Privacy Policy

Last updated: July 2026

Note: This is a convenience translation provided for informational purposes only. The German version of this Privacy Policy is the sole legally binding version.

Data Controller

Aleksei Aduevskii

Email: aleksdevelopergp@gmail.com

For full contact details, please refer to the Legal Notice.

Hosting

This website is delivered through Cloudflare Pages. Technical connection data (in particular IP address, browser type, requested page, and access time) may be processed in security and server logs. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in secure and stable website operation).

Provider: Cloudflare, Inc. The Firebase services of Google Ireland Limited are additionally used for accounts, progress, and subscriptions as described below.

Google Fonts

This website uses web fonts provided by Google Fonts. When you load a page, your browser establishes a connection to Google's servers in order to retrieve the required font files. In the course of this connection, your IP address is transmitted to Google. The legal basis for this processing is Art. 6(1)(f) GDPR (legitimate interest in a uniform and appealing presentation of the website).

For further information, please see the Google Privacy Policy.

Google AdSense

This website uses Google AdSense to display advertisements. The AdSense code is loaded only after your consent decision and premium status have both been resolved. If you consent, AdSense may use cookies and similar technologies for personalised advertising (legal basis: Art. 6(1)(a) GDPR). If you reject consent or use a premium account, no AdSense advertising request is made during that session.

Provider: Google Ireland Limited. For more details, see Google Advertising & Privacy.

Consent Management and Analytics

We use Google Funding Choices to manage your privacy settings. Google Analytics is loaded only after you have made an explicit choice. If you consent, Analytics cookies may be used; if you reject consent, Google Analytics runs in Consent Mode with analytics storage denied, so only cookieless, non-personalised measurement signals are sent for aggregated statistics and modelling.

The former custom Firebase/Firestore page-view counter has been disabled. Reach and product measurement use the consent-aware analytics described here together with aggregated hosting and Search Console reports. Free text and personal form entries are not sent as analytics events.

Account, Progress Sync and Premium Features

If you choose to create an account, we use Firebase Authentication for sign-in as well as Cloud Firestore and Cloud Functions for account features, progress sync, and premium subscription features. On first sign-in, only explicitly approved, non-free-text learning progress is synchronised: IDs of completed reading and listening tasks and structured completion scores. The document uses schema generation 2 and a size limit. Drafts, personal Speaking data, consent, authentication, advertising and access state, and unknown local-storage keys are not synchronised. For web subscriptions, a Stripe-based checkout or customer portal link may also be used.

Provider for the Firebase services: Google Ireland Limited.

External API for Speaking Part 1

On the “Speaking Part 1” page, text you enter may be sent to the external service cold-water-47ff.alexaduevsky.workers.dev in order to generate practice text.

Cloudflare

Cloudflare is used for DNS and technical delivery of the website. In that role, technical connection data may be processed.

Local Storage

This website stores learning progress, drafts, and preferences (such as theme and consent status) in your browser's local storage. Without an account, this data remains on your device. After sign-in, only the structured progress fields explicitly listed in “Account, Progress Sync and Premium Features” are transmitted. Drafts, personal entries from “Speaking Part 1,” and preferences remain local. You can clear local data at any time through your browser settings.

Your Rights Under the GDPR

Under the General Data Protection Regulation, you have the following rights with respect to your personal data:

• Right of access (Art. 15 GDPR) — You may request confirmation of whether your personal data is being processed and, if so, obtain a copy of that data.
• Right to rectification (Art. 16 GDPR) — You may request correction of inaccurate personal data.
• Right to erasure (Art. 17 GDPR) — You may request deletion of your personal data under certain conditions.
• Right to restriction of processing (Art. 18 GDPR) — You may request that processing of your data be restricted in certain circumstances.
• Right to data portability (Art. 20 GDPR) — You may request to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object (Art. 21 GDPR) — You may object to the processing of your personal data based on legitimate interests.

If you believe that the processing of your personal data violates data protection law, you have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or the place of the alleged infringement.

To exercise any of these rights, please contact us via our contact page or by email at aleksdevelopergp@gmail.com.