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Privacy Policy

1. Data Controller & General Information

The protection of your personal data is highly important to us. Below, we inform you about the processing of personal data when using the DriveBase App and website in accordance with the General Data Protection Regulation (GDPR).

Hoffleit Digital

Representative: Samuel Hoffleit

Hauptstraße 92, 12159 Berlin

support@drivebase-app.de

2. Your Rights as a Data Subject

Under the GDPR, you have the following rights at any time regarding your processed personal data:

  • Right of access (Art. 15 GDPR) to your stored data.
  • Right to rectification (Art. 16 GDPR) of inaccurate data.
  • Right to erasure / Right to be forgotten (Art. 17 GDPR), provided there are no legal storage retention duties.
  • Right to restriction of processing (Art. 18 GDPR).
  • Right to data portability (Art. 20 GDPR) in a structured format.
  • Right to object (Art. 21 GDPR) to future processing.
  • Right to withdraw consent (Art. 7 para. 3 GDPR) at any time.
  • Right to lodge a complaint with a competent supervisory authority (Art. 77 GDPR).

You can exercise these rights directly yourself: delete your account in the app settings or via the “Delete Account” page on this website. As a logged-in user, you can download an export of the account data we store about you (Art. 15/20 GDPR) via the app. For any other requests, an informal email to support@drivebase-app.de is sufficient.

3. Hosting, Server Log Files & Web Fonts

Our website and app assets are hosted on web servers located in Germany. When you load the app, the web server automatically saves temporary connection data (server log files, e.g., IP address, date/time, requested page, browser type). This is processed for IT security and system stability purposes based on Art. 6 para. 1 lit. f GDPR.

For a consistent appearance, we serve the 'Inter' typeface as part of the DriveBase application from our own servers. Loading the font does not connect to Google Fonts or another font provider.

Optional DriveBase emails

Only with your express consent will you receive learning tips, product news and Pro offers from Samuel Hoffleit (Hoffleit Digital). Profile signup is optional, available from age 16 and independent of your account or a purchase. It becomes active only after an additional email confirmation (double opt-in). The legal basis is Article 6(1)(a) GDPR. To select relevant emails we use your email address, account association, language, Free/Pro status and last app activity. At most one marketing email is sent every seven days. We use no opening pixels or individual click tracking.

You can withdraw consent at any time in your profile or through the unsubscribe link in every marketing email without signing in. Processing before withdrawal remains lawful. Emails are sent through our hosting and email provider STRATO, which processes the address and message for delivery. We record the consent wording, version, request and confirmation as evidence. Unconfirmed subscriptions are deleted after 30 days. Delivery details are removed after 90 days; minimal delivery identifiers remain to prevent repeated automations until the contact is deleted. After withdrawal, consent evidence is kept for at most three years to defend potential legal claims (Article 6(1)(f) GDPR). Deleting an account deletes associated contact data and evidence. A hash of an unsubscribed or permanently undeliverable address remains solely to prevent further marketing. This hash is also personal data. The suppression list is reviewed annually for continued necessity.

4. Cookies & LocalStorage

To provide the app features you use, we store technically necessary preferences in LocalStorage, SessionStorage or cookies (section 25(2) no. 2 TDDDG; Art. 6(1)(b) or (f) GDPR). Optional analytics information is stored only after your explicit consent (section 25(1) TDDDG; Art. 6(1)(a) GDPR). This includes:

  • Language preferences: Stores the chosen language setting to display the app correctly (DE/EN/ES).
  • Learning progress and status information: locally stored results and information indicating whether onboarding is complete or an app session is active.
  • Analytics consent: your decision, policy version and timestamp so that your choice can be respected and documented.
  • Only after consent: a random pseudonymous analytics ID, a short-lived session ID, and normalized campaign information or the referring website's domain.

5. Custom Analytics Tracking

On the website and in the iOS and Android apps, internal pseudonymous usage analytics takes place only after your explicit consent (Art. 6(1)(a) GDPR). Session starts, scroll depth, feature areas used, learning and purchase-funnel events, and technically redacted error data may be sent to our own application backend. Each event uses a random pseudonymous analytics ID, a session ID renewed after 30 minutes of inactivity, the platform, language, and page path without query parameters. Campaign parameters are normalized; for external referrals, we store at most the domain rather than the full URL. We do not collect email addresses, names, free text, push tokens, or complete user-agent or stack-trace data for usage analytics. Raw product-event data is deleted after 90 days and redacted technical error details after 30 days. On public web pages, Cloudflare Web Analytics may additionally be loaded after the same consent. Advertising measurement is separate and requires additional consent. You can withdraw consent at any time under “Pseudonymous usage analytics” in the app settings; optional analytics identifiers are then removed from your device.

Google Analytics

With your additional consent to usage analytics including Google Analytics, we use Google Analytics 4 for traffic sources, page views, scroll depth, product views, checkout starts registrations, trials and confirmed purchases. In Android and iOS, with the same separate consent, we use Firebase Analytics for app launches, screen views and these actions; this may involve a pseudonymous app instance identifier. Advertising-ID collection and personalized ads are disabled. This processes cookies, technical browser data, sanitized page addresses and purchase data (pseudonymous transaction identifier, value, currency and product). We do not pass names, email addresses, form entries or login tokens. Google may process data in the US. The property is linked to Google Ads for campaign reporting; our website configuration disables personalized ads and Google Signals. You can change your consent here at any time.

Optional ad measurement

With separate consent we load Google Ads and the OpenAI Measurement Pixel. Providers process technical browser data, ad click identifiers, purchase identifier, amount and currency to measure ad performance. Processing in the US is possible. Your choice is stored with a timestamp. Without consent these pixels are not loaded. For signed-in users we store advertising consent and an available OpenAI ad click identifier for up to 30 days to link website and app actions. With consent, confirmed native purchases and other app actions are sent to OpenAI through our server without email addresses. Queued events have a seven-day retention period; older events are no longer used for attribution.

On the website, with your advertising consent, we also use the Meta Pixel (Meta Platforms Ireland Limited) to measure page views, Pro views, checkout starts, registrations, trials and confirmed purchases. This may process cookies (in particular _fbp and _fbc), IP address, browser and device information, page addresses, event and purchase data (amount, currency and pseudonymous transaction identifier), and link this information to a Meta account. We do not pass names or email addresses or enable automatic advanced matching. Meta cookies may be stored for up to 90 days. Processing in the US is possible. The legal basis is your consent under Article 6(1)(a) GDPR and, for access to your device, Section 25(1) TDDDG. After withdrawal we send no further Meta events. Previous consent without Meta is not carried over. The website pixel does not measure native app installations. Meta Privacy Policy.

6. User Account & Sign-In (Email, Google & Apple)

You can optionally register and sign in via Single Sign-On (Google Sign-In and Apple Sign-In) or email. If you use these services, the following data will be processed to create your user account and authenticate you (Art. 6 para. 1 lit. b GDPR):

  • Unique identification number of the provider (OAuth ID).
  • E-mail address (for account creation and contact).
  • First and last name (for a personalized user profile).
  • Profile picture URL (if enabled by you in your Google settings).

We use the backend service Supabase to manage user accounts and synchronize your learning progress. For technical account administration, we also store whether your signed-in account has used the website, iOS app or Android app, including the first and most recent access per platform, as well as the currently selected learning language (DE/EN/ES) and its most recent synchronization time. Promotional emails require the separate voluntary consent described under “Optional DriveBase emails”. Your account data and learning progress are stored on the basis of a data processing agreement (Art. 28 GDPR). After you delete your account, the associated data is erased unless statutory retention obligations apply.

6a. Duel, friends & invitations

When you use a duel, our own game server processes your chosen display name, room and participant identifiers, answers, response times and points. Signed-in participants are also associated with their account ID for social features. Other players see the display name and game results. Room and answer data is held temporarily in memory and discarded when the room expires. This supports shared play, fair scoring and reconnection; guest duels do not require an account.

Friend connections are stored in Supabase until you remove the connection or delete your account. Your account ID, comparison name, learning progress and game statistics are stored there as account data. Friends see your comparison name, learning progress and game statistics. We do not read your device address book. Our game server stores signed-in opponents’ account IDs, display names and the time of their last shared match from the past 30 days; older entries are automatically pruned. This lets you invite familiar players again.

Duel invitations contain the sender’s and recipient’s account IDs, room code, inviter’s display name, selected games and round count. They are valid for two minutes and are cleared after a response, expiry or closure of the associated room. The invitation appears in the recipient’s open app. This data supports the game, comparison and invitation features you choose to use; it is not used for advertising.

Account deletion removes associated friend connections, duel invitations, recent-player histories including references in other players’ lists, and your participant seats. Aggregate usage counters without names, account IDs, room codes or answers remain. They count matches and participations, not uniquely identified people.

7. Payment Processing (DriveBase Pro)

When you purchase DriveBase Pro, we and our payment providers process the data required to complete the purchase (Art. 6 para. 1 lit. b GDPR). On the website, payment is processed by Stripe (Stripe Payments Europe, Ltd., Ireland): your payment details (e.g., card data) are collected and processed directly by Stripe — we ourselves never receive full payment details, only a transaction reference, your email address, and the purchase status. In the mobile apps, purchases are processed by the Apple App Store or Google Play in accordance with their privacy policies. To validate purchases and assign your Pro status across platforms, we also use the service RevenueCat (RevenueCat, Inc., USA); pseudonymous user IDs and transaction data are processed in this context. Our internal sales overview records verified production transactions using a hashed transaction reference, provider, product, purchase time, reported amount and currency, and any refund status. This separate overview contains no names, email addresses, account IDs or usage events and is not joined to optional behavioral analytics. Transfers to third countries are based on appropriate safeguards (e.g., EU Standard Contractual Clauses or the EU-US Data Privacy Framework).

For confirmed web purchases, we send purchase and, where needed, access activation confirmations to the email address supplied in Stripe Checkout. These necessary messages are separate from optional marketing and contain no advertising or open/click tracking. STRATO handles delivery. Delivery details include the email address, account association where available, language, confirmed amount and currency, and processing/delivery status. They are removed 90 days after the last status change; deleting an account immediately removes associated delivery details. A minimal hashed transaction identifier without an email address or account association is retained solely to prevent repeated payment events from sending another purchase confirmation.

8. Push Notifications (Mobile Apps)

In the mobile apps, you can optionally enable push notifications (e.g. learning or streak reminders). For this purpose, we process a pseudonymous device token, platform, app language and time zone through the Apple Push Notification Service or Firebase Cloud Messaging (Google). If you enable dynamic learning or streak reminders, we also use your selected reminder time, the time of your last learning activity, the most recently started topic and its progress to schedule a relevant reminder (Art. 6 para. 1 lit. a GDPR). Learning and streak reminders can each be controlled separately. Product updates and Pro offers require your separate “News & offers” opt-in. For a one-time Pro reminder at least three days after your first push device registration, we check that registration time and your verified Pro status; Pro purchasers are excluded. An account-specific automation receipt prevents repeated offers and is retained until account deletion. This scheduling does not use optional analytics events. Technical delivery logs are deleted after 90 days at the latest and do not contain device tokens. You can withdraw your consent at any time in the app settings or block notifications in your device settings.

9. E-Mail Communication & Contact

When you contact us via email, your details (name, email address and message) are stored to process the request and follow-up questions, based on Art. 6(1)(b) or (f) GDPR. Registered users receive necessary transactional emails, such as sign-in or purchase confirmations. Promotional learning tips, news and Pro offers require express consent and an additional email confirmation; “Optional DriveBase emails” explains this separate signup and how to withdraw consent.

For feedback you choose to send in the app, we store the message and language on our server to handle your request and improve the product. Your name, email address and account ID are not added automatically. IP address and time are stored separately to prevent abuse, so we do not promise complete anonymity. Please avoid personal details in free text unless they are necessary for your request.

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