Privacy Policy

1. Controller and contact

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

You can reach us at this address with any question about data protection and to exercise your rights. No data protection officer has been appointed, because the legal requirements for one (Art. 37 GDPR, Section 38 of the German Federal Data Protection Act, BDSG) are not met.

2. Scope and definitions

This privacy policy applies to the mobile app “SKS”, shown in the app as “SKS Lernapp”, for iOS and Android (the “app”), to the website at einsteinhain.com/sks (the “website”) and to communication with us by email. “We” and “us” refer to the controller named above.

“Personal data” means any information relating to an identified or identifiable natural person (Art. 4(1) GDPR). Third-party services, such as Apple’s App Store or Google Play, are governed by their own privacy policies.

3. The app

3.1 Principle: no data transmission

The app helps you prepare for the German coastal skipper’s exam (Sportküstenschifferschein, SKS). All questions, solutions and images are built into the app. The app needs no internet connection, does not open network connections by itself and sends neither your learning progress nor any other data to us or to third parties.

In particular, the app has no user accounts or registration, no cloud sync, no advertising, no third-party analytics, tracking or crash-reporting software, no advertising IDs or other device identifiers used for tracking, no in-app purchases and no payment features.

3.2 Learning progress on your device

When you rate your answer to a question as “Falsch” (wrong), “Teilweise richtig” (partly correct) or “Richtig” (correct), the app stores the following locally on your device:

• the question’s identifier (e.g. “Frage Nr. 14”),
• your rating, and
• the date and time of the rating.

This information is used only to show you your learning progress and to select questions for review. All evaluation (for example, which questions are due) happens on your device only. The data is kept in the app’s own storage area, which the operating system protects (“UserDefaults” on iOS, “SharedPreferences” on Android). No name, email address, location or device identifier is stored. Your choice between light and dark appearance is not stored.

Because this data never leaves your device and we have no access to it, we do not process personal data in this respect. To the extent that storing it were nevertheless regarded as processing by us, it is necessary to provide the learning feature you use.

Legal basis: Art. 6(1)(b) GDPR (providing the app under the terms of use of the respective store) or Art. 6(1)(f) GDPR. Storing data on your device does not require consent under Section 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG), because it is strictly necessary to provide the feature you have expressly requested. Retention: until you delete the data (section 3.5).

3.3 Permissions and device access

The app requests no permissions and does not access the camera, microphone, photos, contacts, calendar, location, Bluetooth, health data or similar device features. The Android version declares no user-visible permissions, in particular not the permission to access the internet.

3.4 Opening this privacy policy from the app

If you tap “Datenschutzerklärung” on the app’s “Übersicht” screen, the app opens this page in your default browser. Your browser, not the app, makes the connection. Section 6 of this policy and your browser’s privacy terms apply.

3.5 Deletion, uninstalling and backups

You can delete all of your learning progress at any time in the app under “Übersicht” → “Alle Fortschrittsdaten löschen” (delete all progress data). The built-in learning content remains. The data is also deleted when you uninstall the app or clear its data in your device’s system settings.

Depending on your device settings, the operating system may include the app’s locally stored data in device backups, such as Apple iCloud backups or Google Android backups, and restore it when you restore or switch devices. These backups are created and managed by the operating system under Apple’s or Google’s terms, not by us. Deleting the data in the app does not remove it from existing backups. You can manage backups in the settings of your device or your Apple or Google account.

4. App Store and Google Play

4.1 Downloading the app

You get the app from the App Store of Apple Distribution International Ltd. (Ireland) or from Google Play of Google Ireland Ltd. (Ireland). When you download it, these providers process data such as your account name, email address, the time of the download and device information as independent controllers. We have no influence on this; see Apple’s privacy policy and Google’s privacy policy. This data is not passed on to us in a form that identifies you.

4.2 Crash reports and usage statistics

Apple and Google provide app developers with crash reports and app usage statistics in their developer consoles (Apple “App Analytics” and crash logs, Google “Android vitals”). Apple and Google collect this data through the operating system, not through the app, and only from users who have agreed to it in their device settings. We receive technical information such as the device model, operating system and app version, the time and technical cause of a crash, and aggregated statistics (for example, the number of installations). We do not receive names, contact details or account identifiers, and we cannot link the information to any person.

We use this information only to find and fix errors and to improve the app’s stability. We do not combine it with other data. It stays in Apple’s and Google’s developer consoles and is deleted there according to their retention periods.

Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is a stable, error-free app.

You can stop sharing at any time: on iOS in Settings under “Privacy & Security” → “Analytics & Improvements” → “Share With App Developers”; on Android, depending on the device, in Settings under “Google” → “Usage & diagnostics”.

4.3 Store reviews

If you publicly review the app in the App Store or on Google Play, we see your review with the name shown there and may reply publicly. The review is published and managed by the respective store.

Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is responding to feedback.

5. Contacting us by email

If you email us, we process your email address, your name (if given), the content of your message and the email’s technical details (such as the time sent) in order to answer your enquiry.

Legal basis: Art. 6(1)(b) GDPR where your enquiry concerns the use of the app; otherwise Art. 6(1)(f) GDPR, our legitimate interest in answering enquiries.

We delete your message and our reply as soon as they are no longer needed to deal with your enquiry, unless statutory retention obligations apply or we need them to establish, exercise or defend legal claims.

Our mailbox is operated by Namecheap, Inc. (USA) as our processor (Art. 28 GDPR). Data may be transferred to the USA in this context; see section 7.

Please note that email is not always fully protected against access by third parties in transit. Please do not send us particularly sensitive information by email.

6. This website

This website consists of static pages only. It uses no cookies, no JavaScript, no analytics or tracking services, no fonts or other content from third parties and no forms. The website does not store or read any information on your device.

The website is hosted on GitHub Pages, a service of GitHub, Inc., 88 Colin P. Kelly Jr. Street, San Francisco, CA 94107, USA. When you visit it, GitHub necessarily processes your IP address and usually further details of the request, such as the time, the address requested and your browser and operating system identifier, in order to deliver the pages. According to GitHub, it stores the IP addresses of visitors to GitHub Pages sites for security purposes, for example to fend off attacks. We do not receive or analyse this data ourselves. Retention is governed by GitHub’s privacy statement.

Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is providing the website, and in particular this privacy policy, securely and reliably.

The website is delivered over an encrypted connection (HTTPS). Links to third-party websites are recognisable as such; their providers are responsible for their content and data processing.

7. Recipients and transfers to third countries

We do not sell personal data and do not share it for advertising purposes. The only recipients of personal data are the service providers named in this policy: GitHub (website) and Namecheap (email). Apple and Google process data as independent controllers (section 4).

Data may be transferred to the USA in this context:

• GitHub, Inc. is certified under the EU-U.S. Data Privacy Framework. For certified companies, an adequacy decision of the European Commission applies (Art. 45 GDPR).
• Namecheap, Inc.: transfers are based on the standard contractual clauses adopted by the European Commission (Implementing Decision (EU) 2021/914, Art. 46(2)(c) GDPR), which form part of the data processing agreement with Namecheap. You can request a copy using the contact details in section 1.

We only disclose data to authorities or other third parties where we are legally required to do so.

8. No automated decisions, no obligation to provide data

We do not make automated individual decisions, including profiling, within the meaning of Art. 22 GDPR. The selection of review questions in the app takes place only on your device and has no legal or similarly significant effect on you.

You are under no statutory or contractual obligation to provide us with personal data. The app can be used in full without providing any personal information.

9. Data security

The app stores your learning progress in the protected storage area that the operating system assigns to each app separately and shields from other apps. You can further improve protection by securing your device with a screen lock and keeping the operating system up to date. The website is delivered only over encrypted connections (HTTPS) and loads no third-party content.

10. Children and young people

The app is intended for people preparing for the SKS exam. It works the same way for all users, regardless of age. Because the app sends no data to us, we do not collect personal data from children or young people through the app.

11. Your rights

Where we process your personal data, you have the following rights, subject to the statutory requirements:

• access to the data processed about you (Art. 15 GDPR),
• rectification of inaccurate data (Art. 16 GDPR),
• erasure of your data (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR), and
• objection to processing (Art. 21 GDPR, see below).

To exercise your rights, an informal message to the address in section 1 is sufficient. We can neither see the learning progress stored in the app nor link it to you (Art. 11 GDPR). You control this data yourself: you can view and delete it in the app at any time.

Right to lodge a complaint: You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the EU member state of your habitual residence, place of work or place of the alleged infringement. The authority responsible for us is:

12. Changes to this privacy policy

We update this privacy policy when the app, the website or the legal requirements change. The version published on this page applies; the date of the last update is shown at the top. If a future version of the app were to process data in a way that requires consent, we would ask for it in the app beforehand.