Privacy Policy

FirstHandIB is operated by:

RevAce
Waldstr. 26B
85598 Baldham
Germany

Email: lynette@firsthandib.com

For questions about your personal data or this Privacy Policy, you can contact us at the email address above.

FirstHandIB is currently being developed and tested through an Free Preview.

Participation in the Free Preview is currently limited to users aged 16 or older.

Free Preview testers are not required to provide their real name or personal email address. Instead, FirstHandIB generates a tester ID and internal account information.

This allows us to understand how individual testers use FirstHandIB without requiring their name or personal email.

Your activity is therefore pseudonymous rather than completely anonymous because activity can still be associated with your generated tester account.

Please do not enter your name, contact information or other unnecessary personal information into feedback, surveys, notes or other free-text fields.

When an account is created, we may process information including:

• your account identifier
• your generated tester ID, where applicable
• your email address for normal accounts or an internally generated email address for Free Preview accounts
• your password in hashed form
• account creation information
• login information
• authentication and session information
• your acceptance of applicable Terms and privacy choices
• confirmation that you meet the minimum age requirement

Normal FirstHandIB accounts may also contain optional profile information such as a display name, school, year group or profile image.

We use this information to create and secure accounts, authenticate users and provide FirstHandIB.

If you enter a teacher's personal class code during sign-up, your account is linked to that teacher's class. While your analytics consent is active, that teacher can see class-level lesson completion and question-result summaries, not your tester ID, email, notes, or individual answers. Question summaries require at least three contributing students. You can stop contributing by withdrawing analytics consent in Settings. School-wide access codes do not automatically link you to an individual teacher.

When you use FirstHandIB, we may record information about how you learn and interact with educational content.

This may include:

• lessons and topics opened
• lesson progress and completion
• content viewed
• written lesson sections viewed
• questions attempted
• answers submitted
• whether answers are correct or incorrect
• retries and answer changes
• hints or explanations requested
• diagnostic quiz results
• content skipped
• navigation between activities
• video interactions
• notes and reflections
• flashcards
• other saved learning activity

We use this information to provide the learning experience, save your progress and improve FirstHandIB.

During the Free Preview, we want to understand how students actually use FirstHandIB so that we can identify what works well, what causes confusion and what should be improved.

If you consent to Free Preview analytics, FirstHandIB may therefore record interactions such as:

• sessions and page views
• lessons opened and completed
• content viewed
• navigation through lessons
• videos opened, started, paused, resumed and completed
• video progress
• questions viewed and attempted
• answers and whether they are correct or incorrect
• retries and answer changes
• hints and explanations opened
• remediation content viewed or skipped
• content skipped
• jumping directly to questions
• progress resets
• feedback interactions
• survey interactions
• approximate time spent on components
• device category, such as mobile, tablet or desktop

This information is connected to a generated tester or user identifier and session identifier. This allows us to understand a tester's journey through FirstHandIB without requiring their real name or personal email address.

We use this information to evaluate, test and improve FirstHandIB.

For Free Preview analytics collected on the basis of your consent, the legal basis is Article 6(1)(a) GDPR.

You may withdraw your consent for future Free Preview analytics at any time. Withdrawal does not affect the lawfulness of processing that took place before consent was withdrawn.

FirstHandIB does not currently use third-party advertising or behavioural analytics services such as Google Analytics, Meta Pixel, TikTok Pixel, Hotjar, Microsoft Clarity, PostHog, Mixpanel or Amplitude.

You may provide feedback, report bugs or complete surveys about your experience with FirstHandIB.

Depending on the feature, we may process:

• your feedback or survey answers
• ratings and categories you select
• the lesson or content you were viewing
• your generated tester or user identifier
• relevant session information
• the time of submission
• contextual information necessary to understand your feedback

Some questions allow free-text responses.

Please avoid including unnecessary personal information about yourself or another person in these responses.

We use feedback and survey responses to evaluate the Free Preview, identify problems and improve FirstHandIB.

Some FirstHandIB features may allow users to create or save content such as:

• notes
• reflections
• drawings
• flashcards
• written answers
• tutor messages

If you choose to use these features, the information you provide may be stored with your account.

When you access FirstHandIB, our hosting, authentication and infrastructure providers may automatically process technical information such as:

• IP address
• browser and device information
• timestamps
• requested pages or URLs
• authentication events
• request information
• technical and security logs

This processing is used for purposes such as operating the website, authentication, security, preventing misuse and troubleshooting.

FirstHandIB does not intentionally use IP addresses to identify Free Preview testers or display IP addresses in the FirstHandIB Student WALK analytics dashboard.

FirstHandIB uses browser storage to provide and remember platform functionality.

This may include local storage for:

• authentication sessions
• generated Free Preview identifiers
• analytics sessions
• lesson progress
• lesson state
• answers
• interface preferences
• Free Preview settings

FirstHandIB also currently uses limited first-party browser storage or cookies for functional purposes, such as remembering interface preferences.

Some third-party embedded services may use their own browser storage or cookies.

Some FirstHandIB lessons contain videos embedded from YouTube.

When a page containing an embedded YouTube video is loaded or you interact with the video, information such as your IP address, browser information and viewing activity may be transmitted to Google/YouTube.

YouTube may use cookies or other browser storage according to Google's applicable privacy practices.

We are reviewing how embedded videos are implemented as FirstHandIB develops in order to minimise unnecessary data transmission where reasonably possible.

FirstHandIB uses third-party service providers to operate the platform.

Depending on the feature you use, these may include:

These providers may receive information necessary to provide their respective services.

Some providers may process information outside Germany or the European Economic Area. Where required by applicable data protection law, appropriate safeguards must be used for international transfers.

FirstHandIB does not currently use personal data for behavioural advertising.

The current platform does not contain advertising trackers such as:

• Meta Pixel
• TikTok Pixel
• Google Ads conversion tracking

and does not use third-party behavioural analytics platforms such as Google Analytics, Hotjar, Microsoft Clarity, PostHog, Mixpanel or Amplitude.

The current FirstHandIB Free Preview is only available to users aged 16 or older.

You will be asked to confirm that you are at least 16 before participating.

If you are under 16, you should not participate in the current Free Preview.

We do not ask Free Preview testers to provide their date of birth.

Under the GDPR, personal data must be processed on an appropriate legal basis.

Depending on the processing activity, FirstHandIB may process information because:

• you have given consent, under Article 6(1)(a) GDPR
• processing is necessary to provide a service you have requested, under Article 6(1)(b) GDPR
• processing is necessary for our legitimate interests in operating, securing and improving FirstHandIB, under Article 6(1)(f) GDPR
• processing is necessary to comply with a legal obligation, under Article 6(1)(c) GDPR

For Free Preview WALK and usage analytics for which we request your explicit consent, we rely on Article 6(1)(a) GDPR.

Where processing is based on consent, you may withdraw that consent at any time with effect for the future.

When a student uses "Ask a parent to pay", we send one email to the parent or guardian address they enter, so that the parent can learn about FirstHandIB and pay on the student's behalf. We store only the student's first name, the parent's email address, the chosen package, the optional note, a random link code, timestamps and the request status (sent, page opened, paid or unwanted). If the student is signed in, the request is linked to their account so a purchase can unlock it. This is based on our legitimate interest in handling the student's request (Article 6(1)(f) GDPR).

Requests without a purchase are deleted automatically 30 days after sending. Parent email addresses from these requests are never used for marketing unless that parent signs up for tips themselves (see section 14c). A parent can object at any time with the "Let us know" link in the email, which marks the request as unwanted and blocks further requests to that address, or by emailing lynette@firsthandib.com.

Service emails (students and parents). We send emails needed to provide the service: account emails (confirmation, password reset), purchase receipts and access, IA feedback, access reminders (for example that an exam is two weeks away) and, for buyers of the November 2026 Review: Last Minute package, one request to review the course after the exam. Legal basis: performance of a contract (Article 6(1)(b) GDPR). When a student buys a paid package we require an email address on the account for delivery, IA feedback and account recovery. Free use can remain username and code based.

No marketing to students. We never send marketing emails to student accounts.

Tips for parents (consent). Parents can ask for occasional exam-season tips and FirstHandIB news (at most 2 emails a month) by ticking an unticked box on our parents page or at parent checkout. We then send a confirmation email and only add the address after the parent clicks the confirm button (double opt-in). To prove consent we store the email address, the time of the request and of the confirmation, the page it came from, the exact checkbox wording and its version, and a one-way hash of the IP address used to request and confirm. Legal basis: consent (Article 6(1)(a) GDPR).

Parents who bought (existing customers). When a parent pays for a package we may occasionally email them about similar FirstHandIB products. We tell them this at checkout, and they can object at any time, free of charge. Legal basis: our legitimate interest in direct marketing to existing customers (Article 6(1)(f) GDPR, with § 7(3) UWG).

Withdrawing consent or objecting. Every marketing email has an unsubscribe link that leads to your email settings page, where one click stops all marketing emails immediately. You can also write to lynette@firsthandib.com. Withdrawal does not affect emails about a purchase you made.

Retention. Unconfirmed signups are deleted after 30 days. Confirmed contacts are kept while you are subscribed. After you unsubscribe or object, we keep only the email address, the consent record and the date of unsubscribing, so that we can respect your choice and prove our compliance, for up to 3 years. We use our email delivery provider to send these emails.

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected and where necessary to meet legal obligations.

During the Free Preview, pseudonymous learning, analytics, feedback and survey information may be retained for the period necessary to evaluate the preview, analyse student learning journeys and improve FirstHandIB.

Different retention periods may apply to:

• account information
• learning records
• Free Preview analytics
• feedback and surveys
• communications
• technical and security logs
• information that must be retained for legal or accounting purposes

Infrastructure providers may also maintain technical logs according to their own applicable retention periods.

As FirstHandIB develops, we are implementing improved tools for deleting tester-associated information and managing retention.

Under the GDPR, you may have rights concerning your personal data, including the right to:

• request information about how your personal data is processed
• request access to your personal data
• request correction of inaccurate data
• request deletion of your personal data
• request restriction of processing
• object to certain processing
• request data portability where applicable
• withdraw consent where processing is based on consent

If you are an Free Preview tester, providing your generated tester ID can help us locate your records without requiring you to provide your name or personal email address.

To exercise your rights, contact:

lynette@firsthandib.com

You also have the right to lodge a complaint with a competent data protection supervisory authority.

We use technical and organisational measures intended to protect information processed through FirstHandIB.

These include authentication, access controls and private storage for relevant user information and files.

However, no online system can guarantee absolute security.

FirstHandIB is currently under active development.

Features and data processing activities may therefore change as the platform develops.

We will update this Privacy Policy when relevant processing activities change. The current version and date will remain available through FirstHandIB.

For questions about this Privacy Policy or the processing of your personal data, contact:

FirstHandIB
operated by RevAce
Waldstr. 26B
85598 Baldham
Germany

Email: lynette@firsthandib.com