Mobile Applications & Website

Privacy Policy

Last Updated: March 2026 · Invictera LLC

Scope of this document. This Privacy Policy applies to Invictera's mobile applications and the invictera.com website. Advisory engagements with Invictera LLC are governed by separate written agreements that may include additional privacy terms.

1. Local-First Processing & Data Architecture

Invictera's mobile applications are engineered with a strict, privacy-first architecture. Our advanced learning algorithms—including the Knowledge Decay Engine and Bayesian Knowledge Tracing models—process your performance telemetry locally on your device.

We use Apple's CloudKit to securely sync your professional study progress (quiz scores, flashcard states, and mastery probabilities) across your devices.

Anonymous Identity: We link your iCloud User Record ID with RevenueCat to provide a seamless, account-free subscription experience.
Zero PII: We do not collect, request, or store your name, email address, physical location, or biometric data on our servers.
Local Storage: All synced study data stays within your personal iCloud account and is subject to Apple's enterprise security practices.

2. Third-Party Service Providers

We strictly limit our third-party integrations to the following essential partners:

Provider	Purpose	Data Shared
RevenueCat	Subscription status and entitlement management	Anonymous app-user identifier only
PostHog	Anonymous product telemetry, crash reports, and usage diagnostics (session length, feature usage)	No personally identifiable information
Apple	Secure payment processing and CloudKit data hosting	Governed by Apple's privacy policy

No Selling of Data. No data of any kind is sold, rented, or shared with third-party advertisers, data brokers, or marketing firms.

2A. Website Analytics (invictera.com)

When you visit invictera.com, including the Cross-Framework Mapping tool and other web-based resources, we collect anonymous usage analytics through PostHog. This data includes page views, session duration, feature interactions, and referring URLs. No personally identifiable information is collected, stored, or associated with your browsing session.

We do not use cookies for advertising or cross-site tracking. PostHog analytics are self-hosted and configured for anonymous, privacy-preserving telemetry only. No data is shared with third-party advertisers or data brokers.

The interactive tools on invictera.com (including the Cross-Framework Mapping) process all interactions client-side in your browser. No regulatory assessments, search queries, or framework selections are transmitted to or stored on our servers.

3. Your Rights & Data Control

You have complete control over your data:

Deletion: Permanently delete your data at any time by clearing your iCloud storage for the app or by deleting the app itself.
Resetting Progress: Resetting progress within the app clears your local device cache. To completely purge data from the cloud, navigate to Settings → [Your Name] → iCloud → Manage Account Storage.
Subscriptions: For billing inquiries, cancellations, or refunds, contact Apple Support directly. All financial transactions are handled exclusively by the App Store. Invictera LLC does not have access to or control over App Store transactions.

4. GDPR, CCPA & Applicable Rights

Given our zero-PII architecture, most data subject rights requests will confirm that Invictera LLC holds no personally identifiable information about you. However, if you wish to submit a formal data request under GDPR, CCPA, or other applicable privacy law, please contact us at hello@invictera.com. We will respond within the timeframe required by applicable law.

5. Children's Privacy

Our applications are rated 4+ on the Apple App Store and are accessible to users of all ages. However, they are designed for professionals preparing for advanced certifications and licensure examinations and are not intended for use by children. Because our architecture collects zero personally identifiable information (PII), no personal data of any user — regardless of age — is collected or stored on our servers. All study data remains within the user's private Apple iCloud account.

6. Relationship to Apple's EULA

This Privacy Policy is intended to complement and augment Apple's standard End User License Agreement (EULA). In the event of any conflict between this Privacy Policy and Apple's EULA with respect to usage of our applications on Apple devices, Apple's EULA shall govern matters relating to the App Store, in-app purchases, and platform-level terms.

Apple Inc. is a third-party beneficiary of Invictera's Terms of Service as they apply to iOS applications, and Apple has the right to enforce those terms against you as a third-party beneficiary. This Privacy Policy addresses data practices specific to Invictera LLC and supplements — but does not replace — Apple's own privacy framework.

Apple's Privacy Policy is available at apple.com/legal/privacy.

7. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected in the "Last Updated" date above. Continued use of our applications following any update constitutes acceptance of the revised policy.

8. Contact

For formal privacy inquiries, GDPR/CCPA data requests, or legal compliance questions regarding Invictera LLC:
hello@invictera.com

For all subscription cancellations, refunds, or billing inquiries, contact Apple Support directly via your Apple ID.