect data from children under 16. If you think a child under 16 has used the App, contact us and we will delete their data.

8. Changes

We may update this policy. We will show the new effective date here and tell you in the App about significant changes.

9. Contact

Nice Dijital Teknolojiler Yazılımları Limited Şirketi, Türkiye
Email: support@settlescout.app