Privacy Policy
red-azul.com · mobile app Road to Germany (naturalization test prep)
Last updated: May 9, 2026 · Controller: Red Azul LLC, United States
1. Introduction and scope
This Privacy Policy explains how Red Azul LLC (“Red Azul”, “we”, “us”) processes personal data when you visit our website at 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.
2. Controller, app publisher, and contact
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: via the contact form at red-azul.com/contact.html and the official Red Azul social channels linked there, including for privacy requests and exercising your data subject rights.
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.
3. Website hosting and server logs
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.
4. Contact form and business inquiries
If you submit our contact form, we process the information you provide (such as name, email address, and message content) to respond to your inquiry.
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.
Transmission uses HTTPS where supported by your browser.
5. Cookies and similar technologies (website)
Our website may use cookies or similar technologies. Strictly necessary cookies may be used to deliver core functionality.
Non-essential cookies or analytics should only be used based on consent where required by law (typically via a consent banner). For users in Germany, Section 25 TTDSG applies where relevant to storing information on devices or accessing information stored there.
Legal basis: Article 6(1)(f) GDPR for strictly necessary cookies; Article 6(1)(a) GDPR for optional cookies; Section 25 TTDSG where applicable.
Note: this static site may operate without cookies—update this section if you add analytics or marketing tools.
6. Mobile app “Road to Germany” — overview
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.
7. App — what data is processed and where?
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.
8. App — local notifications
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.
9. App — optional online content (YouTube, network images)
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.
10. Question catalog, licensing notices, third-party materials
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.
11. Apple App Store and Google Play (including Germany)
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.
12. Recipients and processors
We use technical service providers (hosting; potentially build/submission tooling). 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.
13. International transfers (United States)
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).
14. Retention
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.
15. Your rights
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.
16. Right to lodge a complaint
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.
17. Are you required to provide data?
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.
18. Children
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.
19. Changes
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.html alongside the German page for App Store / Google Play disclosures.