Effective Date: September 19, 2026

This Privacy Policy applies to the CISM Study Prep 2026 mobile application and related functionality provided by Carlos Andres Ayala Perdomo, referred to in this policy as the “Service Provider.”

The Service Provider respects your privacy and is committed to providing a study experience that minimizes the collection and processing of personal information.

Information Collection and Use

CISM Study Prep 2026 does not require users to create an account, register, or provide personal information in order to use the Application.

The current version of the Application does not directly collect or transmit personal information to servers operated by the Service Provider.

Study-related information is stored locally on the user's device. This may include:

• selected language and application preferences;
• answers to practice questions;
• study progress;
• test results and test history;
• locally stored Premium entitlement information required for application functionality.

This information remains on the user's device unless it is processed by Apple as part of an App Store purchase or subscription transaction.

The Service Provider does not operate a cloud database containing users' study answers, test results, or study history.

Accounts and Registration

The Application does not require a user account.

Users are not required to provide their name, email address, password, profile information, or other identifying information to access the study functionality.

Premium Subscription and Apple StoreKit

CISM Study Prep 2026 offers an optional auto-renewable subscription called CISM Premium Monthly.

Subscriptions and payments are processed through Apple's App Store and StoreKit services.

The Service Provider does not directly collect, process, transmit, or store:

• credit card numbers;
• debit card numbers;
• Apple Account passwords;
• CVV/security codes;
• bank account information; or
• other payment credentials.

Apple may process information relating to purchases, subscriptions, devices, and Apple Accounts according to Apple's own privacy practices.

The Application may communicate with Apple's StoreKit services to retrieve subscription product information, localized prices and currencies, purchase status, and subscription entitlement information.

For additional information regarding Apple's privacy practices, please visit:

Apple Privacy Policy:
https://www.apple.com/legal/privacy/

Tracking, Advertising, Cookies, and Analytics

The current version of CISM Study Prep 2026 does not use third-party advertising networks or cross-app tracking technologies.

The Application does not use advertising cookies, tracking pixels, or similar technologies for behavioral advertising.

The Service Provider does not sell personal information or use personal information for targeted advertising.

If analytics, advertising, cloud synchronization, or other data-processing services are introduced in a future version, this Privacy Policy will be updated accordingly.

Local Storage

Study progress, answers, language preferences, test history, and similar application information may be stored locally on the user's device.

Local information can generally be removed by using available reset or history-clearing functionality within the Application, where provided, or by uninstalling the Application.

Uninstalling the Application removes locally stored application information according to the normal behavior of iOS.

Purchase and subscription records maintained by Apple are governed separately by Apple's policies and cannot be deleted by the Application.

Third-Party Services

The Application relies on certain services provided by Apple to distribute the Application and provide optional subscription functionality, including the Apple App Store and StoreKit.

These services may independently process information according to their own terms and privacy policies.

The Service Provider does not receive users' complete payment information from Apple.

External legal or informational links opened from the Application may be displayed using Apple's operating system or web browser functionality. Once a user leaves the Application, the privacy practices of the destination website apply.

Data Sharing

The Service Provider does not sell or rent personal information.

Because the current version of the Application does not operate a developer-controlled user database containing study activity or user profiles, study progress and practice answers are not routinely disclosed to third parties by the Service Provider.

Information may be disclosed if required by applicable law, court order, or lawful governmental request.

European Union and GDPR

The Service Provider recognizes the privacy rights established by the General Data Protection Regulation (GDPR) and other applicable European privacy laws.

Because the current version of the Application does not require registration and does not maintain a developer-controlled database containing users' study activity, the amount of personal information processed directly by the Service Provider is limited.

Where the Service Provider processes personal information—for example, if a user voluntarily contacts the Service Provider by email—the user may have rights under applicable law, including rights of access, correction, deletion, restriction, objection, and, where applicable, data portability.

Users may also have the right to lodge a complaint with their applicable data protection authority.

More information about European Union data protection rights is available from the European Commission:

European Union Data Protection:
https://commission.europa.eu/law/law-topic/data-protection_en

California Privacy Rights

California residents may have rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

The Service Provider does not sell users' personal information and does not share personal information for cross-context behavioral advertising.

Where applicable, California residents may request information regarding personal data held by the Service Provider or request correction or deletion of such information.

Requests may be submitted using the contact information provided below.

International Data Transfers

The Application does not routinely transfer users' locally stored study progress or practice answers to servers operated by the Service Provider.

Apple services used for subscriptions, application distribution, and related functionality may process information in different countries in accordance with Apple's privacy policies and applicable legal safeguards.

If the Service Provider introduces cloud-based functionality involving international transfers in the future, this Privacy Policy will be updated to describe those practices and applicable safeguards.

Data Retention

Study progress and related information stored locally on the device remain available until they are cleared through the Application, removed by the operating system, or the Application is uninstalled.

The Service Provider does not maintain a central server containing users' study answers or test history in the current version of the Application.

If a user voluntarily contacts the Service Provider by email, correspondence may be retained only as reasonably necessary to respond to the request, maintain appropriate records, resolve disputes, comply with legal obligations, or protect legitimate interests.

Subscription and purchase records maintained by Apple are subject to Apple's retention policies.

Your Privacy Rights

Depending on your jurisdiction, you may have rights regarding personal information that the Service Provider actually controls, including access, correction, deletion, restriction of processing, objection to processing, or other rights provided by applicable privacy law.

To exercise an applicable privacy right, contact:

cayalaperdomo@gmail.com

The Service Provider may need sufficient information to verify and respond to a legitimate privacy request.

Children

CISM Study Prep 2026 is designed as a professional certification study application and is not directed toward children under 13 years of age, or any higher minimum age established by applicable local law.

The Service Provider does not knowingly collect personal information from children through the Application.

If a parent or legal guardian believes that a child has provided personal information directly to the Service Provider, they may contact the Service Provider so that appropriate action can be taken.

Security

The Service Provider takes reasonable measures to protect information under its control.

Because study information is primarily stored locally on the user's device, protection of that information also depends on the security features provided by the user's device and operating system.

Users are encouraged to maintain appropriate device security protections, such as a device passcode and current operating system updates.

No method of electronic storage or transmission can be guaranteed to be completely secure.

Data Breach Notification

If the Service Provider becomes aware of a security incident involving personal information under the Service Provider's control, affected users and/or applicable authorities will be notified when required by applicable law.

Changes to This Privacy Policy

The Service Provider may update this Privacy Policy to reflect changes in the Application, legal requirements, Apple platform functionality, or privacy practices.

The effective date shown at the top of this policy will be updated when material changes are made.

Where required by applicable law, additional notice or consent will be provided before material changes take effect.

Your Choices

Use of Premium functionality is optional.

Users may use the free portion of the Application without purchasing a subscription.

Users may manage or cancel an Apple subscription through their Apple Account according to Apple's subscription management procedures.

Users may stop using the Application at any time and may remove locally stored Application information by uninstalling the Application.

Terms of Use

CISM Study Prep 2026 uses Apple's Standard End User License Agreement where applicable.

Apple Standard Terms of Use (EULA):
https://www.apple.com/legal/internet-services/itunes/dev/stdeula/

Independent Educational Application

CISM Study Prep 2026 is an independent educational study tool.

The Application is not affiliated with, endorsed by, sponsored by, or officially associated with ISACA.

Any third-party names, certification names, trademarks, or referenced materials remain the property of their respective owners.

Contact Us

If you have questions about this Privacy Policy, the Application's privacy practices, or wish to exercise an applicable privacy right, please contact:

Carlos Andres Ayala Perdomo
Email: cayalaperdomo@gmail.com