Privacy Policy

1. Who we are

Pasaa is a product of Codurion, registered with the Dutch Chamber of Commerce (KVK) under number 97713457. Our address is Zonstraat 59, Hengelo (OV), the Netherlands. Contact us at info@codurion.nl.

2. Data we collect

We collect the following personal data:

• Email address and name — at registration
• Learning progress — completed lessons, FSRS card data, review schedules
• Payment data — processed by Stripe; we do not store card details
• Usage data — page views, session duration (via our own analytics system, without cookies)

3. Legal basis

We process your data on the following legal bases (GDPR art. 6):

• Performance of a contract — to provide the app and process payments
• Legitimate interest — to improve the app and prevent abuse
• Legitimate interest — for anonymised analytics (no cookies, no personal data)

4. Data processors

We use the following sub-processors:

• Supabase (database and authentication)
• Stripe (payments)
• Own analytics — We use a self-built analytics system that does not place cookies. Visitor data is anonymized using a daily rotating hash and cannot be traced back to individuals. For logged-in users, activity is linked to your account to improve the learning experience.

We have data processing agreements in place with all processors as required by GDPR.

5. Retention periods

• Account data — retained while you have an account; deleted within 30 days of account removal
• Payment data — 7 years as required by Dutch tax law
• Analytics data — 90 days (raw data), aggregated data kept indefinitely

6. Your rights

Under GDPR you have the right of access, rectification, erasure, restriction, data portability, and the right to object. Send requests to info@codurion.nl. You may also lodge a complaint with the Dutch Data Protection Authority.

7. Cookies

For an overview of all cookies we use, see our cookie statement.

8. Contact

Questions? Contact us at info@codurion.nl.