Privacy Policy

This Privacy Policy explains how Red Azul LLC (“Red Azul”, “we”, “us”) processes personal data when you visit our website at red-azul.com, when you use the browser version of Road to Germany at app.red-azul.com, and when you use our mobile application Road to Germany, published by Red Azul LLC (focused on preparation for the German Einbürgerungstest / naturalization knowledge test).

“Personal data” means any information relating to an identified or identifiable individual (Article 4(1) GDPR).

If you are located in Germany, the European Economic Area, or the United Kingdom, the GDPR (and, where applicable, UK GDPR) applies where relevant. For users in Germany using the German storefront listings on the Apple App Store or Google Play, this statement also serves as transparency information under applicable EU law, including—where the website qualifies as telemedia—the German Telecommunications Telemedia Data Protection Act (TTDSG) concerning cookies and similar technologies on our website (see Section 5).

Where we rely on consent, we point to Article 6(1)(a) GDPR and Article 7 GDPR.

Controller under Article 4(7) GDPR for the website and app:

Red Azul LLC
United States of America
Represented by: Dr. Daniel Leon Glauert

Publisher (store listing): In the respective store listings—including the Apple App Store (Germany region) and Google Play (Germany region)—Red Azul LLC is identified as the publisher of Road to Germany. This Privacy Policy applies equally if you obtain the app through those listings.

Contact: info@red-azul.com, the contact form at red-azul.com/contact.html (opens your mail app to that address), and the official Red Azul social channels linked there — including for privacy requests and exercising your data subject rights. Data deletion instructions: Data deletion.

Article 27 GDPR (EU representative): Red Azul LLC is not established in the Union. Where we are required to designate a representative in an EU member state—or do so voluntarily—we will list name and contact details here. Until then, you can reach us through the contact routes above.

Our website is hosted by an infrastructure provider. When you access pages, the server may automatically collect and store information in server logs (for example IP address, timestamp, requested URL, transferred data volume, browser user agent, referrer).

Purpose: security (including abuse prevention), troubleshooting, and stable operation.

Legal basis: legitimate interests under Article 6(1)(f) GDPR.

Retention: typically days to weeks depending on hosting configuration.

Operational note: insert your hosting vendor name, data processing agreement link, and retention settings here for your records.

Our contact page helps you compose an email to info@red-azul.com (mailto). When you send the message, your email provider transmits the content you chose to include (such as name, reply address, and message body).

Legal basis: Article 6(1)(b) GDPR (pre-contractual steps / business correspondence) and/or Article 6(1)(f) GDPR (responding to inbound requests).

Retention: until your request is handled, unless legal retention obligations require longer storage.

Our marketing website at red-azul.com uses cookies and similar technologies as follows.

Consent Mode v2: Before any Google tag runs, we set Google Consent Mode defaults to denied for analytics_storage, ad_storage, ad_user_data, and ad_personalization. A first-party preference cookie ra_consent (Path=/, SameSite=Lax, up to 180 days) stores your choice. You can reopen Cookie settings in the site footer anytime (or use “Do Not Sell or Share My Personal Information”).

Necessary (always on): ra_consent (stores your cookie preference). Security and CDN delivery cookies from our hosting provider may also apply.

Analytics (opt-in): Google Analytics 4 (gtag.js), measurement ID G-N0KGN6F16J, only after you accept analytics (banner Accept all / Customize). Separate from in-app analytics (Section 7a).

Marketing / ads (opt-in): Google AdSense (publisher pub-4767365735070609) on marketing pages only after consent; legal pages do not load AdSense. Google Privacy & messaging / Consent Mode applies where configured.

Global Privacy Control (GPC): If your browser sends GPC, we treat it as an opt-out of sale/share and keep analytics and ads storage denied.

For users in Germany, Section 25 TTDSG applies where relevant. Legal basis: Article 6(1)(f) GDPR for strictly necessary cookies; Article 6(1)(a) GDPR for optional cookies.

Advertising and consent in the browser app are described in Section 5a.

The learning product Road to Germany is also available in the browser at https://app.red-azul.com/. That host is operated by Red Azul LLC and served via Cloudflare.

On first open, the web app asks for language (necessary cookie rtg_locale, Path=/, up to one year) and then shows an in-app consent screen for analytics and crash reporting. Ads consent for EEA/UK/CH is handled via Google’s Privacy & messaging / Consent Mode (TCF where applicable). Consent Mode defaults for ad and analytics storage are denied until you choose otherwise.

On the web app we may display ads via Google AdSense (Google Ireland Limited / Google LLC). For this purpose Google may process device and usage data (for example IP address, cookie or similar identifiers, browser information, and page interactions) to deliver, measure, and (where consented) personalize ads.

Legal basis: Article 6(1)(a) GDPR (consent) for optional advertising cookies / identifiers; Article 6(1)(f) GDPR only where strictly necessary for security or basic delivery that does not require consent.

Publisher ID: pub-4767365735070609. Google’s privacy information: policies.google.com/privacy and policies.google.com/technologies/ads.

You can change or withdraw consent in the web app Settings (analytics toggle and Google privacy options) or by clearing site data / using browser controls, including GPC. Blocking ads does not affect core study features.

The app helps users prepare for the German naturalization knowledge exam based on the official-style catalog Leben in Deutschland / BAMF overall question pool (300 general questions plus state-specific items). It is implemented as an Expo/React Native application published by Red Azul LLC via Apple App Store and Google Play, including listings for Germany.

Features include practice quizzes, statistics, multilingual UI, federal-state selection, and optional local study reminders. Development is internal; the source repository is private and not publicly accessible.

Important: the app is an educational aid and does not provide legal advice about immigration or citizenship outcomes.

Per current product documentation, core learning data is processed locally on your device using mechanisms such as AsyncStorage and SQLite.

Typical on-device categories include:

• Quiz history (answered items, correctness) for statistics and smarter question selection
• Progress/gamification state (for example streaks, points, levels, completed practice exams), where implemented
• Language preference (for example German / English / Spanish)
• Selected German federal state for state-specific questions
• Notification preferences and optional online-content toggles (see Sections 8–9)

We do not operate a user registration backend for the learning dataset described above. As of this policy version, these core learning records are not transmitted to cloud servers operated by us for the primary offline/local mode.

Legal basis: Article 6(1)(b) GDPR (performance of the app contract / delivery of features) and Article 6(1)(f) GDPR (reliability and security).

You can delete local data by uninstalling the app or—where available—via in-app reset controls.

In the Road to Germany app we may process limited usage / interaction events (for example starting or completing a practice session) to understand product use and improve the learning experience. These events are sent to Google Analytics / GA4 only after you grant analytics consent in the app (consent screen and/or Settings).

You can disable analytics at any time in the app Settings. After withdrawal or refusal, we do not send further analytics events for this purpose, and on iOS and Android the analytics instance identifier is reset.

Separate from advertising consent: App analytics consent is independent of advertising-related choices (for example Google AdMob, Apple App Tracking Transparency (ATT), and Google UMP / consent messaging for ads). Declining analytics does not by itself change ad consent, and declining ads does not by itself change analytics consent.

Technical transport (current product, from app version 2.6.0): On native iOS and Android, consented events are sent via the Google Analytics for Firebase SDK (React Native Firebase). Collection is disabled by default and only enabled after your opt-in. We do not collect the advertising identifier (IDFA / Google Advertising ID) for analytics, automatic screen tracking is off, and analytics data is not used for advertising or ad personalization. On the web app (app.red-azul.com), consented events are sent via Firebase Analytics for JavaScript (Google Analytics 4, measurement ID G-7NERZYQCX1); analytics cookies (for example _ga) are set only after your opt-in, Google signals and ad personalization signals are disabled, and withdrawing consent stops collection.

Categories may include event names and related parameters (for example practice/exam flow markers), plus technical identifiers required by Google Analytics (for example a client/instance identifier). We do not use analytics to create an account with us or to award an official exam result.

Legal basis: Article 6(1)(a) GDPR (consent). Where storing information on your device or accessing information stored there is involved, Section 25 TTDSG also applies where relevant.

Processor / recipient: Google (including Google Ireland Limited and/or Google LLC, United States), acting as processor for analytics where applicable. Transfers to the United States are protected by appropriate safeguards under Article 46 GDPR, in particular the EU Standard Contractual Clauses (SCCs), where required. Google’s information: policies.google.com/privacy.

With permission granted through your operating system, the app may schedule local notifications (study reminders). These are generated on-device; we do not send promotional push notifications via external messaging servers.

Legal basis: Article 6(1)(a) GDPR where consent is required via OS permission flows.

If you enable optional online features in settings (for example linked or embedded media), opening those resources may transfer data to third-party providers. For YouTube links/openings, Google’s privacy policy applies.

Legal basis: Article 6(1)(a) GDPR (in-app consent toggles) and/or Article 6(1)(f) GDPR where applicable.

Review your platform account privacy settings accordingly.

Question and image materials are assembled from documented public sources (including orientation toward the official “Leben in Deutschland” catalog). Portions of the visual catalog may align with the MIT-licensed reference project flexsurfer/einburgerungstest; full license texts are maintained internally with the product archive.

This does not by itself involve processing of personal data by us; if you follow external links, the respective providers’ privacy policies apply.

Downloads, updates, and use of store infrastructure involve processing by Apple Deutschland GmbH & Co. KG and/or Google Ireland Limited (depending on account and region), together with their respective corporate groups, under their privacy policies.

Publication of the app for users in Germany is carried out on behalf of and under the responsibility of Red Azul LLC as the listed publisher in each store.

• Apple: apple.com/legal/privacy
• Google: policies.google.com/privacy

We do not receive full access to your Apple or Google store account credentials.

We use technical service providers (hosting, including Cloudflare; potentially build/submission tooling; Google AdSense for the web app; Google AdMob for the mobile free tier where ads are shown; Google Analytics / GA4 for consent-gated app usage analytics and, where enabled, marketing-site measurement via gtag). We enter data processing agreements under Article 28 GDPR where required.

Build pipelines (for example Expo Application Services) typically process project/build metadata rather than your personal learning history stored locally in the app.

Red Azul LLC is established in the United States. If you access our services from the EU/EEA/UK, transfers to the US may occur.

Where we transfer personal data to the US via processors, we implement appropriate safeguards under Article 46 GDPR (including Standard Contractual Clauses) when required.

Access by US authorities cannot be fully ruled out. You may lodge a complaint with a supervisory authority (Section 16).

We retain information only as long as necessary for the purposes described or as required by law. On-device app data is controlled by you on your device.

Subject to applicable law, you may have the right to:

• Access (Article 15 GDPR)
• Rectification (Article 16 GDPR)
• Erasure (Article 17 GDPR)
• Restriction (Article 18 GDPR)
• Data portability (Article 20 GDPR)
• Object to certain processing (Article 21 GDPR)
• Withdraw consent where processing is consent-based (Article 7(3) GDPR)

To exercise rights, contact us using the routes in Section 2. For erasure of app data, see also Data deletion.

You have the right to lodge a complaint with a supervisory authority, in particular in the EU/EEA member state of your habitual residence, place of work, or place of the alleged infringement.

For Germany, you may contact your state data protection authority or the Federal Commissioner for Data Protection and Freedom of Information (BfDI); see bfdi.bund.de.

You can generally browse the website without actively submitting personal data. Contact form fields marked as required are necessary to process your message.

The app does not require creating an account with us.

The app is not directed at children under 13, and we do not knowingly collect personal information from children in that age group in a centralized account system.

We may update this Privacy Policy to reflect legal, technical, or product changes. The “Last updated” date at the top indicates the current version.

Store listing URL: you may reference https://red-azul.com/legal/privacy alongside the German page for App Store / Google Play disclosures.