Privacy Policy

1. Overview

PassDE is a German citizenship test preparation app. This Privacy Policy explains what personal data we process, the legal basis for doing so, and your rights under applicable law — including the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679).

In short: PassDE does not collect, transmit, or store any personal data on our servers. All data stays on your device or in your personal iCloud account.

2. Data Controller

The data controller responsible for this app is:

Aryvyn Labs
Contact: privacy@aryvynlabs.com

We are not required to appoint a Data Protection Officer (DPO) under Article 37 GDPR, as we do not engage in large-scale processing of personal data.

3. What Data the App Processes

3.1 Data stored locally on your device

The following data is stored exclusively on your device using on-device storage (SQLite):

This data never leaves your device unless you explicitly use the iCloud backup feature described below.

3.2 iCloud Backup (optional, user-initiated)

If you choose to back up your progress via the in-app backup feature, your study data is encrypted and stored in your personal iCloud account. This data:

• —Is associated with your Apple ID, not with Aryvyn Labs
• —Is accessible only by you
• —Is governed by Apple's Privacy Policy
• —May be stored on Apple servers outside the European Union

Aryvyn Labs has no access to your iCloud data at any time.

3.3 Push Notifications (optional)

If you enable study reminders, notifications are scheduled entirely on your device using Apple's local notification system. No data is sent to external servers. Your device token is not collected by us.

3.4 In-App Purchases

If you make an optional in-app donation, the transaction is processed entirely by Apple's App Store (StoreKit). We receive only a confirmation of whether a purchase was completed — no payment information, card details, or Apple ID is transmitted to us.

4. Data We Do NOT Collect

• —We do not operate servers or collect data remotely
• —We do not use advertising, analytics, or tracking SDKs
• —We do not collect device identifiers, IP addresses, or location data
• —We do not require account registration or login
• —We do not share any data with third parties for marketing purposes
• —We do not use cookies or equivalent tracking technologies

5. Third-Party Services

The app integrates with the following Apple-provided services. Each is governed by Apple's Privacy Policy:

6. Data Retention

All data stored on your device is retained until you:

• —Delete it via Settings → Reset all progress, or
• —Uninstall the app

iCloud backup data is retained until you delete it from your iCloud account in iPhone Settings. We do not retain any personal data on our systems as we do not receive it.

7. International Data Transfers

Data you store in iCloud may be transferred to and stored on Apple servers outside the European Economic Area (EEA). Apple participates in the EU-U.S. Data Privacy Framework and uses Standard Contractual Clauses to ensure GDPR-compliant transfers. See Apple's Privacy Policy for details.

8. Your Rights Under GDPR

If you are located in the European Union or EEA, you have the following rights:

• —Right of access (Art. 15): You can access all your data directly within the app.
• —Right to rectification (Art. 16): You can correct your name and settings at any time within the app.
• —Right to erasure (Art. 17): You can delete all your data via Settings → Reset all progress or by uninstalling the app.
• —Right to data portability (Art. 20): Your data is stored in standard formats on your own device and iCloud account.
• —Right to object (Art. 21): Where processing is based on legitimate interest, you may object by contacting us.
• —Right to withdraw consent (Art. 7(3)): Where processing is based on consent (e.g. your name), you may withdraw by deleting the data in-app.
• —Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority. In Germany: the Federal Commissioner for Data Protection and Freedom of Information (BfDI) at www.bfdi.bund.de.

To exercise any right, contact us at privacy@aryvynlabs.com. We will respond within 30 days.

9. Children's Privacy

PassDE is not directed at children under 16. We do not knowingly process data from children. The app contains no advertising and requires no personal information to function.

10. Changes to This Policy

We may update this Privacy Policy as the app adds new features. The "Last updated" date at the top will be updated accordingly. For significant changes, we will notify users via an in-app notice. Continued use of the app after changes constitutes acceptance of the updated policy.

11. Contact

For any privacy-related questions or to exercise your rights:

Aryvyn Labs
Email: privacy@aryvynlabs.com

We aim to respond to all enquiries within 30 days.