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Inburgering.org

Privacy Policy

Last updated: May 4, 2026

1. Data Controller

The data controller for your personal data is:

kirilof (eenmanszaak)

Vaartweg 17-4, 1211 JD Hilversum, Netherlands

Email: info@inburgering.org

2. What Data We Collect

2.1 Account Data

When you create an account via Google or Facebook, we receive and store:

  • Your name
  • Your email address
  • Your profile picture (if provided by the authentication provider)

2.2 Usage Data

As you use the Service, we collect:

  • Exercise progress and scores
  • Course completion status
  • Time spent on exercises
  • Writing and speaking exercise submissions (for AI feedback)
  • Page views and navigation patterns
  • Session duration and frequency

2.3 Technical Data

We automatically collect:

  • IP address
  • Browser type and version
  • Device type
  • Operating system
  • Referring website
  • First-party analytics identifiers, session identifiers, cookie preferences, and advertising click identifiers such as Google Click ID (GCLID) when present in the URL

2.4 Payment and Conversion Measurement Data

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 consent to advertising measurement, we may also use purchase details, advertising click identifiers, and a hashed version of your email address to measure Google Ads conversions. We do not send your raw email address to Google Ads for this purpose.

2.5 Consent Preferences

We store your cookie and measurement consent preferences, including when you gave or changed consent, so that we can respect your choices and maintain consent records.

3. How We Use Your Data

We use your personal data for the following purposes:

  • Providing and maintaining the Service, including your account and subscription
  • Processing your payments through Mollie
  • Generating AI-powered feedback on your writing and speaking exercises
  • Tracking your learning progress and displaying it to you
  • Analyzing usage patterns to improve the Service using our own first-party analytics
  • Measuring the effectiveness of our advertising, where you consent to advertising measurement
  • Communicating with you about your account, subscription, or service changes
  • Complying with legal obligations

4. Legal Basis for Processing (GDPR)

We process your personal data on the following legal bases:

  • Contract performance: Processing necessary to provide the Service you subscribed to (account management, exercise delivery, progress tracking, and payment handling)
  • Legitimate interest: Service security, fraud prevention, and basic operational analytics that do not require consent
  • Legal obligation: Retaining financial records as required by Dutch tax law
  • Consent: Optional analytics cookies, advertising measurement, Google Ads enhanced conversion measurement, and optional communications where required

5. Data Sharing

We share your personal data with the following third parties only as necessary:

  • Mollie (payment processing) — receives your payment details to process transactions
  • AI service providers (such as OpenAI or Anthropic) — receive your writing and speaking exercise submissions to generate feedback. These submissions do not include your name or email.
  • Google and Facebook — authentication providers used for account login
  • Google Ads — when you consent to advertising measurement, receives offline conversion measurement data such as conversion time, conversion value, currency, order ID, Google Click ID where available, and hashed first-party email for enhanced conversion measurement
  • Hosting provider — our website is hosted on infrastructure that processes your data to serve the Service

We do not sell your personal data to any third party. We do not share your personal data with third-party advertisers for their own advertising or targeting.

6. Data Retention

We retain your data as follows:

  • Account data: For as long as your account is active, and up to 12 months after account deletion
  • Usage and progress data: For as long as your account is active
  • Exercise submissions: For as long as your account is active (deleted upon account deletion)
  • Payment records: 7 years after the transaction, as required by Dutch tax law
  • Technical, analytics, and advertising measurement data: Up to 12 months

7. Your Rights (GDPR)

Under the General Data Protection Regulation (GDPR), you have the following rights:

  • Right of access: Request a copy of the personal data we hold about you
  • Right to rectification: Request correction of inaccurate personal data
  • Right to erasure: Request deletion of your personal data ("right to be forgotten")
  • Right to restriction: Request that we limit how we use your data
  • Right to data portability: Request your data in a structured, machine-readable format
  • Right to object: Object to processing based on legitimate interest
  • Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, contact us at info@inburgering.org. We will respond within 30 days.

8. Cookies

We use essential cookies that are strictly necessary for the Service to function, including:

  • Authentication cookies to keep you logged in
  • Session cookies to maintain your browsing session

With your consent, we may also use first-party analytics and advertising measurement cookies or local storage to remember device and session identifiers, cookie preferences, campaign parameters, and advertising click identifiers such as GCLID. These help us understand how people use the Service and measure purchases from our ads.

We do not use third-party advertising cookies for ad targeting. You can withdraw optional analytics or advertising measurement consent at any time.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encrypted data transmission (HTTPS/TLS)
  • Secure authentication via Google and Facebook OAuth
  • Payment processing handled entirely by Mollie — we do not store payment card details

While we take reasonable precautions, no method of electronic transmission or storage is 100% secure.

10. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), specifically when your exercise submissions are sent to AI service providers for feedback.

Where such transfers occur, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or the service provider's participation in an approved data transfer mechanism.

11. Children's Privacy

The Service is not specifically directed at children. We do not knowingly collect personal data from children under 16 without parental consent. If you believe a child under 16 has provided personal data to us without appropriate consent, please contact us at info@inburgering.org, and we will take steps to delete that data.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes via email. The "Last updated" date at the top of this page indicates when the policy was last revised.

13. Supervisory Authority

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

Website: https://autoriteitpersoonsgegevens.nl

Phone: +31 (0)70 888 85 00

14. Contact

For any questions about this Privacy Policy or your personal data, contact us at:

Email: info@inburgering.org