Privacy policy
Data controller: SayPeter SARL-S, 9, rue Raymond Poincaré, L-2342 Luxembourg, RCS B313377 Luxembourg. Contact: support@drillfolio.com.
What we process and why
- Purchase and access (performance of the contract): your email address, the amount and currency, the payment date, the country used to set the currency, the Stripe session reference, your consent to immediate access with its time and version, and the end date of your access; your sign-in links and 6-digit codes, stored only as hashes; the access cookie
cfa_sessionand, while a checkout is open,cfa_checkout. - Practice, mocks and study tools (performance of the contract): your answers, scores and timings, your flashcard reviews, the exam date and weekly hours you enter for your study plan, and which study guides, audio and video lessons you opened, used to show your progress by topic and LOS and to schedule your reviews.
- Free diagnostic (your request): your answers and score, kept with an anonymous result reference. When you ask for your breakdown by email we keep your address, your result and the topics where you can gain the most, and send you your breakdown and two practice emails over the next two days; if you open a checkout and leave before paying, we may send you one reminder. A purchase stops these emails and every one has a one-click unsubscribe link. The cookie
df_detaillets this browser show your breakdown. - News and offers (consent): only if you tick the box, the date of that consent. You can withdraw it at any time.
- Security (legitimate interest): counters of sign-in requests linked to a hash of your IP address and email address, and hosting logs.
How long we keep it
- Purchase data: for your 12 months of access, then 10 years for accounting obligations.
- Sign-in links: 7 days; codes: 24 hours; the access cookie: 30 days.
- Diagnostic emails: your address and result until you ask us to delete them; an unsubscribe is kept so that we never write to you again.
- Security counters: one hour.
Who receives it
- Stripe: payment processing.
- Amazon Web Services (Amazon SES, Frankfurt region): sending emails.
- Cloudflare: hosting of the site, its database and the study materials.
- Meta Platforms Ireland Ltd.: advertising measurement, only after «Accept all».
Some of these providers may process data outside the European Economic Area under the European Commission's standard contractual clauses.
Your rights
You can ask for access, correction, deletion, restriction, portability or object to processing by writing to support@drillfolio.com. You can also complain to the Commission nationale pour la protection des données (CNPD), Luxembourg, or to the authority of your country.
Cookies
On your first visit a banner asks for your choice; it is kept for 12 months in the cookie df_consent and you can change it at any time with «Cookie settings» at the bottom of every page.
- Always set, needed for the service:
df_consent(your choice),cfa_session(your sign-in, 30 days),cfa_checkout(an open checkout, 1 hour) anddf_detail(your diagnostic breakdown on this browser). - Only with «Accept all»:
df_ft, a first-party cookie kept for 12 months with the page where your visit began, the referring site's domain, the campaign tags of the link (utm parameters, gclid, gbraid, fbclid) and the time; it travels with a purchase so we know which advertising works. With «Accept all» Drillfolio also loads the Meta pixel (Meta Platforms Ireland Ltd.) to measure visits and purchases from our Facebook and Instagram ads.
«Only necessary cookies» sets none of these measurement cookies and deletes df_ft. Without any cookie we count page visits and banner answers per day as totals, with no identifier.
The language suggestion is remembered only in your browser (localStorage df_lang_hint), never on our server.
After Accept all, Meta also receives checkout, lead and confirmed purchase events through its Conversions API, with your IP address, browser information, _fbp and _fbc cookies and a hashed email address when available. These events are sent only with consent; Cookie settings lets you withdraw it and clears the measurement cookies.