Privacy policy

Last updated: 30 August 2026

This policy is published in German, English and Turkish, with the same content in each. The German version is the original; if you find any discrepancy between the versions, write to info@urenmobile.de and we will correct it.

This policy covers two separate services: the urenmobile.de website and the Migrant Guide iOS app. The processing differs substantially, so the sections are kept apart.

Controller

The controller under the GDPR is the person or company named in the legal notice:

Name / address: Remzi Yildirim
Hartriegelstraße 130
12439 Berlin
Germany
Email: info@urenmobile.de

No data protection officer has been appointed.

Part A — This website

A.1 Hosting

The website is static and delivered via Cloudflare Pages (Cloudflare, Inc., San Francisco, USA, with Cloudflare Germany GmbH as its EU establishment). Technically necessary data is processed on each request: IP address, date and time, the address requested, the amount of data transferred, and browser, operating system and referrer where sent. The legal basis is Art. 6(1)(f) GDPR — our legitimate interest in secure and stable operation. A data processing agreement is in place with Cloudflare; transfers to the USA are covered by the EU standard contractual clauses and the EU-US Data Privacy Framework. We do not evaluate server logs or combine them with other data.

A.2 No cookies, no tracking, no embeds

This website sets no cookies, uses no analytics or tracking services and loads no third-party content — no external fonts, maps, videos, social media plugins or advertising. That is why there is no cookie banner: there is no consent to obtain. There is deliberately no contact form; contact runs through your own mail client.

A.3 Contact by email

If you write to us we process your email address and the content of your message in order to reply. Legal basis: Art. 6(1)(f) GDPR, or Art. 6(1)(b) where your enquiry concerns a contract. Enquiries are deleted once handled and no statutory retention obligation applies — as a rule after no more than twelve months.

The mailbox is hosted by STRATO AG (Otto-Ostrowski-Straße 7, 10249 Berlin, Germany), so the processing takes place on servers in Germany; a data processing agreement is in place.

Part B — The Migrant Guide iOS app

In short: we collect no personal data. The app has no account and no sign-up, sends no usage data to us, and stores nothing about you on our systems. We receive no personal data about you whatsoever.

Personal data is processed in one place only: by Google, to serve advertising — and in personalised form only if you have consented (B.4 and B.5). Everything else below is either a technically necessary connection or stays on your device.

B.1 No data collection by us

The app has no registration and no user account. It contains no analytics SDK and no crash reporting SDK. No usage behaviour is recorded and nothing is transmitted to us — we build no user profiles and store no personal data about you. Should that change, we will update this policy before the app version concerned is released.

B.2 Settings stay on your device

Your settings are stored locally in iOS user defaults and are transmitted to no one — neither to us nor to third parties: content language, selected federal state, display name and avatar emoji if you enter them (display only, freely chosen, no real name required), and appearance (light / dark / system). This data never leaves your device and is removed when you delete the app. An iPhone backup may include it, in which case Apple's privacy terms apply.

B.3 Loading content (Contentful)

Guides, local services, links and the citizenship test questions are loaded from the Contentful content management system (Contentful GmbH, Ritterstraße 12–14, 10969 Berlin, Germany, with Contentful, Inc., USA). We send no data about you; the app simply requests content. As with any request to an internet address, technically necessary connection data is transmitted — in particular your device's IP address, without which no response can be delivered. No identifiers that would make you recognisable are sent along, and Contentful gives us no information about who requested which content. Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in delivering current content without shipping an app update for every text change.

B.4 Advertising (Google AdMob)

The app is funded by advertising and uses Google AdMob (Google Ireland Limited, Dublin, Ireland). This is the only place in the app where personal data is processed. Google processes it as its own controller and, depending on your consent, may use device identifiers — in particular the advertising identifier (IDFA) where you have consented to tracking — your IP address and the approximate location derived from it, device type, OS version and language setting, and your interactions with ads.

This data flows to Google, not to us: we receive only aggregated billing figures with no link to individual people. Google also processes the data for its own purposes and may transfer it to third countries, covered by the EU standard contractual clauses and the EU-US Data Privacy Framework.

B.5 Consent and how to withdraw it

On first launch the app shows two consecutive prompts: a consent dialog via the Google User Messaging Platform (TCF-compliant consent management), where you decide about personalised advertising — legal basis: your consent, Art. 6(1)(a) GDPR and § 25(1) TDDDG; and Apple's system prompt (App Tracking Transparency). If you decline there, the advertising identifier is not used. Your decision is stored locally on the device. Without consent, non-personalised ads are shown; the app remains fully usable.

Withdrawal. You can change the Apple decision at any time under Settings → Privacy & Security → Tracking. The advertising consent can be reopened and changed in the app at any time under Profile → Help & Support → Legal → Ad privacy settings. That entry appears wherever consent is legally required — in the EEA and the UK.

B.6 Ad measurement (SKAdNetwork)

The app supports Apple's SKAdNetwork, which lets Apple measure advertising performance without a cross-app identifier. The processing takes place at Apple; we receive no personal data from it.

B.7 App Store and planned in-app purchases

Downloading and updating the app runs through the App Store, where Apple processes data as its own controller. We receive only aggregated, non-personal statistics. Planned in-app purchases will be handled by Apple; payment data never reaches us.

B.8 External links and phone calls

When you tap a link or a phone number in the app, iOS opens your browser or phone app. From that point the respective provider's or your mobile operator's terms apply. We do not learn which links you open.

Part C — Your rights

Under the GDPR you have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), to object to processing based on legitimate interests (Art. 21), and to withdraw consent at any time without affecting the lawfulness of processing carried out until then (Art. 7(3)).

An email to info@urenmobile.de is enough for any of these. As we keep no user account, we can only link data to a person where you have contacted us yourself.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular the authority of your habitual residence or the one competent for us: Berliner Beauftragte für Datenschutz und Informationsfreiheit (Berlin Commissioner for Data Protection and Freedom of Information), Alt-Moabit 59–61, 10555 Berlin.

Part D — Children

The app is aimed at adults going through administrative procedures in Germany, not at children. We deliberately collect no age information.

Part E — Changes to this policy

We update this policy when the processing changes — for example if an analytics service or in-app purchases are added. The current version is on this page with its date.