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:
- Learning progress and statistics
- Exam results and evaluations
- Streak data (learning streaks)
- Bookmarks
- Personal settings and preferences
- Onboarding status
- Premium/subscription status (cached locally)
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:
- Access (Art. 15 GDPR): You may request information about your data processed by us.
- Rectification (Art. 16 GDPR): You may request correction of inaccurate data.
- Erasure (Art. 17 GDPR): You may request deletion of your data. Locally stored data can be deleted at any time by uninstalling the App or resetting data in the settings.
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Objection (Art. 21 GDPR): You may object to the processing of your data.
- Complaint to a supervisory authority (Art. 77 GDPR): You have the right to lodge a complaint with a data protection supervisory authority.
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