Privacy Policy - Einbürgerungstest App

1. Data Controller and Contact Information

Data Controller under GDPR:

DABE Apps
dabeapps@gmail.com
Berlin, Germany
App: Einbürgerungstest (de.dabe.einburgerungstest)

This privacy policy informs you about the nature, scope, and purpose of the processing of personal data in our mobile application "Einbürgerungstest" (German Citizenship Test).

2. General Information on Data Processing

We take the protection of your personal data very seriously. This privacy policy explains what data we collect, how we use it, and what rights you have.

Principles of Our Data Processing

Data Minimization: We only collect data necessary for app functionality
Local Storage: Your learning data is primarily stored locally on your device
Consent: External data transmission only occurs with your explicit consent
Transparency: Complete information about all data processing activities

3. Data Collection and Use

3.1 Locally Stored Data

This data is stored exclusively on your device and is not transmitted:

Data Type	Purpose	Storage Location	Deletion
Answers to test questions	Track learning progress, create statistics	Realm database (local)	Upon app uninstallation or manually in settings
Bookmarks (saved questions)	Manage personal question list	Realm database (local)	Upon app uninstallation or manually deletable
App settings	Personalization (language, theme, region)	AsyncStorage (local)	Upon app uninstallation or reset in settings
Consent status	GDPR compliance, remember preferences	AsyncStorage (local)	Upon app uninstallation
Notification preferences	Store practice reminder schedule (selected days, time)	AsyncStorage (local)	Upon app uninstallation or disable in settings

3.2 Local Push Notifications

Our app offers optional practice reminders through local push notifications:

How it works: Notifications are scheduled locally on your device - no data is sent to external servers
Data stored: Your preferred days and time for reminders (stored only on your device)
Control: You can enable, disable, or modify notification settings at any time in the app settings
Permissions: The app will request notification permission from your operating system; you can revoke this permission at any time in your device settings

Legal Basis: Art. 6 para. 1 lit. a GDPR (Consent) - Notifications are only sent after you explicitly enable them and grant permission.

3.3 Optionally Transmitted Data (Only with Consent)

                Important: This data transmission only occurs if you have explicitly consented. You can withdraw your consent at any time in the app settings.
            

Analytics Data (PostHog)

Legal Basis: Art. 6 para. 1 lit. a GDPR (Consent)

Processed Data:

App version and operating system (for compatibility assurance)
Anonymized usage statistics (which features are used)
Learning progress metrics (without personal identification)
Technical events (app start, navigation between screens)

Purpose: Improving app functionality and user experience

Recipient: PostHog Inc., EU servers (Frankfurt)

Retention Period: 12 months

Crash Reports (Sentry)

Legal Basis: Art. 6 para. 1 lit. a GDPR (Consent)

Processed Data:

Technical error information
App version and device information
Time of error occurrence
Anonymized usage context (without personal data)

Purpose: Bug fixing and stability improvement

Recipient: Sentry.io (Functional Software Inc.)

Retention Period: 90 days

Advertising (Google AdMob)

Legal Basis: Art. 6 para. 1 lit. a GDPR (Consent) for personalized advertising; Art. 6 para. 1 lit. f GDPR (Legitimate interests) for non-personalized advertising

Processed Data:

Device advertising ID (for personalized advertising)
IP address (anonymized for geolocation)
Device information (model, operating system, screen size)
Ad interactions (clicks, views)
Approximate location (based on IP address)

Purpose: Display of advertising to fund free app usage

Recipient: Google LLC (Google AdMob)

Retention Period: According to Google policies (see Google Privacy Policy)

                Your Advertising Choices:
                Personalized Advertising: Interest-based ads are only shown with your explicit consent
Non-personalized Advertising: If you decline, you will see general ads without tracking
Settings: You can change your advertising preferences at any time in the app under Settings → Privacy
Device Settings: Additionally, you can reset your advertising ID or disable personalization in your device settings

            

4. Legal Bases for Processing

The processing of your personal data is based on the following legal grounds:

Art. 6 para. 1 lit. a GDPR (Consent): For analytics, crash reporting, and personalized advertising
Art. 6 para. 1 lit. b GDPR (Contract performance): For providing app functionality
Art. 6 para. 1 lit. f GDPR (Legitimate interests): For technical functionality, security, and non-personalized advertising to fund the free app

5. Data Sharing and Third Parties

5.1 PostHog (Analytics Service)

Provider: PostHog Inc.
Server Location: European Union (Frankfurt)
Purpose: Anonymized usage analysis for app improvement
Privacy Policy: https://posthog.com/privacy

5.2 Sentry (Error Monitoring)

Provider: Functional Software Inc. (Sentry.io)
Server Location: USA (adequate level of data protection under Adequacy Decision)
Purpose: Error analysis and app stability
Privacy Policy: https://sentry.io/privacy/

5.3 Google AdMob (Advertising)

Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Server Location: Worldwide (Google data centers, including EU)
Purpose: Display of advertising (banner and rewarded ads)
Data Transfer to Third Countries: Google is certified under the EU-US Data Privacy Framework
Privacy Policy: https://policies.google.com/privacy
Ad Settings: https://adssettings.google.com

Information about Google AdMob:

Google AdMob uses cookies and similar technologies to display advertising. For personalized advertising, Google uses information such as previous search queries, app usage, and demographic data to show relevant ads. More information about how Google uses data can be found at: https://policies.google.com/technologies/partner-sites

Important Note: We do not sell user data. Data transfer to advertising partners occurs solely for the purpose of displaying advertising and only with your consent for personalized advertising.

6. Your Rights Under GDPR

You have the following rights regarding your personal data:

6.1 Fundamental Rights

Right of Access (Art. 15 GDPR): Information about processed data
Right to Rectification (Art. 16 GDPR): Correction of inaccurate data
Right to Erasure (Art. 17 GDPR): "Right to be forgotten"
Right to Restriction (Art. 18 GDPR): Limitation of processing
Right to Data Portability (Art. 20 GDPR): Export of your data
Right to Object (Art. 21 GDPR): Objection to processing

6.2 Withdrawal of Consent

You can withdraw your consent for analytics and crash reporting at any time:

In the App: Settings → Privacy → Disable Analytics/Crash Reporting
By Email: dabeapps@gmail.com

Withdrawal only affects future processing and does not affect the lawfulness of processing prior to withdrawal.

6.3 Data Export and Deletion

Functions available in the app:

Data Export: Settings → "Export Data"
Delete Local Data: Settings → "Clear All Data"
Uninstall App: Automatically removes all local data

7. Data Security

We implement technical and organizational measures to protect your data:

7.1 Technical Measures

Local Storage: Learning data remains on your device
Encryption: Secure data transmission (TLS/SSL)
Anonymization: Removal of personal identifiers in analytics
Device-specific Protection: Utilization of operating system security

7.2 Organizational Measures

Regular security reviews
Restricted access to processing systems
Employee training in data protection
Incident response procedures

8. Retention Periods

Data Type	Retention Period	Deletion
Local learning data	Until app uninstallation or manual deletion	Immediately upon uninstallation or in app settings
Analytics data (PostHog)	12 months	Automatically after period expires
Crash reports (Sentry)	90 days	Automatically after period expires
Advertising data (Google AdMob)	According to Google privacy policies	Via Google ad settings or resetting advertising ID
Consent records	3 years after withdrawal	According to legal retention requirements
Notification preferences	Until app uninstallation or manual disable	Immediately upon disabling or uninstallation

9. Special Notes

9.1 Minors

Our app is intended for persons who want to take the citizenship test. We do not knowingly collect data from persons under 16 years of age. If we learn that we have received data from minors without parental consent, we will delete it immediately.

9.2 Automated Decision-Making

We do not use automated decision-making or profiling within the meaning of GDPR.

9.3 International Data Transfers

Data transfers to third countries only occur with adequate level of data protection or appropriate safeguards (Adequacy Decisions, Standard Contractual Clauses).

10. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority about our processing of personal data:

Competent supervisory authority for Germany:

Federal Commissioner for Data Protection and Freedom of Information (BfDI)
Graurheindorfer Str. 153
53117 Bonn, Germany
Phone: +49 (0)228 997799-0
Email: poststelle@bfdi.bund.de
Website: www.bfdi.bund.de

11. Changes to This Privacy Policy

We reserve the right to update this privacy policy to reflect changes to our practices or for other operational, legal, or regulatory reasons.

For significant changes, we will inform you by:

In-app notification on next app launch
Updating the "Last Updated" date at the top of this policy
New consent request if data processing changes