Law 25 — Québec

Privacy policy

Last updated: 27 August 2026
About this English version. Permis 101’s legal documents are written in French. This English text is provided so you can read them in your own language; if the two ever differ, the French version at permis101.com/confidentialite/ is the one that prevails.

The short version: your data stays with you.

Permis 101 is built to work without knowing anything about you: no account, no advertising, no profile. Your study progress lives on your device and, when iCloud is available, in your own iCloud — never on our servers. What we receive is limited to anonymous usage statistics, the question reports you choose to send, anti-fraud fingerprints when a purchase is verified (section 4), and the technical metadata every server receives. This page is the complete inventory, item by item.

1 · No account

The app never asks you to create an account: no email address, no password, no phone number, no profile. There is no user database on our side — nothing to breach, nothing to sell.

2 · What lives on your device

Everything the app knows about your studying stays local. Specifically, it keeps on your iPhone:

None of this is sent to our servers. Delete the app and the local data goes with it.

3 · iCloud sync

When your device is signed in to iCloud, syncing happens automatically: your practice log, your first name, your situation, your test date and your self-declared results are also copied into your own iCloud — the private space Apple provides you, which we cannot access. That is what lets you pick your progress back up on your other devices. This data never passes through our servers — we have none for your data. The app has no switch for this syncing: it follows your iPhone’s iCloud settings, and if iCloud isn’t available the app simply works locally.

Worth knowing: deleting the app erases the local data, but not the copies already in your iCloud — those stay in your Apple Account, under your control, and are reused if you reinstall the app. To get rid of them entirely, write to us (section 13) and we will tell you how.

4 · Purchase and proof of purchase

The full unlock is bought through the App Store: Apple handles the payment. We never receive your name, your address or your payment details. To deliver the complete question bank, the app presents our server with a proof of purchase signed by Apple. That proof contains no name, no address and no payment data; it contains a transaction number assigned by Apple — an identifier only Apple can connect to a person. Our server checks the signature and answers with an access token valid for about ten minutes. The transaction number itself is not kept, and there is no record on our side of who bought what.

To prevent and detect fraud — for example a proof of purchase copied and then published, which would let anyone download the question bank — the server does keep a minimal trace of each verification:

These fingerprints serve one purpose: spotting the abusive use of a single proof of purchase from an abnormal number of networks — fraud prevention and detection within the meaning of Law 25. They are deleted automatically at most 90 days after the last verification. Restoring a purchase also goes entirely through Apple.

5 · Anonymous statistics

To know which parts of the app are useful and to catch bugs, the app sends anonymous usage events. The complete list:

With the single exception of the system crash described above, the properties attached to these events are only numbers, yes/no values and closed choices — never the identifier of a question, never free text, never your first name, never your test date. These events are processed by PostHog, hosted in the European Union (Frankfurt, Germany). Concretely:

You can decline these statistics: in the app, open Settings and turn off “Share anonymous statistics”. The app then stops collecting anything at all — usage events as well as error and crash reports — and does not resume at the next launch. Your choice stays on your device; it is not reported to us.

One caveat, for the same technical reason as the last point above: if the app closes abruptly while statistics are turned off, PostHog’s native module may still write a crash report on your device — it is written beyond our reach and we cannot prevent it. Nothing leaves while statistics stay off; if you ever turn them back on, that report may be sent along with the others.

6 · Question reports

If you use “Report this question” in the app, we receive exactly three things: your comment (optional), the identifier of the question and the version of the content — nothing else, and no device or personal identifier is attached. The report is anonymous: do not write personal information into it. If you do anyway and want it removed, write to us (section 13). Reports are kept for as long as it takes to check and correct the question, then at most 24 months, before being deleted.

7 · Server metadata

Like any online service, our server (used only for proof of purchase, the question-bank download and question reports) sees the IP address of the requests it receives. It appears in temporary technical logs and is used to limit abuse (rate limiting); those traces are erased automatically within hours or days and are never connected to your studying — the server does not know who is studying what. The server is hosted with Fly.io (Toronto, Canada) and its database with Neon (United States); that database contains only question reports, temporary anti-abuse counters and the purchase-verification fingerprints described in section 4.

8 · This website

permis101.com is a static site: no cookies, no analytics scripts, no fonts loaded from a third party. The site is served by Cloudflare, our host, which handles the network requests needed to deliver the pages — as any web host does.

This site’s “App Store” links carry a campaign tag — the name of the page you leave from, written into the link’s address — which Apple counts in aggregate in the statistics it provides to developers. Nothing is stored on or read from your device, and we receive no individual data: only per-campaign totals, produced by Apple under its own privacy rules.

9 · Processors and providers

No other third party receives data. No data is sold, rented or shared for advertising purposes.

10 · Retention

11 · Your rights (Law 25 and GDPR)

Permis 101 aims at compliance with Law 25 (Québec) and the GDPR (the operator is established in Europe) in the simplest way there is: by holding almost no personal information. You have the right to request access to the information we hold about you, its correction or its deletion — in practice there is normally nothing to hand over, since your study data is with you. If you have a question, a request or a concern, write to us (section 13) and we will answer within thirty days. You can also contact the Commission d’accès à l’information du Québec.

12 · Privacy officer

The person responsible for the protection of personal information is Julien Courbebaisse, the operator (section 13), reachable at [email protected].

13 · Operator and contact

Permis 101 is developed and operated by Julien Courbebaisse, a self-employed operator (autónomo) registered in Spain (NIE: Y8924027H) — a postal address is provided on request. For any question about this policy or about your data: [email protected], or the Support page. The terms of use complete this policy.

14 · Changes

If this policy changes, the new version will be published here, with its update date. This policy is written in French. Where a translation is offered, it is provided for convenience: in case of any discrepancy, the French version prevails.