1. Introduction

Welcome to SkillPass.

SkillPass is an AI-powered driving test preparation platform operated by Future Data Ltd, a company incorporated in England and Wales (Company No. 16728072), registered office at 27 OLD GLOUCESTER ST LONDON UNITED KINGDOM WC1N 3AX, United Kingdom.

SkillPass is a digital platform designed exclusively to help users prepare for the Italian driving licence (patente) theory examination. Our features include multilingual lessons, AI-assisted practice, progress tracking, and community learning.

SkillPass is an independent educational platform. It is not affiliated with, endorsed by, or officially connected to the Italian Ministry of Infrastructure and Transport or any governmental authority, unless explicitly stated.

We are committed to handling your personal data transparently, lawfully, and securely. This Privacy Policy explains what we collect, why we collect it, how we use it, and your rights.

2. Applicable Law

Because SkillPass is operated from the UK and primarily serves users in Italy and the EEA, our data processing is governed by:

• EU GDPR (Regulation 2016/679) — applies because we target users in Italy and the European Economic Area.
• UK GDPR — applies because Future Data Ltd is established in the United Kingdom.
• Italian Privacy Code (D.Lgs. 196/2003, as amended by D.Lgs. 101/2018) — applies because we actively serve Italian users. Italy’s national implementation adds obligations beyond the base GDPR text.

We also observe binding guidance issued by the Garante per la protezione dei dati personali (Italian DPA), including its 2021 Cookie Guidelines.

UK–EU Data Transfers: Transfers of personal data from the EEA to Future Data Ltd in the UK are made on the basis of the European Commission’s adequacy decision for the UK (adopted June 2021). We monitor the status of this decision and will implement alternative safeguards if required.

Where Italian or EU law grants users greater protections than UK GDPR, those greater protections apply to our Italian users.

3. Data Controller

The data controller responsible for your personal data is:

Future Data Ltd
27 OLD GLOUCESTER ST LONDON UNITED KINGDOM WC1N 3AX

Email: hello@skillpassplatform.com

Website: https://skillpassplatform.com/

4. Information We Collect

4.1 Personal Information

Information you provide directly when registering or using the platform includes:

• Full name
• Email address
• Account login credentials
• Language preferences
• Country / Region
• Age confirmation (to verify you meet the minimum age requirement of 13)

4.2 Learning & Usage Data

To deliver personalised practice and track your progress within the patente preparation scope, we collect:

• Test progress and performance scores
• Quiz answers and results
• Practice session activity
• Study patterns and engagement within the platform
• Saved lessons and bookmarked content

4.3 Device & Technical Data

We automatically collect the following technical data to ensure the platform functions correctly on your device, diagnose issues, and deliver a consistent, personalised experience tailored to your setup:

• Device type, operating system, and browser type
• IP address and approximate location (country/region level)
• App version and usage logs

We use this data to:

• Ensure the platform loads and works correctly across different devices and browsers.
• Identify and resolve technical issues or performance gaps that affect your experience.
• Understand how users interact with the platform, including pain points and drop-off moments, so we can continuously improve.
• Personalise the interface based on your device setup (for example, mobile versus desktop layouts).
• Prioritise development based on real usage patterns.

4.4 Community Interactions

If you use community features, we collect messages and content you choose to share within the platform.

4.5 Payment Data

Payment information is processed directly by our third-party payment processor. We do not store full payment card details on our systems.

5. How We Use Your Information

5.1 Core Services — Account creation and management, delivering multilingual lessons, and tracking your learning progress.

5.2 Personalisation — Adapting practice question difficulty and content recommendations based on your performance within the patente preparation scope.

5.3 App Performance & Experience — Using device and technical data to ensure the platform works well on your device, fix issues, and improve the overall user experience.

5.4 Platform Improvement — Analysing aggregated, anonymised usage trends to enhance features and improve the platform for all users.

5.5 Communication — Sending service-related notifications, responding to your enquiries, and sharing updates about new features. You may opt out of non-essential marketing communications at any time.

5.6 Legal Compliance — Meeting our obligations under applicable UK, EU, and Italian law.

We do not sell your personal data to third parties.

6. Our AI Engine

SkillPass uses a purpose-built AI model trained exclusively on Italian driving licence (patente) examination content.

The AI operates solely within the patente preparation scope and does not process, respond to, or retain queries outside of this domain.

Your learning data is used only to adapt practice content difficulty and relevance within the platform.

The AI does not make significant automated decisions about you as a person. It adjusts educational content within a fixed subject domain only.

Because the AI is self-contained within our platform, your learning data is not sent to any external AI provider or third-party language model.

This means the heavier automated decision-making obligations under Article 22 of the GDPR do not apply to our AI engine, as it does not produce decisions with significant effects on users beyond their in-platform learning experience.

7. Legal Basis for Processing

We process your personal data on the following legal bases under the EU GDPR and UK GDPR:

• Contract (Art. 6(1)(b)) — Providing your account and core platform features, including access to lessons, quizzes, community features, and learning progress tracking.
• Legitimate Interests (Art. 6(1)(f)) — Improving platform security, preventing fraud, maintaining platform performance, and analysing usage trends to improve the Service. You have the right to object to processing based on legitimate interests (see Section 10).
• Consent (Art. 6(1)(a)) — Sending marketing communications and using non-essential cookies or similar technologies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Legal Obligation (Art. 6(1)(c)) — Complying with applicable laws, regulations, court orders, tax requirements, and other legal obligations.

8. Data Sharing

8.1 Service Providers

We share data only with trusted third-party service providers who are contractually obligated to protect your data and process it only on our instructions.

These service providers may include:

• Hosting and cloud infrastructure providers
• Analytics services (using aggregated and anonymised data where possible)
• Payment processors
• Authentication providers
• Customer support tools

We do not currently share learning data with external AI providers. If this changes in the future, we will update this Privacy Policy and implement appropriate safeguards as required by applicable law.

8.2 Legal Requirements

We may disclose personal data where required by law, regulation, court order, legal process, or where necessary to protect our legal rights, users, or the security of the platform.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy and to comply with applicable legal obligations.

Our retention periods are generally as follows:

• Account Data (name, email, credentials): Duration of your account plus up to 12 months after deletion to meet legal obligations.
• Learning and Performance Data: Up to 3 years from your last active login unless you request earlier deletion.
• Community Content: Until you delete the content or request account deletion.
• Device and Technical Data: Up to 12 months.
• Financial and Payment Records: Up to 7 years as required by applicable tax and accounting laws.

You may request account and personal data deletion at any time by contacting us at hello@skillpassplatform.com.

10. Your Rights

Under the EU GDPR, UK GDPR, and the Italian Privacy Code, you have the following rights:

• Access (Art. 15) — Request a copy of the personal data we hold about you.
• Rectification (Art. 16) — Request correction of inaccurate or incomplete personal data.
• Erasure (Art. 17) — Request deletion of your personal data (“Right to be Forgotten”).
• Restriction of Processing (Art. 18) — Request that we limit how we process your personal data.
• Data Portability (Art. 20) — Receive your personal data in a structured, commonly used, and machine-readable format.
• Object (Art. 21) — Object to processing based on legitimate interests or direct marketing.
• Withdraw Consent — Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us at hello@skillpassplatform.com.

We will respond within one month of receiving your request. For complex requests, this period may be extended by up to two additional months, and we will notify you accordingly.

Right to Lodge a Complaint

If you believe your personal data has not been handled lawfully, you have the right to lodge a complaint with the relevant supervisory authority.

• Italian Users: Garante per la protezione dei dati personali — www.garanteprivacy.it
• UK Residents: Information Commissioner’s Office (ICO) — www.ico.org.uk

11. Data Security

We implement appropriate technical and organisational measures designed to protect your personal data from unauthorised access, disclosure, alteration, or destruction.

These measures include:

• Encrypted data transmission using SSL/TLS technologies.
• Access controls and role-based permissions.
• Regular security monitoring and system maintenance.
• Data minimisation practices and restricted access to personal information.

While we take reasonable measures to protect your data, no system can be guaranteed to be completely secure.

In the event of a personal data breach that is likely to affect your rights and freedoms, we will notify affected users and the relevant supervisory authorities as required by applicable law.

12. Children’s Privacy

SkillPass is designed for users aged 13 and over, reflecting the minimum driving age requirements in Italy.

Age confirmation is required during registration.

We do not knowingly collect personal data from individuals under the age of 13.

If you believe that a minor has registered for SkillPass or provided personal information to us, please contact us at hello@skillpassplatform.com and we will take appropriate action, including removal of the account and associated data where required.

13. Cookies & Tracking Technologies

We use cookies and similar technologies for authentication, platform functionality, security, user preferences, and analytics.

For detailed information about the cookies we use, the purposes for which they are used, your consent choices, and how to manage your preferences, please review our Cookie Policy.

Cookie Policy: https://skillpassplatform.com/cookie-policy/

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, business practices, legal requirements, or regulatory obligations.

Where material changes are made, we will provide notice through the platform, by email, or by other appropriate means at least 30 days before the changes become effective.

The “Last Updated” date displayed on this page indicates when this Privacy Policy was most recently revised.

Your continued use of SkillPass after any changes become effective constitutes acceptance of the updated Privacy Policy, unless applicable law requires a different form of consent.

15. Contact Us

If you have any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact us:

SkillPass
27 OLD GLOUCESTER ST LONDON UNITED KINGDOM WC1N 3AX

Email: hello@skillpassplatform.com

Website: https://skillpassplatform.com/