Privacy Policy
This policy explains which personal data we process when you use uscitizenshiptrainer.com, the US Citizenship Test Trainer (a product by Even Keel Studio). In short: we log every visit with your full IP address, your browser and your clicks, and delete this log after 14 days. The name and email address you enter at checkout are also kept for 14 days. We do not collect or store card numbers, expiry dates or security codes; they never leave your browser. Google ads measurement and personalized advertising only run if you agree.
1. Controller
Digital Service GmbH
Seestraße 16
71638 Ludwigsburg
Germany
Email: info@online-infektionsschutzbelehrung.de
Represented by its managing director, Thomas Andreas Mücke. See also our imprint. Because we are based in Germany, the EU General Data Protection Regulation (GDPR) applies to this website.
2. Hosting and server logs
This website runs on a server we rent from netcup GmbH (Karlsruhe, Germany). When pages are requested, the web server writes entries to its access log: your IP address, date and time, the requested address, the status code, the amount of data transferred, the previously visited page and your browser’s identification (user agent). Technical errors can also create an entry in the error log, which may contain the IP address.
We need these logs to deliver the website, find errors and fend off attacks. The legal basis is our legitimate interest in a secure, working website (Art. 6(1)(f) GDPR). The logs are deleted after 14 days at the latest.
3. Our own visit and click log (no cookies)
In addition to the server log, we keep our own log of how the website is used. It runs for every visitor, without consent and without cookies. When a page is requested, our server writes an entry. In addition, a small script in your browser sends messages to our server: when the page opens, when you leave or hide the page, and when you click buttons and links. For this, the script reads the information listed below from your browser. Without JavaScript, this information is not sent.
We store:
- time and type of the event (page request, visit, dwell time, click, click on an order button, checkout opened, step 1 sent, step 2 shown, payment method chosen, click on the pay button, checkout left),
- your full IP address,
- your browser’s identification (user agent) and, derived from it, browser and device type,
- the language and time zone your browser reports,
- screen and window size,
- the previously visited page (referrer), if your browser sends it,
- the requested address with all parameters, including click IDs from Google ads (gclid, gbraid, wbraid) and campaign values (utm parameters),
- a session ID that our server calculates from IP address, user agent and date and that changes daily,
- a random ID of the single page view, held only in your browser’s memory while the page is open,
- dwell time and scroll depth,
- which buttons and links you click, with their position on the page,
- a flag whether our server classifies the request as automated or as our own test,
- at checkout: the payment method you chose, whether the card fields were completed (yes or no), how long you worked on the form, which field you last used, and, if your input was incomplete, the names of the affected fields. The content of the card fields is never part of this log.
This log stores nothing on your device.
The purpose is to measure demand for the trainer, to see which advertising and which content lead to it, to improve the website and to recognize automated requests. The legal basis is our legitimate interest in these purposes (Art. 6(1)(f) GDPR). You can object to this processing at any time on grounds relating to your particular situation (section 9).
The log is stored on the same server, outside the publicly accessible area. Each daily file is deleted after 14 days.
3b. The Even Keel Studio visit count (no cookies)
The trainer is a product of Even Keel Studio. Like every Even Keel Studio product page, this website also sends a short message to the Even Keel Studio visit counter on our server at evenkeelstudio.com when you open the main page and when you click an order button. That counter stores the type of event (page view or button click) and the product page, the position of the button, the date and time, the domain of the website that referred you (if your browser shares it), your browser’s preferred language (for example “en-CA”) and whether you use a mobile or desktop device, a country code only if our web server derives one from your IP address at the moment of the request (the IP address itself is not stored with it), and, if you arrived through one of our Google ads, the click ID that Google adds to the web address (gclid). To keep that click ID when you move on to the checkout, your browser holds it in its session storage until you close the tab.
This counter does not store your IP address and does not set cookies. The click ID is removed after 90 days. The legal basis is our legitimate interest in measuring demand for our products (Art. 6(1)(f) GDPR); you can object under section 9.
3a. Your details at checkout
When you enter your full name and email address in step 1 of the checkout and select “Continue to payment”, we store this information together with the place you came to the checkout from, how long you worked on the form, the random ID of the page view, how it was sent (with or without JavaScript), the automated or test flag, and time, IP address, user agent, browser language and session ID. Through the session ID and the page view ID, these details can be linked to your visit log from section 3, including the requested address with any ad click ID, your screen size and your clicks.
In step 2 we record the payment method you choose (card or PayPal) and whether the card fields were completed. We do not collect or store card numbers, expiry dates or security codes; they never leave your browser. The card fields are checked for completeness inside your browser only. The same applies to the country and postal code entered with the card.
The purpose is to process your order, that is, steps prior to a possible contract that you start by sending the form. The legal basis is Art. 6(1)(b) GDPR. At the moment, no order is completed through the checkout: you then see the message shown on the page, and you are not charged. We also evaluate the stored entries to measure demand for the trainer and to see which payment methods are wanted. The legal basis for this is our legitimate interest in this evaluation (Art. 6(1)(f) GDPR); you can object to it under section 9.
The entries are kept in a separate daily file on our server, outside the publicly accessible area. They are not passed to Google or any other recipient. We do not send anything to these email addresses automatically. Each daily file is deleted after 14 days. To limit mass requests, we count per IP address and day how often the form was sent; for this we store only a value calculated from the address and delete it the next day. From 20 entries per IP address and day, we store no further entries.
4. Google Ads: conversion measurement, remarketing and personalized advertising (only with your consent)
When we advertise the trainer on Google, we want to measure which ads lead to clicks on an order button that opens the checkout. While we use this service, a banner appears on your first visit. Measurement is off by default. Only when you choose “Accept” does your browser load the Google tag (gtag.js) from Google’s servers. Google then sets cookies on your device, creates entries in your browser’s local storage (_gcl_ls, containing the ad click ID, for up to 90 days) and receives information such as your IP address, the page visited, the ad click ID and the fact that an order button was clicked. Google does not receive what you enter at checkout.
With your consent, we also use the service for remarketing and personalized advertising: Google can add you to audience lists based on these cookies and data, so that we can show you ads for the trainer on Google and on Google’s partner sites. Google determines how long it keeps the data. If there is no “Cookie settings” link at the bottom of the page, the service is not active.
The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Data may be transferred to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework, for which the European Commission adopted an adequacy decision on July 10, 2023 (Art. 45 GDPR). More on how Google uses data: policies.google.com/privacy.
The legal basis is your consent (Art. 6(1)(a) GDPR and § 25(1) of the German Telecommunications Digital Services Data Protection Act, TDDDG). You can withdraw it at any time with effect for the future, using “Cookie settings” at the bottom of every page. When you withdraw, the page removes these cookies and entries from your device. If you decline, Google receives nothing from us; our own log from section 3 continues.
We remember your choice in your browser’s local storage under the key “ek-consent” (the same key the Even Keel Studio pages use), so that we don’t ask on every page. Personalized advertising and remarketing for the trainer only run once you accept the banner on this website, which we note under the key “uct-remarketing”. Storing these choices is necessary to respect them (§ 25(2) no. 2 TDDDG).
5. Fonts
All fonts are hosted on our own server. Your browser does not connect to a font provider.
6. Contact by email
If you write to us, we process your email address and your message to reply to you (Art. 6(1)(b) or (f) GDPR). We delete them once your request is settled, unless a statutory retention obligation applies.
7. Recipients
Apart from our hosting provider (section 2) and, only with your consent, Google (section 4), we do not pass on your data unless we are legally obliged to.
8. Obligation to provide data
You are not legally or contractually obliged to provide data. We need the required fields of the checkout to process an order; without them the checkout cannot be sent. Without your IP address, the website cannot be delivered. The information sent by the script is not sent if you turn off JavaScript; the content of the website remains readable.
9. Your rights
Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to withdraw consent (Art. 7(3)). Where we rely on legitimate interests, you can object on grounds relating to your particular situation (Art. 21). Write to info@online-infektionsschutzbelehrung.de.
You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is the State Commissioner for Data Protection and Freedom of Information Baden-Württemberg (Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg), Heilbronner Straße 35, 70191 Stuttgart, Germany.
10. No automated decisions
We do not make automated decisions within the meaning of Art. 22 GDPR. The audience lists from section 4 are only created with your consent and only decide which ads you see.