Privacy policy
Effective 25.10.2026. Applies to the “Listovki: Yasno” mobile app for Android and iOS and to this website. The Bulgarian version prevails.
1. Who is responsible
The data controller is ASOINCOL – Asociación Colombo-Lanzaroteña por la Solidaridad y la Integración Sociocultural en la Isla (OpeTest Apps), Calle Alcalde Lorenzo Cabrera 23, 35500 Arrecife, Spain. For any privacy question write to hola@opetest.es.
2. In short
- The app works without sign-up or an account. We never ask for your name, email or phone.
- Your progress (answers, mock exams, plan, favourites, settings) stays on your device only. We have no server for user data and never receive it.
- We use no analytics, tracking, profiling or ads.
- Data reaches third parties only in the cases in section 4: purchase, video downloads and emails to support.
3. Data that stays on your device
| Data | Purpose | How to delete it |
|---|---|---|
| Answers, sessions, mock exams, mistakes, favourites, plan, settings | To make study and statistics work | Settings → Data → Delete progress, or uninstall the app |
| Downloaded videos | Offline use | Downloads → Remove videos |
| Study reminders | Local notifications you choose; they never pass through our servers | Turn them off in Settings |
| Progress export file | Created only when you ask; you decide where to save or share it | Delete the file |
4. Data processed by others
| Service | What data | When |
|---|---|---|
| Google Play (Google Ireland Ltd.) or the App Store (Apple Distribution International Ltd.) | Purchase and payment data. Payment is handled entirely by the store; the app only receives a purchase confirmation and verifies it on the device. | Only when you buy or restore Pro. The store’s own privacy policy also applies. |
| The Road Transport Administration server (public-eis.rta.government.bg) | IP address and the file request, as with any visit to a public website. | Only when you download a video pack: the device fetches the videos directly from the public RTA website. We do not receive this data. |
| Email to support or “Report a problem” | Your email address and the message (for a report: the question number, your comment and the app version). | Only if you write to us. The message is sent from your own email app. |
| Text-to-speech on the device | The question text | Only if you use “Read aloud”. It is processed by the speech engine selected in your device settings. |
| Store rating | Handled by the store | The app occasionally offers a rating; the dialog belongs to the store. |
Google and Apple may process purchase data outside the European Economic Area (for example in the United States) on the basis of the European Commission’s EU–US Data Privacy Framework decision or standard contractual clauses.
5. Legal basis (Art. 6 GDPR)
- Contract – buying and restoring Pro and downloading the video packs you request.
- Legitimate interest – answering support requests and reports.
- Legal obligation – accounting and tax rules the stores apply to sales.
6. How long we keep data
Data on your device stays until you delete it or the app. Support emails are kept for up to 12 months after the request is closed. Retention for purchases is set by Google and Apple.
7. Your rights
You have the right of access, rectification, erasure, restriction, data portability and objection. Because we do not store your progress on a server, most rights are exercised directly in the app (delete, export). For anything else write to hola@opetest.es; we reply within one month.
You may lodge a complaint with the Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria, www.cpdp.bg.
8. Children
The app is meant for learner drivers and is not directed at children under 14. We do not knowingly collect children’s data.
9. Security
Data on the device is protected by the operating system. Connections for purchases and downloads are encrypted (HTTPS). Every downloaded video is integrity-checked before use.
10. Changes
If this policy changes we will publish the new version on this page with a new date, and notify you in the app of significant changes.