Privacy Policy

1. Data Controller and Contact

This privacy policy explains how your data is processed when you use the ZertifikatsFuchs platform, under Turkey's Personal Data Protection Law No. 6698 ("KVKK").

Data controller: Hüseyin Beraat Çayıroğlu (the individual who runs ZertifikatsFuchs)
Email: iletisim@zertifikatsfuchs.com.tr
You can write to this address with questions about privacy or use the form on our contact page. When ZertifikatsFuchs becomes part of a company, the data controller details in this section will be updated.

2. What Data We Process

We process the data needed to run ZertifikatsFuchs:

• Account details: when you sign up: your name, email address and an irreversibly encrypted (hashed) form of your password. Your password is never stored in plain text. If you sign in with "Continue with Google", we receive only your name and the email address verified by Google; in that case no password is stored and we never see your Google account password.
• Learning progress: the topics you have completed, your exam results, practice results, streak, which steps of the daily plan on the home page you finished on which day, the learning goal you chose (an exam, life in Germany or for yourself), your level and the review schedule of the questions you got wrong in Practice. If you use the site without an account, this data is kept only in your browser (localStorage) and is not sent to us. When you open an account, it is also stored in the database on our server so it can be synced across devices.
• Membership status: whether your account is free, Pro or on a time-limited Pro trial (launch offer), and when the trial ends.
• Contact messages: your name, email address and message when you use the contact form, as well as our replies to you.
• Waiting list: your email address, when you use the "Notify me when Pro opens" box.
• Technical and security data: the biscuit needed to keep you signed in; records containing the IP address and time stamp to prevent misuse (for example many sign-in attempts), deleted automatically within 24 hours; server access logs kept by the hosting provider.
• Visit statistics: biscuit-free statistics showing in aggregate which pages, which sources (for example a social media link) and which countries/device types visitors come from.
• Local settings: your light/dark theme preference and audio playback speed are stored only in your browser and are not sent to us.

The voice recordings you make in the speaking exercises are processed only on your device; they are not sent to or stored on our servers.

3. Purposes and Legal Grounds of Processing

We process your data only for the following purposes, on the grounds listed in Art. 5 KVKK:

• Providing your account, the learning platform and Pro membership (including the trial period); sending account verification and password reset emails — conclusion and performance of the contract (KVKK Art. 5/2-c)
• Saving and syncing your learning progress — performance of the contract (Art. 5/2-c)
• Replying to contact requests — legitimate interest of the data controller (Art. 5/2-f)
• Informing people on the waiting list when Pro membership opens — your explicit consent, as you requested this notification yourself (Art. 5/1). You can withdraw your consent at any time and ask to be removed from the list.
• Ensuring the technical security of the platform, preventing misuse and fixing errors — legitimate interest (Art. 5/2-f)

We don't send marketing or advertising emails without your knowledge.

4. Biscuits and Local Storage

After you sign in, ZertifikatsFuchs uses a technically necessary session biscuit to keep you signed in. This biscuit is not used for advertising or tracking. Apart from that, the site stores some information in your browser's localStorage (learning progress when used without an account, theme preference, audio speed). The tool we use for visit statistics (Vercel Web Analytics) sets no biscuits and does not identify you personally. When you come from one of our short links on social media (e.g. /ig), a biscuit containing only that day's date is set and deleted after 24 hours, so that the same click is not counted twice in a day; this biscuit contains no information that identifies you.

5. Service Providers and Transfers Abroad

We do not sell your data or share it with third parties for marketing purposes. To provide the service, we work with the service providers below. These providers are based abroad; your data is therefore transferred abroad within the meaning of Art. 9 KVKK:

• Vercel Inc. (USA): hosting of the site and visit statistics. Server processing runs in the Frankfurt (Germany) region.
• Neon (based in the USA): the database where account and progress data are stored. The data is kept on servers in the Frankfurt (Germany) region.
• Resend (USA): sending account verification, password reset and contact reply emails (name and email address).
• Google LLC (USA): verification of your sign-in, only if you use the "Continue with Google" option. Google processes the information that you signed in according to its own privacy policy.

We are completing the steps needed to base these transfers on the safeguards provided for in Art. 9 KVKK (e.g. standard contracts). Apart from this, data may only be shared with the competent authorities where required by law.

The audio for the reading and listening texts on the site was generated in advance with Google's Gemini service; none of your personal data is used for this.

6. Payment

The payment system for the paid Pro membership is not active yet. When it goes live, a licensed payment service provider will be used; your card details will be processed only by this provider and will not pass through our servers. This section will be updated at that time.

7. Retention Period

• Account and progress data: as long as your account is open.
• When you delete your account: your account details and learning progress are deleted from the database immediately.
• Contact messages: a reasonable time after your request has been resolved, at most 2 years.
• Waiting list: until we have informed you that Pro membership has opened, or until you ask to be removed.
• IP records for security purposes: no more than 24 hours.

8. Your Rights under the KVKK

Under Art. 11 KVKK you have the following rights:

• Find out whether your personal data is being processed
• Request information about it if it has been processed
• Find out the purpose of processing and whether the data is used in line with it
• Know the third parties in Turkey or abroad to whom your data is transferred
• Request correction if it has been processed incompletely or incorrectly
• Request deletion or destruction under the conditions set out in the KVKK
• Object to a result against you that arises from your data being analysed exclusively by automated systems
• Claim compensation if you suffer damage because of unlawful processing

You can download your data or delete your account at any time from your account page. For other requests, write to iletisim@zertifikatsfuchs.com.tr; we reply within 30 days at the latest.

9. Changes to This Policy

We update this privacy policy whenever the way we process data changes (for example when the payment system goes live). The current version is always on this page.