Making the PHV Prep UK Privacy Policy Match What the App Actually Does
A privacy policy is a description of a system. Like any description, it can drift away from the thing it describes. Before submitting version 1.7.3 of PHV Prep UK, I read the privacy policy line by line against what the app actually does, and found two statements that were not true.
Neither was hiding anything. Both described more than the app does, not less. But a privacy policy that is wrong in a reassuring direction is still wrong, and the people reading it are deciding whether to trust the app with their data.
What was wrong
A consent mechanism that didn’t exist. The policy listed consent as a legal basis “for certain analytics” and said you could withdraw it at any time. The app had no consent banner, no settings screen and no switch for analytics. There was nothing to withdraw.
Crash data the app never collected. The policy said Firebase Analytics collected “diagnostic or crash data” to help find and fix problems. The app does not include Crashlytics or any other crash-reporting or performance SDK.
What the app actually does
From version 1.7.3, this is the full picture of analytics in PHV Prep UK:
- Firebase Analytics records the events the SDK collects automatically (such as first open, session start and engagement time) and three of my own: when the premium screen is viewed, when a purchase is completed and when a free-tier limit is reached. Each carries the council you selected and where in the app it happened.
- No identity is attached. The app does not set a user ID in Analytics, and no email address or account ID is sent with any event.
- No advertising ID. The app does not use the Android advertising ID, ad personalisation is turned off on both platforms, and the app does not ask for tracking permission on iOS.
- Firebase App Check verifies that requests to the backend come from the genuine app.
- No crash or performance reporting of any kind.
What changed on the page
The consent line is now a plain description of analytics: what is collected, why, the legal basis it relies on, and how to ask about this data or object to its use. The full details are in the privacy policy. The “diagnostic or crash data” claim is gone, replaced with a clear statement that no crash reports or performance data are collected. The “Last updated” date now reads 6 October 2026.
Why it matters
It’s tempting to copy privacy policy wording that sounds thorough. “You can withdraw consent at any time” sounds responsible. But if the app has no way to do that, the sentence is a promise the product can’t keep. The same goes for crash data: claiming you collect something you don’t is still an inaccurate description of your data processing.
I treated this the same way I treat changes to the question database: check every claim against the real system, change only what is wrong, and keep a record of what changed and why. The privacy policy is part of the product. It should be as accurate as the answers in the exam questions.
PHV Prep UK is available on the App Store and Google Play.
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