Onboard App - Privacy Policy

Last updated: 19.01.26

1. Controller and Contact

Takacs Peter Zoltan
Sasvari 46, 8000 Szekesfehervar, Hungary
Email: info@onboardapp.de / info@onboardapp.at / info@onboard.hu

2. Target Countries

The Service is intended for users located in Austria (AT), Germany (DE), and Hungary (HU).

3. What Data We Process

Depending on the features you use, we may process account and registration data (such as name if provided, email address, and a securely stored password), optional social login data (Apple/Google/Facebook; such as name and email or an Apple relay/alias), usage and learning/progress data (progress, results, interactions), device and technical data (device type, OS/app version, language, date/time of access, IP address in server logs, and technical identifiers needed to operate the Service), a push notification token if you enable notifications, diagnostics and crash data (e.g., via Firebase Crashlytics, typically pseudonymized/aggregated), purchase/subscription confirmations from Apple/Google (we do not receive full payment card details), and support communications when you contact us.

The App does not require GPS location services and we do not intentionally process special categories of data under Art. 9 GDPR (e.g., health data).

4. Purposes of Processing

We process data to provide the App and its functions, manage authentication and accounts (including social logins), store and display learning progress, communicate with you (support and service notices), send push notifications if you enable them, verify purchases/subscriptions and unlock paid features, operate, secure, and improve the Service (diagnostics, stability, abuse prevention), comply with legal obligations, and defend legal claims.

5. Legal Bases (GDPR)

We rely on contract performance (Art. 6(1)(b)) for core app features, consent (Art. 6(1)(a)) for optional functions like push notifications, legitimate interests (Art. 6(1)(f)) for security, abuse prevention and diagnostics/improvement, and legal obligation (Art. 6(1)(c)) for required retention duties.

6. Sharing / Recipients

We do not sell personal data. We share data only as necessary, including with Apple/Google (for app downloads and purchase processing, as independent controllers), social login providers (Apple/Google/Meta if you choose social login), and service providers acting as processors (e.g., Google Firebase and Crashlytics) under appropriate terms. We may also share data with authorities or legal parties where required by law or needed to protect rights and prevent abuse.

7. International Transfers

If data is processed outside the EU/EEA, we use GDPR safeguards (e.g., Standard Contractual Clauses and other measures where applicable).

8. Retention

We store data only as long as necessary: account data for the lifetime of the account (deleted upon account deletion unless legal retention applies), learning/progress data typically as long as you use the App (deleted/anonymized after account deletion where possible), support communications as long as needed to handle the request plus a reasonable follow-up period, transaction/subscription records as required by tax/accounting laws (often 6–10 years), and server logs typically for weeks (longer if needed for security incidents).

9. Security

We implement reasonable safeguards (encryption where possible, access control, least privilege, secure authentication). No system can be guaranteed 100% secure.

10. Your Rights

Under GDPR and applicable local laws, you may have rights to access, rectification, deletion, restriction, portability, objection (for legitimate-interest processing), withdrawal of consent, and complaint to a supervisory authority. To exercise rights, email info@onboardapp.de (or app@onboard.hu) and include enough information to identify your account.

Supervisory authority reference: NAIH (Hungary) - naih.hu. You may also contact your local authority in AT/DE.

11. Updates to this Policy

We may update this Privacy Policy. The current version is available in the App and/or on our website.

12. Website Cookies

We use cookies on our website(s). Cookies are small text files stored in your browser. We may use essential/session cookies (for navigation and login/session), analytics/performance cookies (e.g., Google Analytics), functional cookies (preferences such as language), and marketing/targeting cookies. Where required by law, we ask for consent for non-essential cookies. You can manage and delete cookies via your browser settings; disabling cookies may reduce website functionality.