Privacy Policy
Section 10 additionally applies to the website ppl-training.com.
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)(a) GDPR (consent) |
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 to detect and resolve app crashes and is disabled by default. You can enable crash reports in the app settings and withdraw your consent there at any time. When enabled, only technical crash information is collected, with no personal content such as search queries, learning progress or user input.
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
10. Website ppl-training.com
This section applies to the website ppl-training.com. The controller is Clesk Digital GmbH as named in section 2, and your rights under section 7 also apply to the website.
10.1 Hosting and Server Logs
The website runs on a server that we operate with Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, in a data centre in Germany. We have concluded a data processing agreement with Hetzner under Art. 28 GDPR. When you open a page, the server processes your IP address in order to deliver the page to your device. In the server logs we store the time, the requested address, the status code, the amount of data transferred, the referring page (referrer) and the browser identifier (user agent), but not your IP address. The logs have a fixed maximum size, and older entries are deleted automatically. The legal basis is our legitimate interest in delivering the website securely and without errors (Art. 6(1)(f) GDPR).
10.2 Visitor Statistics with Umami
For anonymous visitor statistics we use the open-source software Umami. We run it ourselves on our server at Hetzner in Germany, and the data is not passed to any analytics service or other third party. Umami sets no cookies and stores nothing on your device. It records the page visited, the referring page, browser, operating system, device type, screen size, language, the approximate location derived from the IP address (country, region, city) and the time. Umami does not store the IP address itself. It is used only briefly to create a regularly changing identifier for the visit, from which the IP address cannot be recovered. You are not identified, and the data is not combined with other data. The legal basis is our legitimate interest in improving the website on the basis of anonymous usage figures (Art. 6(1)(f) GDPR).
10.3 No Cookies, No Embedded Content
The website sets no cookies and stores nothing in your browser's storage. Fonts, images and scripts come from our own servers, and there is no embedded third-party content. The calculators work only in your browser, and your entries are not transmitted. Links to the App Store, Google Play and Instagram are plain links: the provider only receives data when you click a link, and from then on its privacy policy applies. On iPhone and iPad, Safari may show a banner for the app, and Safari loads the details for it from Apple itself.
10.4 Former Address latc-ppl-training.web.app
The app's former website at latc-ppl-training.web.app is hosted on Firebase Hosting by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When you open this address, Google processes your IP address in order to deliver the page or to forward you to this website. The legal basis is our legitimate interest in keeping existing links working (Art. 6(1)(f) GDPR).