Privacy

Privacy Policy

Last updated: 4 October 2026

1. Who we are

R0 Pass ("we", "us", "the app") is an independent revision app for the CII Diploma in Regulated Financial Planning (units R01–R06). This policy explains what happens to your information when you use the app, in line with the UK GDPR and the Data Protection Act 2018.

For anything you email us and for handling your requests, the data controller is the publisher of R0 Pass. You can reach us at support@r0pass.com.

2. Our approach: on-device storage

R0 Pass works without collecting your personal data. Everything you do in the app is stored only on your device, using your phone's standard local storage. That covers the questions you answer, your scores and history, your mistake bank and bookmarks, your settings, your exam date and any reminders. None of it is sent to us, and we have no account, profile or copy of it on any server.

Because we don't collect or have access to this information, we can't see your progress, and we can't identify you from using the app.

3. What is stored on your device

4. Backups you create yourself

The app lets you export a backup file of your on-device data and restore it later. This is entirely under your control: the backup is a plain file you save or share using your phone's own share sheet (for example to Files, iCloud Drive or another app you choose), and you re-import it with the document picker. We never receive this file. Where it goes after you export it is governed by whatever service you chose to save it to.

5. Payments

If you buy a unit or the bundle, the purchase is handled entirely by Apple's App Store using Apple's in-app purchase system. We never see or receive your card or payment details. The app only receives confirmation from Apple that a purchase completed, and records the purchase locally on your device. Apple's handling of your payment is covered by Apple's Privacy Policy.

6. What we don't do

• No user accounts, logins or profiles.
• No analytics, advertising or third-party tracking SDKs.
• No tracking in Apple's sense: we do not link your activity across other companies' apps or websites, and we do not share data with data brokers.
• No selling of personal data. Ever.

7. This website, and email to support

This website (r0pass.com, also served at r0pass.pages.dev) is a static site. It has no accounts and no sign-up forms. A pre-launch mailing-list form that used to live here was removed before launch, and we hold no email addresses from this site.

If you email us at support@r0pass.com, we use your email address and the content of your message to answer you. Our lawful basis is legitimate interests (UK GDPR Article 6(1)(f)): dealing with the request you sent us. We keep support correspondence for 12 months after the conversation ends, then delete it.

Cookies

This site sets no cookies and stores nothing in your browser: no localStorage, no sessionStorage. There are no analytics, no advertising and no tracking scripts, and the site makes no third-party requests; the one web font is served from this site itself. Cloudflare hosts the site and sets no cookies on it. That is why there is no cookie banner: there is nothing to consent to.

8. International transfers

Using the app involves no international transfer of personal data, because the app sends us nothing. This website is served from Cloudflare's global network, and support email passes through Cloudflare's email routing on its way to us, so a message you send may be processed outside the UK while in transit. Purchases are handled by Apple under Apple's own privacy terms. Where a transfer does happen, it relies on the safeguards in our providers' terms (standard contractual clauses or the UK International Data Transfer Addendum). For a copy of the relevant safeguards, email support@r0pass.com.

9. Retention

• On-device data: stays until you delete it. Clear it in Settings, or delete the app. We hold no copy.
• Support email: kept for 12 months after the conversation ends, then deleted.

10. Your rights

Under UK GDPR you have the right to be informed, and to access, rectify, erase, restrict or object to processing of your personal data, and to data portability. Because we hold no personal data about you on any server, most of these are exercised directly on your device: you can view, correct and delete everything from within the app, and export it yourself with the backup feature.

If you believe we hold personal data about you (support emails are the realistic case) and want to exercise a right, contact us at support@r0pass.com and we'll respond within one month.

You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint, helpline 0303 123 1113.

11. Children

R0 Pass is a professional revision tool aimed at adults studying for the CII financial planning exams. It is not directed at children and we do not knowingly collect data from children. We follow the principles of the ICO's Age Appropriate Design Code.

12. Changes to this policy

If we change how the app handles data, we'll update this page and the "last updated" date above. For material changes we'll also flag it in the app.