Privacy policy

Medborgarskapspro is a private learning service that helps people prepare for the Swedish citizenship test. It is offered as a mobile and web app and through this website. Medborgarskapspro is not affiliated with, authorised, approved or sponsored by, or acting on behalf of the Swedish Council for Higher Education (UHR), the Swedish Migration Agency (Migrationsverket) or any other Swedish authority. The app contains no official test questions.

The controller is Ott & Stadler Group KLG (Swiss general partnership, Kollektivgesellschaft), Rosgartenstrasse 26, 8280 Kreuzlingen, Switzerland, Swiss business identification number (UID) CHE-452.933.007. The partners of the company are Tobias Stadler and Maximilian Ott. We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the supplementary Swedish legislation, mainly the Swedish Data Protection Act (2018:218). As we are based in Switzerland, the Swiss Federal Act on Data Protection (FADP) also applies.

Contact for all questions and requests about personal data: citizenprosupport@gmail.com. We have no data protection officer, as we are not required to appoint one.

Data you submit on this website, for example an Early Access signup, is stored in Google Cloud Firestore in Stockholm (europe-north2) where the service is available, otherwise in Finland (europe-north1). Current region of the website database: Stockholm, Sweden. The app's data is also stored with Google Firebase in Stockholm or Finland.

The website's web server (Firebase Hosting with Cloud Functions) runs at Google in Finland (europe-north1), because Firebase Hosting offers no region in Sweden for this type of server. Forms on the website are sent through that server to the database in Stockholm or Finland. The function that deletes app data when an account is deleted runs at Google in Frankfurt (europe-west3), because this type of function is not available in Stockholm or Finland. The data itself stays in the database in Stockholm or Finland.

Our controller is located in Switzerland and accesses the data from there. The European Commission has decided that Switzerland ensures an adequate level of protection for personal data, so the transfer to Switzerland requires no additional safeguards. Some of our providers process data in the United States, see the section on transfers to third countries.

The website requires no account and does not collect the app's account data. We only collect the following personal data, and only in the situations described here:

Early Access signup: the email address you enter and the context described in the next section. Technical server data: your IP address, the time, the requested page and your browser type, which our hosting provider records in server logs to operate and protect the website. Contact by email or through the contact form: what you send us, and in the form your first and last name, your email address and your message. Messages from the form reach us through our email provider and are not stored on the website. We keep them in our inbox only as long as needed to reply to you and delete them on request.

The website uses no advertising cookies, shows no advertising, does not sell or rent out any data and creates no visitor profiles. We use no analytics tools and do not measure how visitors use the website.

If you sign up for Early Access on our website, we collect your email address, the time of your signup and limited technical context that helps us understand where signups come from and prevent abuse: your browser language, the page you came from, the page you signed up on and your browser type.

We use your email address only to reserve your free Premium access, to manage the Early Access list (including a counter and a check that an address is not entered twice) and to tell you when the app is available. We do not send a confirmation email, we do not use the address for advertising and we do not sell it.

Your signup is stored in Google Cloud Firestore (see above) and delivered to us by email through our email provider Resend, whose servers are located in the United States. To limit repeated or automated signup attempts, we also process your IP address temporarily in the server's memory. We do not store it.

The legal basis is your consent under Article 6(1)(a) GDPR, which you give by submitting the form after reading the information below it. You can withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing before the withdrawal. We keep Early Access addresses until the launch notification has been sent and for 12 months afterwards, or until you ask us to delete your address, whichever comes first. Write to the contact address to withdraw or delete your signup. As an outer limit, each signup is deleted automatically after 24 months.

The website stores a few things on your own device that never leave it: your choice in the cookie banner and the items you have ticked in the checklists in the resource centre. We use this so that the website works the way you have set it up.

The website sets no advertising cookies or cookies for cross-site tracking. As we only use what is necessary for the website to work, no consent is required under Chapter 9, Section 28 of the Swedish Electronic Communications Act (2022:482). We use no analytics tools. You can clear this data at any time in your browser settings. Your saved choices are then reset.

Account data: the email address and nickname you enter when you register and, if you sign in with Google or Apple, the basic data that service shares for the sign-in (usually your name and email address; with Apple you can choose to hide your email address, and we then receive a relay address from Apple). Google or Apple learns that you sign in with us. Sign-in is handled by Firebase Authentication, so we never see or store your password in plain text.

Learning data: your answers in exercises, results, progress in the review schedule, favourites, statistics on weak areas and your planned test date if you enter one. Settings: the app language.

Purchase status: whether you have Premium access. Payments are handled exclusively by Apple or Google. Our provider RevenueCat receives the purchase status so that we can unlock Premium. We never receive or store your payment card details.

Feedback: the message you send from the feedback page. It reaches us by email through Resend, together with your nickname and email address if you are signed in, the app language and whether you have Premium access.

Technical data: basic diagnostics needed for the app to work.

We process your data only to create and protect your account, save and restore your progress across devices, unlock the Premium access you have bought, manage the Early Access list and tell you about the launch, reply to your messages, keep the app and website technically running and secure, and meet our legal obligations.

Legal basis: contract (Article 6(1)(b) GDPR) for the account, learning data and Premium, consent (Article 6(1)(a)) for Early Access, and legitimate interest (Article 6(1)(f)) for operation, security and protection against abuse. You can object to processing based on legitimate interest.

We do not use your data for advertising, we do not sell or rent it out and we do not profile you. We do not collect sensitive personal data and do not ask for information about your residence permit, your citizenship application or your personal identity number.

We use processors only to operate the app and website. Their access is limited to what they need to provide their service to us:

Google (Firebase): sign-in, database (Cloud Firestore) and web hosting (Firebase Hosting on Google Cloud). Firestore is set up in the region Stockholm, Sweden.

Resend: email delivery of Early Access signups, contact form messages and feedback to us. Servers in the United States.

Google (Gmail): our support mailbox. Messages you send to our contact address, and our replies, are stored there. Servers in the United States and other countries.

RevenueCat Inc.: management of the purchase status for the app. Servers in the United States.

Google and Apple (sign-in): if you choose to sign in with Google or Apple, that company learns that you sign in with us and shares the data described above with us. Servers in the United States and other countries.

Apple and Google (App Store and Google Play): distribution of the app and processing of payments under their own privacy policies. Your payment details never pass through our systems or RevenueCat.

Your personal data is transferred outside the EU/EEA in three ways. First, our controller is located in Switzerland, which has an adequacy decision. Second, Resend, Gmail (Google) and RevenueCat process data on servers in the United States, and so do Google and Apple when you sign in. Third, Google may operate operations and support infrastructure outside the EU/EEA even when the database is in Stockholm or Finland.

Transfers to the United States are based on the European Commission's adequacy decision for recipients certified under the EU-US Data Privacy Framework, or on the European Commission's standard contractual clauses together with technical safeguards such as encryption in transit and access control. You can ask us for more information about these transfers at any time.

We only send marketing by email, for example the Early Access launch notification, to people who have consented to it, in accordance with Section 19 of the Swedish Marketing Act (2008:486). Each such message names us as the sender and contains a simple way to unsubscribe, which we respect without delay.

Messages needed for the service, for example a reply to your request or a notice about changes to this policy, do not count as marketing and may reach you even after you have unsubscribed.

The app's practice recommendations, for example which questions are shown again, are created automatically from your own answer history using a common spaced repetition method. This does not lead to decisions that have legal effects for you or similarly significantly affect you. It only controls which practice questions are suggested. No profiling for advertising or other purposes takes place.

Early Access email addresses: until the launch notification has been sent and for 12 months afterwards, or until you ask us to delete your address. As an outer limit, each signup is deleted automatically after 24 months.

Account and learning data in the app: as long as your account exists. When you delete your account in the app, this data is deleted. Backup copies are overwritten automatically after no more than 28 days.

Feedback and email conversations: as long as needed to handle them and improve the app, and until you ask us to delete them.

Technical server logs: for a limited period set by our hosting provider, only for operation and security.

Data stored only on your device stays there until you clear it.

You can delete your app account and all associated data at any time in the app under Profile, Delete account. This cannot be undone. Step-by-step instructions are in the account deletion guide.

To withdraw or delete an Early Access signup, or to have other data deleted, write to the contact address. We reply within 30 days. Purchase data held by Apple, Google or RevenueCat under their own policies is outside our control and follows their own retention rules.

Data is transferred encrypted (HTTPS). Passwords are handled by Firebase Authentication and are never visible to us in plain text. Our providers apply industry-standard technical and organisational safeguards, and we limit internal access to personal data to those who need it to operate the app and website. No system is completely secure and we cannot guarantee absolute security.

If a personal data breach concerning your data is likely to result in a risk to your rights and freedoms, we report it to the Swedish Authority for Privacy Protection (IMY) within 72 hours under Article 33 GDPR. If the breach is likely to result in a high risk, we also inform you under Article 34 and take measures to limit it.

Under the GDPR you have the right of access to the data we hold about you (Article 15), rectification of inaccurate data (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20) and the right to object to processing based on legitimate interest (Article 21). You can also withdraw a consent at any time.

Write to the contact address for all requests. We reply within one month and charge no fee. We may need to verify your identity first. Where the Swiss FADP applies to you, you have equivalent rights.

If you believe we have not handled your personal data correctly, please contact us first at the contact address. We reply within one month. If you are not satisfied with our reply, you can lodge a complaint with the Swedish Authority for Privacy Protection (IMY), imy.se, or with the supervisory authority in your home country within the EU/EEA. For matters under Swiss law, the competent authority is the Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch).

The app and website may be used from the age of 16. If you are under 16, you may only use them with the consent of your parents or guardians. We do not knowingly collect personal data from children under 16 without such consent. In the app, you confirm when registering that you are over 16 or that your parents agree. Swedish law allows children from the age of 13 to consent to certain services themselves, but we deliberately apply the stricter limit of 16.

We may update this policy when our practices or the law change. The current version is always on this page. We inform active users about material changes and ask for new consent where the law requires it. The date at the top shows when the policy was last updated.