Privacy Policy

Last updated: July 30, 2026

Blue Lion (“we,” “us,” or “our”) has established this Privacy Policy (“Policy”) to explain how we handle personal information and other information in connection with Cloud Pass (the “App”).

This Policy describes the information we collect through the App, how we use and manage that information, how information may be shared with external service providers, and the rights available to users.

1. Information We Collect

We may collect the following information to the extent necessary to provide and operate the App.

1.1 Account Information

Email address
Name or display name
Profile image
Authentication information required for Google or Apple social login
Account identifiers

We do not directly collect or store passwords for Google or Apple accounts.

1.2 Device and Technical Information

Device type and model
Operating system and App version
Language and regional settings
IP address
App instance identifiers
Push notification tokens
Access dates and times
Error logs
Crash reports
Other technical information necessary to provide the App reliably

We do not access contacts, photos, videos, or other information stored on a user’s device without the user’s permission.

1.3 Learning and Usage Information

Certification exams and learning content used
Answers submitted to questions
Correct and incorrect answer history
Practice exam results
Learning progress
Average accuracy rates
Time spent answering individual questions
Performance by exam domain
Question review and saved-item history
Features used
App usage time and usage patterns

1.4 AI Tutor Information

When a user accesses the AI Tutor, we may collect or process the following information:

Questions and messages entered into the AI Tutor
Conversation history with the AI Tutor
The question and related learning content from which the AI Tutor was opened
AI-generated responses and explanations
Dates, times, and frequency of AI Tutor use
Technical information required to improve quality and analyze errors in AI features

Users should not enter names, addresses, phone numbers, financial information, passwords, or other sensitive information into the AI Tutor.

1.5 Subscription and Payment Information

Subscription plan
Purchase date and time
Subscription period
Transaction identifiers
Order numbers
Receipt data or other information required to verify purchases
Refund and subscription status information

Payments for the App are processed through the Apple App Store or Google Play Store.

We do not directly collect or store credit card numbers, card expiration dates, security codes, or other payment method details.

1.6 Communications

Customer support inquiries
Email and other communications
Feedback
Survey responses
Bug reports

2. How We Collect Information

We may collect information through the following methods:

Information entered directly by users in the App
Information provided through Google or Apple login
Information collected automatically when users access or use the App
Information provided by the Apple App Store or Google Play Store
Information collected through analytics, authentication, cloud infrastructure, AI, and other external services used by us
Information provided when users contact us

3. How We Use Information

We use collected information for the following purposes:

To provide, maintain, and operate the App and its main features
To create, authenticate, and manage user accounts
To provide practice questions, mock exams, explanations, review tools, and other learning features
To provide accuracy rates, answer times, domain-level results, and other learning statistics
To record and display learning progress
To provide content or study recommendations based on a user’s learning activity
To provide AI Tutor responses, explanations, and learning assistance
To verify subscription purchases, subscription periods, and access rights
To respond to subscription, refund, and payment inquiries
To analyze App usage and usage patterns
To improve the quality, functionality, usability, and performance of the App
To develop new features and services
To identify and fix errors, crashes, and other technical issues
To detect and prevent fraud, unauthorized use, security incidents, and other improper activity
To respond to customer support inquiries
To send important notices regarding accounts, subscriptions, the App, or this Policy
To respond to requests from courts, government agencies, law enforcement authorities, or other public bodies
To enforce our Terms of Use and other policies
To send promotions or other marketing communications only where the user has provided explicit consent

Users may opt out of marketing communications at any time.

4. Use of AI Services

We use AI services provided by Google to provide the AI Tutor and other AI-powered features.

Questions entered into the AI Tutor, related question content, conversation history, and other information necessary to generate a response may be transmitted to Google’s systems for AI response generation.

We seek to limit the information sent to AI services to what is necessary to provide the relevant AI functionality.

Google’s handling of information is governed by Google’s applicable terms of service, privacy policies, and the contractual terms between Google and us.

AI-generated responses are created automatically. We do not guarantee their accuracy, completeness, or the user’s success in any particular certification exam. Users should treat AI responses as learning assistance and consult official materials where appropriate.

5. External Services and Service Providers

We may engage external service providers to process personal information and other information on our behalf to the extent necessary to provide and operate the App.

The main external services we use include the following.

5.1 Authentication

Google Sign-In
Sign in with Apple

Purposes:

Account creation
User authentication
Login session management

5.2 Analytics and Crash Reporting

Google Analytics for Firebase
Firebase Crashlytics

Purposes:

Analysis of App usage and usage patterns
Identification of errors and crashes
Improvement of quality and performance

5.3 AI Services

Google AI services

Purposes:

Generation of AI Tutor responses
Provision of AI-generated explanations and learning assistance
Analysis of errors and improvement of AI feature quality

5.4 Cloud Infrastructure

Amazon Web Services

Purposes:

Operation of databases, servers, and related systems
Storage and processing of App data
Security and service reliability

5.5 Payments and Subscriptions

Apple App Store
Google Play Store

Purposes:

Subscription purchase and management
Payment processing
Purchase verification and access management
Refund processing

Each external provider processes information in accordance with its own privacy policy, terms of service, and contractual arrangements with us.

When selecting external service providers, we review their data protection practices and, where appropriate, manage them through contracts or other reasonable measures.

6. Disclosure to Third Parties

We do not sell, rent, or disclose users’ personal information to third parties except in the following circumstances:

Where the user has provided consent
Where processing is entrusted to an external service provider to provide the App
In connection with a merger, corporate reorganization, business transfer, acquisition, or similar transaction
Where required by law
Where we receive a lawful request from a court, law enforcement authority, government agency, or other public body
Where disclosure is necessary to protect the life, physical safety, or property of a person and obtaining consent is difficult
Where disclosure is necessary to prevent fraud, unauthorized use, or a serious security incident

We do not sell users’ personal information for third-party advertising or marketing purposes.

7. International Processing of Information

Information collected by us may be processed or stored on servers, data centers, or other processing facilities located outside the user’s country of residence.

These locations may include the Republic of Korea, where we are based, as well as countries or regions in which Amazon Web Services, Google, Apple, or other external service providers operate data processing facilities.

Where information is processed internationally, we seek to protect it in accordance with applicable law, this Policy, and our agreements with external service providers.

8. Data Retention

We retain information only for as long as necessary to fulfill the purposes described in this Policy.

8.1 Active Accounts

While an account remains active, we retain information necessary to provide the App, store learning progress, manage subscriptions, and fulfill the other purposes described in this Policy.

8.2 Deleted Accounts

When a user deletes an account, we immediately delete or anonymize the following information associated with that account:

Account information
Learning progress
Question answer history
Practice exam results
Question review and saved-item history
AI Tutor conversation history
Other service data directly linked to the account

However, we may retain the following information for as long as necessary to comply with law, prevent fraud, verify payment records, process refunds, resolve disputes, or fulfill another legitimate purpose:

Subscription and payment records
Records required for tax or accounting purposes
Records concerning unauthorized use or security incidents
Records necessary to respond to legal claims or disputes
Information required to be retained by law or at the request of a public authority

Such retained information will not be used for purposes unrelated to the reason for retention.

Information stored by external service providers may be subject to the provider’s own retention periods and deletion procedures.

9. Security

We implement reasonable technical and organizational safeguards designed to protect user information against unauthorized access, disclosure, loss, alteration, destruction, and other risks.

These measures may include:

Encryption of data in transit
Access restrictions
Authentication and permission management
Security configuration of servers and databases
Monitoring of errors and unusual access
Restricting access to data to persons with a business need
Periodic review of external services and infrastructure
Investigation and response procedures for security incidents

However, no method of transmission over the internet or electronic storage is completely secure.

10. Cookies and Similar Technologies

The App generally does not use browser cookies of the type commonly used on websites.

However, we may use device storage, App instance identifiers, software development kits, and similar technologies for the following purposes:

Maintaining login sessions
Saving App settings
Verifying subscription status
Analyzing usage
Detecting errors and crashes
Preventing fraud and maintaining security

Our website may use cookies or similar technologies for essential functionality, security, analytics, and other necessary purposes.

11. Account and Data Deletion

Users may request account deletion through the settings screen in the App.

Where deletion cannot be completed within the App, users may contact us at support@cloudpass.pro.

Once the account deletion process is completed, we immediately delete or anonymize the personal information and learning data associated with the account, except for the minimum information that must be retained for legal or legitimate purposes.

Deleting an account may not automatically cancel a subscription managed through the Apple App Store or Google Play Store.

Users with an active subscription must separately cancel it through the subscription management screen of the Apple App Store or Google Play Store.

12. User Rights

Depending on applicable law and the user’s location, users may have the following rights regarding their personal information:

The right to request information about the purposes and status of processing
The right to access personal information
The right to request a copy of personal information
The right to correct inaccurate or incomplete information
The right to request deletion of personal information
The right to request suspension or restriction of processing
The right to object to certain processing activities
The right to withdraw consent where processing is based on consent
The right to receive information in a structured, commonly used, machine-readable format
The right to lodge a complaint with a competent data protection authority

To exercise these rights, users may contact us at support@cloudpass.pro.

We may request information necessary to verify the identity of the person making the request.

We generally respond within 30 days of receiving a request, subject to applicable law. This period may be extended where a request is complex, multiple requests have been received, or an extension is permitted by law.

13. Children’s Privacy

The App is not designed for children under the age of 13.

We do not knowingly collect personal information from children under the age of 13.

If we become aware that we have collected personal information from a child under the age of 13, we will take steps to delete that information promptly.

Depending on the laws of the user’s country or region, minors may require the consent of a parent or legal guardian to use the App or purchase paid services.

14. Changes to This Policy

We may update this Policy in response to changes in law, App features, external services, or other relevant circumstances.

The updated Policy becomes effective when it is posted in the App or on our website.

Where a change materially affects user rights or the handling of information, we will provide notice through the App, by email, or through another appropriate method.

Where applicable law requires user consent for a change, we will obtain separate consent.

15. Contact Us

For questions, requests, or complaints regarding this Policy, our handling of personal information, or user rights, please contact us using the information below.

Business name: Blue Lion
Service name: Cloud Pass
Location: Republic of Korea
Email: support@cloudpass.pro
Website: https://cloudpass.pro

16. Governing Law

This Policy is governed by and interpreted in accordance with the laws of the Republic of Korea, without regard to conflict-of-law principles.

However, this provision does not exclude the application of mandatory privacy or consumer protection laws in the user’s country or region of residence.