سياسة الخصوصية | Inburgering Oefenen

This is an English translation of our Dutch privacy policy. If the two versions differ, the Dutch version prevails.

Inburgering Oefenen ("we", "us") respects your privacy and processes personal data carefully and securely. In this privacy policy we explain which data we collect, why we collect it and what your rights are. This policy applies to the website inburgeringoefenen.nl, including the Inburgering Oefenen app in ChatGPT.

1. Who is responsible?

The data controller is:

Inburgering Oefenen
E-mail: contact@inburgeringoefenen.nl

2. What data do we collect?

That depends on how you use the platform.

If you practise without an account:

Your e-mail address, if you enter it to see your result. You can skip this step.
Your score on the free practice questions.
If you practise through ChatGPT without an account, OpenAI sends us an anonymised identifier of your ChatGPT account. We only store an encrypted value derived from it, to keep track of which of the ten free practice questions you have already had. We cannot use it to find out who you are.

If you create an account:

Your name, e-mail address and profile picture from your Google account. You can only sign in with Google: we never receive or store a password.
Your progress: which practice exams you took, which answer you gave to each question, your scores and your times.
Your answers to open tasks: the texts you write for Writing (Schrijven).
Your speaking recordings. In Speaking (Spreken) you record your answer. The recording is stored in non-public storage, together with its transcript and its assessment.
Payment data: which modules you have, until when, and the customer and subscription numbers of our payment provider. Your bank account number and card details never reach us: the payment provider processes them itself.
If you connect your account to ChatGPT, you allow the Inburgering Oefenen app in ChatGPT to fetch practice questions, check your answers and update your progress on your behalf. This is the same data as listed above; no second account is created. You can remove the connection in ChatGPT at any time.

We do not ask for special categories of personal data such as nationality, religion or health data. Keep in mind that in an open task you may write or speak about your own situation: do not share more about yourself than you want to.

3. What do we use your data for?

We use your data for the following purposes:

Sending you your personal test results
Sending you free practice material and study tips for the inburgering exam
Occasional communication about the platform
Keeping track of your progress, so you can see where you stand and which part needs attention
Checking your Writing and Speaking answers against the teacher's assessment criteria, and storing that assessment so the teacher can review and correct it
Giving you access to the modules you have bought, and collecting the subscription fee

4. Legal basis

The processing is based on your consent (Article 6(1)(a) GDPR), which you give by entering your e-mail address to see your results. You can withdraw this consent at any time.

5. How long do we keep your data?

We keep your e-mail address until you unsubscribe or ask us to delete it, or at most 2 years after our last contact, unless a legal obligation requires a longer retention period.

If you have an account, we keep your progress, your answers, your recordings and your assessments for as long as your account exists. If you ask us to delete your account, we delete that data too. Payment data is subject to the statutory accounting retention period of 7 years.

6. Sharing with third parties

We use the following parties as processors. They may only use your data to provide their service to us.

Supabase — database, sign-in and file storage. Our data is stored in the EU (Frankfurt).
Vercel — website hosting.
Google — signing in with your Google account, and Google Analytics for visitor statistics.
Mollie — payments and subscriptions.
Resend — sending our e-mails.
ElevenLabs — transcribing your spoken answer to text, and producing the audio in the practice exams.
Vercel AI Gateway— for Writing and Speaking, your answer (for Speaking: also the audio recording) is sent to a language model that applies the teacher's assessment criteria. Your name and e-mail address are not sent along.
OpenAI (ChatGPT)— only if you use the Inburgering Oefenen app in ChatGPT. The practice questions, the answers you choose and the explanations then pass through ChatGPT; whatever you type in ChatGPT is covered by OpenAI's privacy policy. We do not store conversation content.
Microsoft Clarity — insight into how the website is used, including recordings of mouse movements and clicks.
Meta — measuring the results of our advertisements.

We never sell your data to third parties.

7. Artificial intelligence (AI)

We use AI in a few places. This section explains where, which data is involved and what that means for you. A full description of how we make our content is on the page How we make our content.

Grading of Writing and Speaking.Your written answer, or for Speaking your recording and its transcript, is sent through the Vercel AI Gateway to a language model (currently Google's Gemini). The model applies our NT2 teacher's marking scheme and gives a score with an explanation per criterion. Your name and e-mail address are not included. The teacher reviews the gradings afterwards. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
Transcribing your recording. ElevenLabs turns your spoken answer into text (Scribe). The recording is processed only for that purpose, never to identify you.
No decision with legal effect. A grading is practice feedback. It is not an official DUO result and no decision about admission, a diploma or money depends on it, so there is no automated decision-making within the meaning of Article 22 GDPR. If you disagree with a grading, let us know via contact and the teacher will look at it herself.
No training. We do not use your answers to train AI models, and the providers we use process your data only to produce the grading.
Transfers outside the EU.Vercel, Google and ElevenLabs may process data in the United States, on the basis of the EU-US Data Privacy Framework or the European Commission's standard contractual clauses.
Retention. We keep your answers, recordings, transcripts and gradings for as long as your account exists, so you can see your progress. If you delete your account, we delete them too.
Also made with AI, but without your data: the first drafts of practice exercises and guides (then checked by our teacher), the English and Arabic translations of the guides (not reviewed; every translated page says so) and the voices in the listening fragments.

8. Security

We take appropriate technical and organisational measures to protect your personal data against loss, theft or unauthorised access. The website uses HTTPS encryption.

9. Your rights

Under the GDPR you have the following rights:

Right of access — you can ask which data we hold about you
Right to rectification — you can have incorrect data corrected
Right to erasure — you can ask us to delete your data ("right to be forgotten")
Right to restriction — you can have the processing restricted
Right to object — you can object to the processing
Right to data portability — you can request your data in a structured format

To exercise a right, send an e-mail to contact@inburgeringoefenen.nl. We respond within 30 days.

10. Filing a complaint

If you believe we are violating your privacy rights, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens): autoriteitpersoonsgegevens.nl.

11. Cookies

This website uses two kinds of cookies and similar technologies.

Necessary — to keep you signed in and to remember your preferences (such as sound on or off). The platform does not work without them.
Analytics and advertising — Google Analytics, Microsoft Clarity and the Meta pixel. These measure how the website is used and how our advertisements perform.

You can always refuse or delete cookies in your browser settings. If you refuse the necessary cookies, you cannot sign in.

12. Changes

We may change this privacy policy from time to time. The "Last updated" date at the top of the page shows when the most recent version was published. We recommend that you check this policy periodically.

13. Contact

For questions or requests about this privacy policy or the processing of your data, contact us at: contact@inburgeringoefenen.nl.