Privacy Policy

1. Scope

This Privacy Policy explains how personal data is processed when using Digitales Register ("App"). It covers Android, iOS and Microsoft Windows builds where the respective build is distributed and supported.

The App primarily acts as a client for educational services available through digitalesregister.it and/or infrastructure operated by the relevant educational institution or service provider. Processing independently performed on those institutional systems remains subject to the responsibilities and privacy information of the relevant institution or provider.

2. Controller

Where an educational institution independently determines the purposes and means of processing official school data stored on its systems, that institution is responsible for that processing.

3. Core App Data

Depending on the institutional system and feature used, the App may process:

• usernames, account identifiers, credentials, session tokens and server information;
• grades, evaluations, absences, timetables, examinations, assignments and calendar entries;
• messages, notices, educational documents and files;
• profile, school, class, teacher, course or subject information;
• locally cached data, settings, downloaded files and account configuration.

Authentication information is used to establish and maintain the requested connection to the institutional service. Where stored locally, platform-appropriate storage mechanisms are used where technically available.

4. Optional Privacy Choices

The App separates optional processing into three independent purposes:

• Diagnostics consent – Firebase Crashlytics for crashes and technical errors;
• Usage analytics consent – Google Analytics for Firebase for App-usage statistics;
• Academic statistics consent – additional pseudonymous school/grade statistics.

These optional purposes are not required for the App's essential educational functionality. They are disabled until the required consent conditions are fulfilled. Users can reject all optional purposes, allow individual purposes and later withdraw them in the App's privacy settings.

The App stores the privacy version and privacy choices locally. It does not need a date of birth or exact age for this purpose.

5. Google Analytics for Firebase

On supported platforms, and only after valid usage-analytics consent, the App may use Google Analytics for Firebase to understand App usage and improve functionality.

Analytics may include allow-listed events, technical screen/feature identifiers, session information, App version, OS/device information supplied by the service, App language/theme and a locally generated pseudonymous user ID.

The analytics user ID is random. It is not a username, email address, school account ID or a hash of such data. A person using multiple devices may therefore be counted as multiple pseudonymous users.

The App does not intentionally send names, emails, usernames, passwords, tokens, cookies, individual grades, subjects, teachers, school names, messages, homework text, absence reasons, health information, free text, full URLs with identifiers/query parameters, precise GPS data, Wi-Fi SSID/BSSID or advertising identifiers added by the App.

Google Signals, user-provided-data features, personalized advertising, remarketing and Google Ads conversion optimization are not used for this App. Advertising-related consent signals are kept denied. Detailed location/device reporting is disabled in the Analytics configuration.

6. Pseudonymous Academic Statistics

Academic statistics require separate academic-statistics consent and usage-analytics consent. They are not sent in demo mode.

The App may send only:

• academic year and semester;
• the overall locally calculated grade average, rounded to one decimal place and transmitted as integer tenths;
• bucketed numbers of grades and subjects;
• a technical snapshot-schema version;
• a stable internal school identifier such as school_0001, where the school can be mapped unambiguously.

School names, individual grades, subjects, teachers, comments, examination names and other educational content are not sent as academic-statistics events. These data are pseudonymous, not anonymous.

7. Firebase Crashlytics

On supported platforms, and only after valid diagnostics consent, the App may use Firebase Crashlytics to identify crashes and technical errors.

Crashlytics may process crash reports, stack traces, App/OS version, device type/architecture, technical App state, Firebase/Crashlytics installation identifiers and controlled technical logs/custom keys.

The App is designed not to intentionally include passwords, tokens, individual grades, school names, messages, absence reasons, free text or other educational content in crash reports.

Google states that Crashlytics keeps crash stack traces, processed crash/minidump data and associated identifiers for 90 days before beginning removal from live and backup systems.

8. Platform-Specific Behaviour

Android

Firebase Analytics and Crashlytics may be used after the respective consent has been granted. Collection is designed to remain disabled before consent.

iOS

Where the iOS version is distributed and Firebase is correctly configured, the same consent rules apply. The App does not request App Tracking Transparency permission merely for the Firebase setup described here and does not intentionally use IDFA for advertising or cross-app tracking.

Microsoft Windows

Firebase states that its Flutter support on Windows is not intended for production use. The App therefore treats Firebase Analytics and Crashlytics as unavailable/no-op telemetry on production Windows builds unless a supported production implementation is introduced later. Essential App functionality does not depend on Firebase telemetry.

9. Children and Adolescents

The App may be used by children and adolescents. For the optional consent-based telemetry model in Italy, the App asks only whether the user is 14 years or older.

If the user is under 14, or age eligibility is unknown, optional Analytics, Crashlytics and academic-statistics processing remains disabled because the App currently does not provide a parent/legal-guardian authorization flow for those optional purposes.

This rule concerns the App's optional consent-based processing and does not mean that every processing operation concerning a person under 14 is prohibited. Educational institutions may process school data under different legal bases and responsibilities.

10. Purposes and Legal Bases

• core App functions: connecting to the requested institutional service and displaying requested educational information;
• optional diagnostics: consent, Art. 6(1)(a) GDPR;
• optional usage analytics: consent, Art. 6(1)(a) GDPR;
• optional academic statistics: separate consent, Art. 6(1)(a) GDPR.

For core processing, the applicable legal basis depends on the relevant service relationship. Processing independently determined by an educational institution is subject to the legal basis determined by that institution.

11. Recipients

Google Firebase / Google Analytics

Depending on platform and consent, relevant services may include Google Analytics for Firebase and Firebase Crashlytics. Firebase Performance Monitoring is not part of this telemetry setup.

The App also communicates with the relevant educational institution and/or service infrastructure required for the requested school functionality.

12. International Transfers

Some service providers may process information outside the European Economic Area. Where personal data is transferred to a third country, the transfer is subject to the safeguards applicable to the relevant provider and transfer, such as an adequacy decision, the EU-U.S. Data Privacy Framework where applicable, Standard Contractual Clauses or another recognized transfer mechanism.

13. Retention

Local App Data

Local App data may remain until logout/account removal, deletion through available App or operating-system functions, clearing App data, or uninstallation. Files saved outside the App's private storage may need to be deleted separately.

Google Analytics

The Google Analytics property is configured with a 14-month user/event data-retention setting for data to which that setting applies.

BigQuery

Analytics event data may be exported daily to Google BigQuery in the European Union (EU). Advertising-ID export and the separate Analytics user-data export are disabled. BigQuery retention is technically separate from the GA4 retention setting. The operator's policy for exported Analytics event data is a maximum of 14 months; the BigQuery dataset/table expiration configuration must be maintained separately to enforce this maximum.

Crashlytics

Google states a 90-day retention period for the Crashlytics data described above before the removal process begins.

Institutional Data

Retention periods for data stored on educational institution servers are determined by the relevant institution or service provider.

14. Withdrawal and Deletion

Users may change or withdraw optional privacy choices in the App's privacy settings. Withdrawal takes effect for future optional processing.

When Analytics consent is withdrawn, the App is designed to stop future Analytics collection, clear the App-set Analytics user ID/properties and reset local Analytics state where supported. This does not itself guarantee deletion of already transmitted server-side data.

When academic-statistics consent is withdrawn, future academic-statistics events and the school analytics identifier are disabled/removed from the App's Analytics context. When diagnostics consent is withdrawn, future Crashlytics collection is disabled and, where supported, unsent local crash reports are deleted.

15. GDPR Rights

Where the App operator acts as controller for the relevant processing, users may have rights of access, rectification, erasure, restriction, data portability where applicable, objection where applicable, withdrawal of consent, and complaint to a supervisory authority under Arts. 15–21 and 77 GDPR.

Requests concerning processing for which the App operator is responsible can be sent to buccitobias774@gmail.com. In Italy, users may also contact the Garante per la protezione dei dati personali.

16. Account and Data Deletion

Digitales Register generally connects to an account managed by the relevant school or institutional server rather than creating an independent school account controlled by the App operator. Deleting local App data therefore does not automatically delete the underlying institutional account.

Requests concerning personal data independently controlled by the App operator may be sent to the contact address above. Requests concerning official educational records should generally be directed to the responsible educational institution.

17. Platform Providers

The App may be distributed through Google Play / Android, Apple App Store / iOS, and Microsoft Store or other distribution channels / Microsoft Windows. The relevant platform provider may independently process information related to downloading, installing, updating or using applications through its platform.

18. Changes

This Privacy Policy may be updated when the App, third-party services, legal requirements or processing practices change. Where a material change requires a new consent decision, an older optional consent is not silently treated as consent to the changed purpose.

19. Contact

Privacy version: 4
Effective date: 1 October 2026