Privacy Policy
Theorie-Tutor KI (“the App”) is an on-device German driving-theory study coach (class B style practice). There is no account, no ads and no analytics we run. This policy mirrors the data flows in main commit c56760f.
1. Controller
Publisher of “Theorie-Tutor KI”. Privacy contact: merkzettel@kurvenlicht.studio.
2. What stays on your device
- Practice content: bundled demo questions plus your attempts, weak topics, explanations and learning records in local JSON under Application Support.
- Sign / textbook photos under
photo-notes/. Pixels are analysed with Apple on-device Vision (OCR + image labels) and are not uploaded. - Study-card exports may be saved to Photos (add-only) after permission; receipts stay local.
- AI consent in
ai-consent.json(toggle “Cloud-Erklärungen erlauben”). - Read-aloud uses on-device
AVSpeechSynthesizer(de-DE). No cloud TTS.
3. What may leave after consent
| Service | Data | Purpose |
|---|---|---|
| DeepSeek api.deepseek.com People's Republic of China model deepseek-flash |
Text prompts only: question stem and choices, correct-answer index, topic tag, weak-topic summaries and short prior outcomes; OCR text and image labels from a sign photo (no pixels); transcript of a spoken answer. The App does not send photo pixels or raw mic audio to DeepSeek. | Theory explanations, sign rules, spoken-answer scoring |
| Apple Speech Recognition | Microphone audio of your spoken answer. The App does not set requiresOnDeviceRecognition, so Apple may process audio on its servers. |
Speech → text before an optional DeepSeek call |
Without consent, local practice continues; cloud coaching does not start. Withdraw anytime in Settings. Legal basis: Art. 6(1)(a) GDPR. Do not enter special-category data (Art. 9) in free text.
4. International transfers
DeepSeek processes data in China (no EU adequacy decision). Transfers rely on your explicit consent (Art. 49(1)(a) GDPR), with risks of government access and fewer remedies.
5. Permissions
- Camera – photograph signs or textbook pages
- Microphone & speech recognition – spoken answers
- Photo library (add only) – save study cards
- Local notifications – optional study reminders
6. Retention and deletion
Local data remains until you remove individual history items, revoke consent, or uninstall. There is no in-app “wipe everything” control. DeepSeek and Apple keep their own retention rules.
7. Your rights
Access, rectification, erasure, restriction, portability, objection and withdrawal (Art. 15–21 GDPR), and the right to lodge a complaint with a supervisory authority.
8. Children
Intended for users 16+ (or the age at which theory training is allowed where you live).
9. Privacy Nutrition Label
Bundled PrivacyInfo.xcprivacy currently declares no collected data types even though text may go to DeepSeek and speech audio may leave the device via Apple. The developer should update the nutrition labels.
10. Changes
We update this page and the date above when features change.