1. Controller
The party responsible for this website and the learning application for the citizenship test provided here is: Ryan Davidson / EinbürgerTestCoach
Email: webmaster@einbürgertestcoach.de
2. General Information on Data Processing
This website provides a web-based learning application to prepare for the German naturalization test. No registration or user account is created. We process personal data only as far as it is necessary for the technical operation of the website, the provision of learning functions, storage of your settings and progress, display of advertising, and compliance with legal obligations. GDPR requires information especially on purposes, legal bases, recipients, retention periods, transfers to third countries, and data subject rights.
3. Website Provision and Hosting
When you access this website, technically necessary information is processed so that the website can be delivered, run reliably, and be protected against abuse. This includes, in particular, server log data such as IP address, date and time of access, browser and device information, referrer URL, and requested content. Processing is based on legitimate interests under Art. 6(1)(f) GDPR to provide the service, secure it, and perform error analysis. Under the general principles of GDPR, personal data must be processed lawfully, transparently, and purpose-limited.
Hosting provider: Netlify
Retention period: [default from Google AdSense]
4. Use of the Learning Application and Local Storage in the Browser
For using the learning application, we store and read back certain information locally on your device. This may include, in particular:
- selected federal state
- selected learning mode
- answered questions
- local progress data
- locally stored app settings
This storage is intended to provide the explicitly requested functionality of the learning application and to restore your progress on your next visit. To the extent that information is stored on or read from your device, this is governed by § 25 TDDDG. As a rule, consent is required for storage or access to information in end devices; an exception applies in particular when this is absolutely necessary to provide a telemedia service explicitly requested by the user. Where personal data is subsequently processed, this is done on the legal basis of Art. 6(1)(f) GDPR. Retention period: Local data remains on your device until you delete it yourself or reset your browser data.
5. Consent Management with Google CMP
For consent management related to advertising and cookies, we use the Google Consent Management Platform (Google CMP) within Google AdSense / Privacy & messaging. Google describes this solution as a dialog or overlay that shows users options to consent, decline, or manage their choice depending on location and consent status. After a decision, the message is generally shown again only if a new consent check is required or the message has been updated.
For personalized ads, Google requires a Google-certified CMP integrated into the IAB Transparency and Consent Framework (TCF) for accesses from the EEA/EWR, United Kingdom, and Switzerland. The Google CMP fulfills this role within AdSense.
You can change or revoke your choice at any time, with effect for the future, via: Privacy and cookie settings / Datenschutz- und Cookie-Einstellungen
Google also notes that users must be able to adjust their consent decisions again after the first choice; when the consent interface is opened again, the options “Do not consent”, “Consent”, and “Manage options” are shown accordingly.
6. Google AdSense, Cookies, and Personalized Advertising
We use Google AdSense to display advertising on this website. Google and, depending on your selection, additional ad partners may use cookies or similar technologies and process personal data. Google requires websites using AdSense to provide the notice that third parties, including Google, use cookies to serve ads based on previous visits by a user to this or other websites. Google further states that its ad cookies enable Google and its partners to provide ads based on visits by your users to this website and/or other websites on the internet.
Depending on consent status, the following data or identifiers may be processed, in particular:
- cookie IDs and similar online identifiers
- device and browser information
- IP address
- approximate location information
- information on page views and interactions with ads
- data for reach measurement, frequency capping, and fraud and abuse detection
Personalized advertising is only provided where the required consent has been given. Google describes personalized ads as ads that are based on previously collected or historical data, such as previous searches, website or app visits, location data, or demographic information.
7. Non-Personalized Ads
If you do not consent to personalized advertising, non-personalized ads or limited ads may be served, depending on configuration. Google notes that non-personalized ads may not rely on cookies for ad personalization, but cookies or similar identifiers may still be used for frequency capping, aggregated ad reporting, and prevention of fraud and abuse.
8. Ad Partners and Own Purposes
Within the Google CMP, selected ad partners can be integrated in European consent messages. Google explains that these partners appear on the website section “Ad partners” and are used there to obtain consent. Likewise, your own website purposes can be configured via Google CMP (“purposes for your own use”) with options None, Consent, or Legitimate interest.
The currently selected partners and purposes for this website can be viewed and adjusted through the consent interface at Privacy and cookie settings
9. Legal Basis of Processing
To the extent we process technically necessary data to provide and secure the website, this is done under Art. 6(1)(f) GDPR. To the extent we store or read information on your device, this is governed by § 25 TDDDG. For cookies or comparable technologies that are not strictly necessary, especially in connection with advertising, processing is based on your consent. Where personal data is processed on the basis of your Google CMP decision for personalized advertising, ad measurement, or comparable purposes, this is done under Art. 6(1)(a) GDPR. GDPR explicitly recognizes consent and other legal bases as permissible bases for processing.
10. Recipients of the Data
Possible recipients of personal data include:
- our hosting provider
- Google Ireland Limited or Google LLC within Google AdSense and Google CMP
- additional ad partners potentially selected through the consent interface
- Google states for its publisher products that publishers and Google act as independent controllers.
11. Transfers to Third Countries
In the use of Google AdSense and the Google CMP, transfer of personal data to countries outside the European Union or the European Economic Area, in particular the United States, cannot be excluded. Google explains for its Ads services that it relies on the EU-U.S. Data Privacy Framework, the UK Extension, and the Swiss-U.S. Data Privacy Framework for certain transfers, and uses standard contractual clauses as a supplement in certain circumstances.
12. Retention
We store personal data only as long as necessary for the respective purpose or as long as required by statutory retention obligations. In detail:
- local browser data: until you delete it
- server logs: according to hoster policies
- consent and ad data: according to Google and the respective partners involved
13. Your Rights
Under GDPR, you have the following rights in particular:
- Right of access
- Right of rectification
- Right of erasure
- Right to restriction of processing
- Right to data portability
- Right to object
- Right to withdraw previously given consent with effect for the future
- Right to lodge a complaint with a data protection authority
- The European Commission explicitly lists these rights as core GDPR data subject rights.
- To exercise your rights, sending a message to webmaster@einbürgertestcoach.de is sufficient.
14. Right to Complain to a Supervisory Authority
You have the right to complain to a data protection authority about the processing of your personal data, in particular in the member state of your habitual residence, workplace, or location of the alleged violation. The European Commission also explicitly lists this right.
Responsible supervisory authority: [Name and address of the competent data protection authority]
15. Changes to This Privacy Policy
We reserve the right to amend this privacy policy if legal, technical, or organizational conditions change. The current version published on this website shall always apply.