Privacy Policy

When you create an account, we receive and store:

• Your name
• Your email address
• Your account ID at Google, Facebook or Apple, if you sign in with one of them
• A hashed copy of your password, if you sign up with your email address and a password

A hashed copy is a code made from your password. It cannot be turned back into your password.

Inburgering.org, DeutschPass.org and Pamellinika.gr share one account system. If you sign in on more than one of these websites with the same email address, you have one account for all of them. We store that account's data together.

As you use the Service, we collect:

• Exercise progress and scores
• Course completion status
• Time spent on exercises
• Your answers to writing and speaking exercises: the text you type, your voice recordings, and the text made from your recordings
• Your answers in the ONA (Orientation on the Dutch Labour Market) portfolio, such as your desired profession, your work and education history, and practice texts like a CV or an application letter
• AI feedback and scores on your answers, including an analysis of your pronunciation and a review of your ONA portfolio
• Page views and navigation patterns
• Session duration and frequency

We do not store your voice recordings ourselves. We send them to the companies in section 5.1 to make a transcript and give feedback.

If you try exercises or the free level test without an account, we send your answers to the companies in section 5.1 for feedback in the same way. These answers are not linked to an account.

We automatically collect:

• IP address
• Browser type and version
• Device type
• Operating system
• Referring website
• Analytics and session identifiers that we create ourselves
• Your cookie preferences
• Advertising click identifiers, if the link you followed carries one: Google Click ID (GCLID), Microsoft Click ID (MSCLKID) or Facebook Click ID (FBCLID)

When you make a purchase, we store payment and subscription records needed to provide the Service, including payment ID, amount, currency, purchased course or bundle, billing period, payment method, transaction status, and purchase date.

If you buy a course as a gift, we also store the email address of the person who receives it. We need it to send them the gift.

If you consent to advertising measurement, we may also use purchase details, advertising click identifiers, and a hashed copy of your email address to measure conversions in Google Ads and Microsoft Advertising. We send Google Ads the hashed copy only, never your email address itself.

We store your cookie and measurement consent choice in your browser, together with the date you made it, so that we can respect your choice.

When you use our forums, we collect:

• Your forum nickname
• Your posts and comments
• The names and descriptions of groups you create
• Moderation decisions about your posts, comments, groups and nickname

AI checks this content for us. It flags content for us to review. It removes posts and comments that contain child sexual abuse material on its own, without a person checking first.

When you contact us or use our Telegram bot, we collect:

• Emails you send to our support address, and our replies
• Messages you send us on WhatsApp, and your phone number
• Your Telegram user ID and your settings in our Telegram bot
• Messages and voice messages you send to our Telegram bot
• The link between your Telegram account and your account with us, if you connect them

These companies process your data for us, so that we can run the Service:

• Vercel (website hosting): every request your browser or app sends to us, including your IP address and browser details. Vercel runs the code behind our website and app on servers in London (United Kingdom) and Frankfurt (Germany).
• DigitalOcean (database and server hosting): all the data we store about you, such as your account, payments, learning progress, forum posts and support messages. DigitalOcean also runs our Telegram bot.
• Mollie (payments): your name, email address and user ID, the amount, the course you buy, any promotion code or referral discount you use, and the advertising click identifiers from your visit, if there are any. Mollie uses this data to process your payments. Mollie collects your card or bank details itself.
• OpenAI (AI feedback): the text you type in writing exercises, the text made from your spoken answers, your voice recordings, your ONA portfolio answers, and the answers you send to our Telegram bot. OpenAI scores your answers, analyzes your pronunciation, gives feedback, and reviews your portfolio.
• OpenAI (forum moderation and translation): your forum posts and comments, the names and descriptions of groups you create, and your nickname. OpenAI checks this content against our community rules and translates posts and comments into other languages.
• Google (speech-to-text): your voice recordings from speaking exercises on the website and in the app. Google's Gemini service turns your speech into text.
• ElevenLabs (speech-to-text): your voice recordings from speaking exercises in our Telegram bot, and from speaking exercises on the website and in the app when Google does not turn them into text. ElevenLabs turns your speech into text.
• Postmark (email delivery): your email address, your name and the content of each email we send you, such as receipts, payment reminders and password-reset links. Postmark also delivers the gift email to the person who receives a gift.
• Google (Gmail): the emails you send to our support address and our replies, with your name and email address. We use Gmail to receive and answer support emails.
• Sentry (error monitoring): error reports from our website and app. A report contains technical data, such as your browser type and the page you were on, and can contain your user ID or email address. We use Sentry to find and fix errors.
• Trustpilot (reviews): if you are a subscriber, your email address and a copy of one check-in email, which includes the name on your account. Trustpilot uses them to invite you to review us. We send the check-in email once, to subscribers whose subscription is active and started at least 7 days ago, and who have completed at least 10 exercises.

We send your answers and recordings to OpenAI, Google's Gemini service and ElevenLabs without your name, email address or user ID. Before we send your ONA portfolio, we remove email addresses, phone numbers, postcodes and street addresses from it. Your answers and posts can still identify you, for example when they contain your name.

OpenAI, Google's Gemini service and ElevenLabs may keep a copy of what we send them for a limited time under their own terms, for example to check for abuse. Deleting your account does not delete these copies straight away.

These advertising platforms receive purchase data, so that we can measure which of our ads lead to purchases:

• Google Ads: after you buy a course or make a payment, the time, value and currency of the purchase, the order ID, a hashed copy of your email address, and the Google Click ID if you came from a Google ad.
• Microsoft Advertising: after your first purchase, if you came from a Microsoft Bing ad, the time, value and currency of the purchase, the order ID, a hashed copy of your email address, and the Microsoft Click ID.

A hashed copy is a code made from your email address. We send the hashed copy only, never your email address itself. If you have an account with the platform, the platform can use the code to recognize you and link the purchase to the ad you saw.

When you use these companies' services together with ours, they receive your data and use it under their own privacy policies:

• Google, Facebook and Apple (sign-in): if you sign in with one of them, that company confirms who you are and sends us your account ID, name and email address. That company also learns that you use the Service.
• Apple (App Store): if you buy a subscription in our iOS app, Apple handles the payment and sends us the transaction details.
• Google Pay: if you pay with Google Pay, Google receives your payment request and your browser details.
• Telegram: if you use our Telegram bot or join our Telegram groups, Telegram receives your messages, including voice messages.
• WhatsApp: if you message us on WhatsApp, WhatsApp receives your phone number, your name and your messages.

Some pages load files from these companies' servers:

• Bunny.net: course images and audio
• Google Fonts: a font, only on the page we show when the website has an error

When a page loads one of these files, your browser sends your IP address and browser details to the company that stores it.

If you do not pay an amount you owe us, we may pass your case to a debt-collection agency. The agency then receives your name, your email address, the amount you owe and your payment history.