Privacy Policy
Effective date: 28 April 2026
This Privacy Policy explains what personal data DeutschTest.pro collects, how we use it, with whom we share it, and how it's protected. By using the service, you agree to this Policy.
This Policy is written to comply with the EU General Data Protection Regulation (GDPR) and applicable data protection laws in your jurisdiction.
1. Data controller
The data controller is:
Wjatscheslaw Larionow (Sole Proprietor under Russian law)
Tax ID (INN): 550517616144
Address: Sibirsky Prospekt 20, Apt. 61, 644109 Omsk, Russian Federation
Email for data protection matters: hallo@deutschtest.pro
We do not have an EU representative or a dedicated Data Protection Officer. For all data protection questions, contact us directly at the email above (in English or German).
2. What data we collect
2.1. Data you provide directly
At registration:
- email address;
- name (optional);
- password (stored only as a salted hash; we never see your plaintext password);
- preferred interface language.
During use:
- your responses to tasks (text in Schreiben, voice recordings and their transcripts in Sprechen);
- results and history of completed Modules;
- responses to optional surveys (e.g., "How did you hear about us?");
- feedback after Module completion (optional).
At payment:
- We do not receive or store your payment card data. This is handled directly by the payment provider Prodamus.
- We receive a payment confirmation, transaction ID, and amount from the payment provider.
2.2. Data collected automatically
- Technical data: IP address, browser type and version, operating system, language, time zone — used for service operation and abuse prevention.
- Session cookies: technically necessary cookies for keeping you logged in. Without these, the service can't function.
- Anonymous statistics: aggregate site usage via the Umami analytics tool, which doesn't use cookies and doesn't identify individual users.
2.3. Data we do NOT collect
- We don't use advertising cookies or tracking pixels.
- We don't deploy Google Analytics, Facebook Pixel, or similar tracking systems (as of this version).
- We don't access your microphone without your explicit permission (only during active Sprechen modules with your consent).
3. Why we process your data
| Purpose | Data | Legal basis |
|---|---|---|
| Registration and authentication | email, password, name | Contract performance (Art. 6(1)(b) GDPR) |
| Service delivery (Module access, AI scoring) | responses, history | Art. 6(1)(b) GDPR |
| Payment processing and refunds | email, payment confirmation | Art. 6(1)(b) and (c) GDPR |
| Transactional emails (verification, receipts) | email address | Art. 6(1)(b) GDPR |
| Fraud prevention | IP address, technical data | Legitimate interest (Art. 6(1)(f) GDPR) |
| Service improvement (anonymous stats) | Umami data | Legitimate interest |
| Responding to your inquiries | data from your inquiry | Art. 6(1)(b) and (f) GDPR |
We do not use your data for:
- automated decision-making with legal effect;
- profiling for advertising purposes;
- training third-party AI models.
4. Recipients of your data
To deliver our services, we use the following data processors:
| Provider | Data | Location | Purpose |
|---|---|---|---|
| Supabase (Supabase Inc.) | email, name, history, responses | Frankfurt, Germany (EU) | Database and authentication |
| Timeweb Cloud | all application data | Frankfurt, Germany (EU) | Application hosting |
| Resend (Resend Inc.) | email address, message body | USA | Transactional email delivery |
| Anthropic (Claude) | text of your response + task context | USA | AI-based response evaluation |
| OpenAI (Whisper) | voice recording from Sprechen | USA | Speech-to-text transcription |
| ElevenLabs | dialogue scripts | USA | Speech synthesis for Hören |
| Prodamus | payment data (via secure payment form) | Russia | Payment processing |
| Umami | anonymous visit statistics | Self-hosted | Cookie-free analytics |
4.1. Transfers to the United States
Resend, Anthropic, OpenAI, and ElevenLabs process data in the USA. Since the U.S. is not consistently recognized by the EU Commission as providing adequate data protection, transfers rely on:
- EU Standard Contractual Clauses (SCCs) under Art. 46 GDPR;
- where applicable, certification under the EU-U.S. Data Privacy Framework;
- the principle of data minimization — we transmit only what's necessary and avoid sending identifying information (such as your email) alongside response content where technically feasible.
4.2. Transfers to Russia
The data controller is registered in Russia. The payment provider Prodamus also operates in Russia and receives your payment data directly via its secure form. This transfer is based on your explicit consent (Art. 49(1)(a) GDPR) given when you click "Pay", and is necessary for contract performance (Art. 49(1)(b) GDPR).
We do not sell your data, and we do not share it for advertising purposes.
5. Where data is stored
The main database and application hosting are physically located on servers in Frankfurt, Germany — within the European Union, ensuring the high level of protection required by the GDPR.
6. Retention periods
| Data type | Retention period |
|---|---|
| Registration data (email, name) | Until account deletion |
| Module history and responses | Until account deletion |
| Payment records (confirmation, transaction ID) | 3 years (statutory tax records) |
| Technical logs (IPs, errors) | 90 days |
| Database backups | 30 days, automatic deletion |
| Data after account deletion | Deleted within 30 days, except where retention is legally required |
7. Your rights under GDPR
You have the following rights:
- Right of access (Art. 15) — find out what data we hold about you;
- Right to rectification (Art. 16) — correct inaccurate data;
- Right to erasure (Art. 17) — request deletion ("right to be forgotten"). You can delete most data yourself via account settings;
- Right to restriction (Art. 18) — pause certain processing;
- Right to data portability (Art. 20) — receive your data in a machine-readable format;
- Right to object (Art. 21) — object to processing based on legitimate interests;
- Right to withdraw consent — at any time, with effect for the future;
- Right to lodge a complaint with a supervisory authority (Art. 77) — file a complaint with your country's data protection authority.
To exercise any of these rights, email us at hallo@deutschtest.pro with the subject line "Data Protection Request". We respond within 30 days.
8. Data security
We apply reasonable technical and organizational measures:
- HTTPS/TLS encryption for data in transit;
- passwords stored only as salted hashes;
- restricted database access at the infrastructure level;
- regular backups with automatic deletion of old copies;
- role-based access controls.
In case of a data breach, we'll notify you and the supervisory authority within the GDPR's 72-hour deadline (Art. 33 GDPR).
9. Cookies
We use only technically necessary cookies:
- Session cookies for login state and language preference;
- Cookie-consent cookie to remember your choice in the cookie banner.
These don't require explicit consent under EU law (PECR/§25(2) TTDSG).
Our analytics provider Umami is cookie-free and doesn't identify individual users — no consent required.
If we add additional analytics or marketing tools in the future (e.g., Google Analytics), they will be activated only with your explicit consent via the cookie banner. This Policy will be updated accordingly.
10. Minors
The service isn't aimed at a specific age group, but is open to anyone preparing for Goethe exams — which can include people under 18. If you're under 16, please use the service only with your parents' or legal guardians' consent. If you're a parent and notice your child registered without your knowledge — contact us, and we'll delete the account.
11. Changes to this Policy
We may update this Policy from time to time, e.g., when adding new features or in response to legal changes. For substantial changes, we'll notify you by email. The current version is always available at deutschtest.pro/privacy.
12. Contact
For data protection inquiries:
Wjatscheslaw Larionow Sibirsky Prospekt 20, Apt. 61 644109 Omsk, Russian Federation
Last updated: 28 April 2026.