PPL Training

Privacy Policy

Effective: April 2026

1. Scope

This Privacy Policy applies to the mobile applications and services published under the names PPL Training & Exam Preparation, ppl-ecqb-app, and all related variants (hereinafter "the App").

2. Data Controller

Clesk Digital GmbH Am Biehl 5 57234 Wilnsdorf Germany

Managing Directors: Enzo Frenker-Hackfort, Tobias Kajetan Rösner

Phone: +49 (0) 271 33885017 Email: info@clesk.de

3. What Data Is Processed?

3.1 Data Stored Locally (remains on your device)

The following data is stored exclusively on your device and is not transmitted to our servers or third parties:

3.2 Data Transmitted to Third Parties

Service Provider Purpose Data Transmitted Legal Basis
Firebase Storage Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland Loading annex images (exam question graphics) IP address, access time Art. 6(1)(b) GDPR (contract performance)
RevenueCat RevenueCat Inc., 633 Tatnall St, Ste 100, Wilmington, DE 19801, USA In-app subscription management Purchase ID, device ID, subscription status Art. 6(1)(b) GDPR (contract performance)
Google Play Billing Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland Payment processing (Android) Payment data (processed by Google) Art. 6(1)(b) GDPR (contract performance)
Apple StoreKit Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA Payment processing (iOS) Payment data (processed by Apple) Art. 6(1)(b) GDPR (contract performance)
Firebase Crashlytics Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland Detection and analysis of app crashes to improve stability Crash logs, device model, operating system version, app state at time of crash, installation ID Art. 6(1)(f) GDPR (legitimate interest in app stability)

3.3 Data Transfers to Third Countries

RevenueCat and Apple are based in the USA. Data transfers are carried out on the basis of the EU-US Data Privacy Framework (Art. 45 GDPR) or Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR.

4. Cookies and Tracking

The App uses no cookies, no tracking, no Google Analytics, and no Firebase Analytics. No user profiling or tracking of any kind takes place.

Firebase Crashlytics is used solely for detecting and resolving app crashes. It does not capture any personal content (such as search queries, learning progress, or user input), only technical crash information.

5. User Accounts

The App does not require registration or a user account. All learning and usage data remains locally on your device.

6. Data Retention

Locally stored data remains on your device until you uninstall the App or manually reset data via the App settings.

Data held by third parties (RevenueCat, App Stores) is subject to their respective privacy policies and retention periods.

7. Your Rights

Under the GDPR, you have the following rights:

To exercise your rights, please contact: info@clesk.de

8. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy as needed to reflect changes in legal requirements or changes to the App. The current version is always available in the App and on our website.

9. Contact

For questions regarding data protection, please contact:

Clesk Digital GmbH Am Biehl 5 57234 Wilnsdorf Email: info@clesk.de Phone: +49 (0) 271 33885017

PPL Training & Exam Preparation · Clesk Digital GmbH © 2026