Privacy Policy

This is a courtesy English translation. The legally binding version is the German Datenschutzerklärung.

1. Who is responsible

The controller under the GDPR for the app "Einbürgerungstest: Bestehen" is Alexey Berezka, M 7, 13, 68161 Mannheim, Germany, e-mail [email protected] (see also the Impressum). I have no data protection officer; the law does not require one for me.

2. What the app stores on your device

The app stores your data only locally on your iPhone or iPad, in the app's protected storage. I have no access to it. What is stored:

• your progress per question: correct and wrong answers, streak, bookmarks, time of the last answer;
• your exam history: date, federal state, score, number of questions, duration;
• which questions you have unlocked translation and explanation for;
• your settings: language, German-only mode, inline translation, federal state, theme, introduction finished;
• which Pro level is active (section 5).

The app has to remember this, otherwise it does not work the way you want it to (Art. 6(1)(b) GDPR); no separate consent is needed for that (§ 25(2) no. 2 TDDDG, the German Telecommunications Digital Services Data Protection Act). The data stays as long as the app is installed. "Reset Learning Progress" in the settings deletes progress, bookmarks and exam history; the settings, the unlocks and the number of free exam simulations already used remain. If you delete the app, the data on the device is gone.

Backups. If you use iCloud Backup or back up your device through a computer, this app data is included in the backup and stays there until you delete it. Only you control that, in your device settings; the app itself syncs nothing through iCloud. Apple is responsible for iCloud (Apple's privacy policy).

3. No internet connection, no tracking

All questions, pictures, translations, explanations and state borders are built into the app. It opens no connection to the internet by itself: no third-party analytics or crash tools, no ad networks, no servers of my own, no link to the BAMF or any other authority. Nobody but you sees your results. Only Apple's purchase functions talk to Apple (section 5). Whether Apple passes crash reports and usage statistics on to me, which Apple says it collects anonymously, is your choice in the iOS settings under Privacy & Security, Analytics & Improvements.

Links in the app open in your browser; from there the privacy policy of that website applies. This page, too, belongs to my website; what happens when you open it is described in the privacy policy of berezka.me.

4. Location, only if you want it

If you tap "Use GPS" at the first start or later "Detect via GPS" in the settings, iOS asks for your permission. If you allow it, the app asks iOS once for your approximate location (requested with an accuracy of about one kilometre) and checks on the device, against the built-in state borders, which federal state it lies in. Only the federal state is stored. The app neither stores nor transmits the location, looks up no address and needs no internet for this; how iOS determines the location is governed by Apple's Location Services. Outside Germany no federal state is found.

The legal basis is your consent in the iOS dialog (Art. 6(1)(a) GDPR, § 25(1) TDDDG). You can withdraw it at any time in the iOS settings under Location Services (Art. 7(3) GDPR); this takes effect for the future, the processing before it remains lawful. You do not have to share your location: the federal state can always be chosen by hand.

5. Purchases and subscription (Pro)

Pro is optional: a weekly subscription or a one-time purchase through Apple's App Store. Payment and your Apple account stay entirely with Apple; I receive neither your name, address, e-mail address nor payment details. The app only receives a signed purchase confirmation from Apple (product, purchase date, validity period, transaction number), checks it on the device and remembers only the active Pro level. There is no server of my own for this. The check is necessary to unlock what you paid for (Art. 6(1)(b) GDPR). Apple is responsible for the processing on Apple's side; for users in Germany that is Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland (Apple's privacy policy). You manage and cancel subscriptions in your Apple account.

6. Reporting a problem and contact by e-mail

If you choose "Report an Issue with this Question" or "Contact & Feedback" and tap "Send Email", your own mail app opens with a prepared message to [email protected]. Pre-filled are your text, the topic, for a reported question its number and ID, the German text with the correct answer and the translation in your app language, and always the app version, federal state, app language, iOS version and device type (iPhone or iPad). You can change or delete all of it before sending. The app sends nothing; only your mail app sends, with your e-mail address as sender.

I use the e-mail to fix the error and to answer you. The legal basis is my legitimate interest in finding errors in the app and answering enquiries (Art. 6(1)(f) GDPR), for questions about a purchase Art. 6(1)(b) GDPR. You do not have to send me anything; without an e-mail address, though, I cannot reply. I keep the e-mail for as long as I need it for your report and delete it afterwards, unless a law obliges me to keep it.

E-mails to [email protected] are received by Cloudflare and forwarded to my mailbox at Google (Gmail) (Cloudflare Email Routing; provider Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA, as my processor under Art. 28 GDPR). The provider of Gmail for users in the European Economic Area is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Cloudflare and Google may also process the data outside the EEA, above all in the USA. Cloudflare, Inc. and Google LLC are certified under the EU-U.S. Data Privacy Framework; the transfer relies on the European Commission's adequacy decision for this framework (Art. 45 GDPR, Implementing Decision (EU) 2023/1795). More in section 5 of the privacy policy of berezka.me; it also covers the contact form on my website that the app links to.

7. Recipients, third countries, no automated decisions

I pass no data on from the app. There are recipients only when you trigger something yourself: Cloudflare and Google as my e-mail providers when you write to me (section 6), and Apple, under its own responsibility, for purchases (section 5) and backups (section 2). Data may be processed outside the EU in doing so: for e-mails on the basis named in section 6, for Apple under Apple's privacy policy. Beyond that I transfer no data to countries outside the EU. The app makes no automated decisions with legal or similarly significant effect (Art. 22 GDPR); the exam readiness shown is only a calculation on your device that nobody but you sees.

8. Your rights

You have the right to access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20). You may withdraw a consent at any time (Art. 7(3) GDPR), for the location in the iOS settings; the withdrawal takes effect for the future. For this, write to [email protected] or to the postal address in section 1. The data on your device can be viewed and deleted only by you (section 2).

Right to object (Art. 21 GDPR). You may object at any time, on grounds relating to your particular situation, to processing I base on my legitimate interest (e-mails, section 6). I will then no longer process your data, unless compelling grounds override your interests or I need the data for legal claims.

You may lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for example with the one responsible for me: the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg (Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg), Heilbronner Straße 35, 70191 Stuttgart, Germany, www.baden-wuerttemberg.datenschutz.de.