Privacy Policy

Last Updated: September 15, 2026

1. Controller

The controller responsible for data processing in this app is:
Roman Sharonov
Louisenstraße 148E, 61348 Bad Homburg v.d. Höhe
aproposde.info@gmail.com

2. General Information

The use of our app is possible without creating a user account. Personal data is processed only to the extent necessary for providing, securing, and improving the app.

3. What Data is Collected, Used, and Shared?

Data we collect:

We do NOT collect: Name, email address, phone number, precise location, photos, contacts, or any other personally identifiable information unless you provide it to us directly (e.g. by email, via support requests, or via our social media profiles).

How data is used:

Data shared with third parties:

4. Services Used

a) Firebase Analytics

We use Firebase Analytics (Google Ireland Ltd.) to obtain anonymous statistics on app usage. Information such as device identifiers, interactions, and session duration may be processed. This data is used to improve the app and user experience.
Legal basis: Legitimate interest (Art. 6(1)(f) GDPR).
More info: https://firebase.google.com/support/privacy

b) Firebase Crashlytics

We use Firebase Crashlytics for error analysis. In the event of a crash, anonymous device and app data are transmitted to improve stability.
Legal basis: Legitimate interest (Art. 6(1)(f) GDPR).

c) Push Notifications

For push notifications we store an anonymous push token. This is used solely to deliver notifications and does not allow identification of a person.
Legal basis: Consent (Art. 6(1)(a) GDPR).

d) App Stores (Apple / Google)

When downloading our app, data may be processed by the Apple App Store or Google Play Store (e.g. account information, payment data). We have no influence on this process.
More info:
Apple
Google

e) Google Play In-App Payments

Our app enables in-app purchases via the Google Play Store. Payment data (e.g. credit card, Google Pay account) is processed directly by Google. We do not have access to payment information.
Legal basis: Performance of a contract (Art. 6(1)(b) GDPR) to complete the purchase.
More info: https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice

f) Apple In-App Payments (optional)

For in-app purchases on iOS devices, payment data is processed directly via the Apple App Store. We do not have access to these payment details.
More info: https://www.apple.com/legal/privacy/

5. Social Media Presences

a) General Information

We maintain publicly accessible profiles on the social networks TikTok, YouTube, Instagram and Telegram in order to provide information about the app "Apropos Deutsch", to share learning content, and to communicate with interested persons and users.

When you visit our social media profiles, personal data is also processed by the respective platform operators. The scope, purpose, and duration of that processing is determined primarily by the platform operators. We have only limited influence over this processing.

We process personal data that you voluntarily provide to us via the platforms or that you make available through your interaction with our profiles. This may include in particular:

Processing takes place for the following purposes:

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in public relations, communication with users, and the needs-based further development and marketing of our app.

Where your request is aimed at concluding or performing a contract, processing is additionally based on Art. 6(1)(b) GDPR. Where consent is obtained, Art. 6(1)(a) GDPR is the legal basis.

Messages and requests stored by us are deleted as soon as the purpose of storage no longer applies and no statutory retention obligations or legitimate interests in further storage exist. Publicly published comments and other interactions can generally be deleted by you directly on the respective platform.

Please note that in order to fully exercise your data subject rights regarding platform-side processing, you should contact the respective platform operator, as only they have full access to the data stored there. For confidential matters, we recommend contacting us by email at aproposde.info@gmail.com rather than via social networks.

b) TikTok

We maintain a profile on TikTok. The platform providers for users in the European Economic Area are:

TikTok Technology Limited
10 Earlsfort Terrace
Dublin 2, D02 T380
Ireland

and

TikTok Information Technologies UK Limited
Kaleidoscope, 4 Lindsey Street
London EC1A 9HP
United Kingdom

According to TikTok, these companies act as joint controllers with regard to the processing of personal data carried out by TikTok.

When you visit or interact with our TikTok profile, TikTok may process in particular account data, usage data, device and network data, IP addresses, location information, comments, messages, and information about content viewed and shared. TikTok may provide us with statistical and aggregated information about the use and reach of our profile and our content.

TikTok may also process personal data outside the European Economic Area, in particular in the USA, Malaysia, and Singapore. According to TikTok, such transfers are based on adequacy decisions, standard contractual clauses, or other transfer mechanisms permitted under the GDPR.

More info: https://www.tiktok.com/legal/page/eea/privacy-policy/en

c) YouTube

We maintain a channel on the video platform YouTube. The provider for users in the European Economic Area is:

Google Ireland Limited
Gordon House, Barrow Street
Dublin 4
Ireland

When you visit our channel, Google may process in particular device and usage data, IP address, watch history, search queries, comments, and subscriptions, and may use cookies and comparable technologies. If you are signed in to a Google account, Google may associate this data with your account.

Through "YouTube Analytics", Google provides us exclusively with aggregated statistics on views, reach, and interactions, which do not allow the identification of individual persons.

Google may also process personal data in third countries, in particular the USA. Such transfers are based on the EU-US Data Privacy Framework or on standard contractual clauses pursuant to Art. 46 GDPR.

More info: https://policies.google.com/privacy

d) Instagram

We maintain a profile on Instagram. The provider for users in the European Economic Area is:

Meta Platforms Ireland Limited
Merrion Road
Dublin 4, D04 X2K5
Ireland

When you visit or interact with our Instagram profile, Meta may process in particular account and profile data, device and usage data, IP address, interactions with our content, and message content, and may use cookies and comparable technologies for this purpose.

Meta provides us with statistical evaluations about the use of our profile ("Insights"). We receive these statistics exclusively in aggregated form. To the extent Meta collects and processes this Insights data, we and Meta are joint controllers within the meaning of Art. 26 GDPR. The applicable agreement ("Page Insights Addendum") is available at: https://www.facebook.com/legal/terms/page_controller_addendum

In this agreement, Meta has assumed primary responsibility under the GDPR for the processing of Insights data, including compliance with information obligations and data subject rights. You may therefore assert your data subject rights directly against Meta; requests addressed to us will be forwarded to Meta.

Meta may also process personal data in third countries, in particular the USA. Information on the transfer mechanisms and safeguards used by Meta is available in Meta's privacy policy linked below.

More info: https://privacycenter.instagram.com/policy

e) Telegram

We maintain a channel or profile on Telegram. According to Telegram's privacy policy, the controller for users in the EEA is:

Telegram Messenger Inc.
Commerce House, Wickhams Cay 1
PO Box 3140, Road Town, Tortola, VG1110
British Virgin Islands

Telegram has appointed the European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium, as its representative in the EEA.

If you subscribe to our channel, comment on posts, or send us a message, Telegram processes in particular your phone number, username, profile information, device and usage data, and the content of your messages. We may see your publicly visible username, profile picture, and the content you send to us or publish in our channel; in addition, we receive aggregated information on subscriber numbers and post views.

According to Telegram, EEA users' data is stored in data centres in the Netherlands. Telegram may transfer data to group companies outside the EEA, including in the United Arab Emirates; Telegram states that it uses Standard Contractual Clauses approved by the European Commission for this purpose. Further details and information on exercising data subject rights are available in Telegram's privacy policy linked below.

More info: https://telegram.org/privacy

6. Advertising and Campaigns

We promote the app "Apropos Deutsch" through advertisements on third-party platforms (in particular Google Ads/YouTube, Meta – Instagram/Facebook – and TikTok Ads). The selection, delivery, and audience targeting of ads is carried out by the respective platform under its own responsibility and in accordance with its own privacy policy. From the platforms we receive only aggregated campaign statistics (e.g. impressions, clicks, installations) that do not allow the identification of individual persons.

Where technologies for measuring the success of advertising campaigns are used in the app that access or store information on your device (e.g. conversion tracking, the device advertising ID), this is done exclusively on the basis of your consent (Art. 6(1)(a) GDPR in conjunction with Sec. 25(1) TDDDG). You may withdraw your consent at any time with effect for the future in the app settings.

In addition, you can reset or delete your device advertising ID at any time:

We do not transfer contact details (e.g. email addresses or phone numbers) to advertising platforms for the creation of "custom audiences".

7. International Data Transfers

When using Google/Firebase services and our social media presences, personal data may be transferred to third countries (e.g. the United States, the United Kingdom, Singapore, Malaysia, the United Arab Emirates). The transfer mechanisms used in each case are set out in the privacy notices of the relevant providers. Where no adequacy decision applies, Google relies on Standard Contractual Clauses pursuant to Art. 46 GDPR; Google LLC is also certified under the EU-US Data Privacy Framework. The United Kingdom is covered by a European Commission adequacy decision.

A copy of the Standard Contractual Clauses used by Google can be requested from Google. For transfers by TikTok, Meta and Telegram, please consult their privacy notices linked above.

More info: https://policies.google.com/privacy/frameworks

8. Data Security

We implement appropriate technical and organizational security measures to protect your data against unauthorized access, loss, or alteration. These include:

While we strive to protect your data, no method of transmission over the internet or electronic storage is 100% secure.

9. Data Retention & Deletion

Retention periods:

Your deletion rights: You can request deletion of your data at any time by contacting us at aproposde.info@gmail.com. You can also:

After data deletion requests, we will delete your data within 30 days unless we are required to retain it by law.

10. User Rights

Under the GDPR you have the right to:

Right to object: Where we process personal data on the basis of legitimate interests (Art. 6(1)(f) GDPR) – for example in the context of our social media presences – you may object to the processing at any time on grounds relating to your particular situation.

You also have the right to lodge a complaint with the competent supervisory authority:
The Hessian Commissioner for Data Protection and Freedom of Information (HBDI)
Postfach 3163
65021 Wiesbaden, Germany
Phone: +49 611 1408-0
Email: poststelle@datenschutz.hessen.de
Website: https://datenschutz.hessen.de

11. Contact

If you have questions regarding data protection, please contact:
Roman Sharonov / aproposde.info@gmail.com