Privacy Policy

1. Scope

This Privacy Policy explains how personal data is processed when you use the app Digitales Register (also published as “Schulregister Südtirol”; “App”). It covers the builds for Android, iOS, Microsoft Windows and Linux. The website and the server have their own privacy policy and legal notice.

The App is a client for the school register at digitalesregister.it. Register data travels directly between your device and the register of your school. The App’s operator has no server for this data and does not receive it.

2. Controller

The school and its register provider are responsible for the data held in the register. Their own privacy information applies to it.

3. School Register and Core App Data

Depending on your school and the features you use, the App processes on your device and exchanges with the register:

• usernames, passwords, a second factor where used, and session data;
• grades, evaluations, absences including reasons that may concern health, timetables, tests, homework and calendar entries;
• messages, notices, documents and files;
• profile, school, class, teacher and subject information.

Unsaved credentials and session cookies stay in memory for the session. Saved credentials are kept in the secure storage of the device.

School notifications. If you turn them on for an account, the App checks the register in the background with the saved login and shows local notifications. This runs directly between your device and the register. No push service is involved.

Calendar, files and exports. Calendar sync (Android) writes the events you request to the device calendar you choose, and the calendar’s provider may sync them. Downloads and PDF, CSV or ZIP exports are saved where you choose. These copies are under your control.

4. Local Storage

Settings, privacy choices, notes, reminders, widgets data and, where enabled, register caches stay on your device. Android app backup is disabled. Other operating-system backups may exist separately.

5. App Announcements

While the App is open, it requests https://api.digitalesregister.com/api/v1/notifications about every 5 minutes. The interval comes from the server and varies randomly by about 10 percent. The App also checks when you return to it after at least a minute, and it waits longer after errors. This works without login and does not depend on any consent.

What the App sends: the platform, the app version without the build number, the language and technical values for paging and caching (limit, cursor, ETag), plus the connection data of any HTTPS request (IP address, user agent). It sends no account, school or grade data, no device identifier and no advertising ID. There is no account, no push provider (no APNs, no FCM), no tracking and no advertising.

What the server keeps: in normal operation nothing. The IP address is held in memory only, to limit requests, and there is no access log. Only on a server error (HTTP status 5xx) does the web server write the IP address, the requested address with parameters and the request headers, without cookies, to the system log, which is deleted after 15 days at the latest.

On your device: read status, hidden announcements and unread content are stored on the device only and are not sent to the server. They stay after logout. Read status is removed once an announcement has not been listed for 180 days; hidden announcements stay recorded until you delete the app data. If you turn off saving of data, no content is cached.

The App has no switch to turn off these requests; they stop when you close or uninstall it. The feature does not exist on macOS.

6. Infrastructure: Cloudflare and Oracle

Requests to api.digitalesregister.com, like those to the website, run through Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA (DNS, proxy and CDN, TLS termination, DDoS protection). Because encryption ends at Cloudflare, Cloudflare sees IP addresses, request headers and the requests themselves.

According to Cloudflare, it is a processor for customer logs and a controller for other personal data. Cloudflare states that it primarily stores data in the United States and the European Economic Area, so a transfer outside the EU is possible. As safeguards Cloudflare names its certification under the EU-U.S. Data Privacy Framework and, should that lapse, standard contractual clauses. Responses carry Cloudflare headers for Network Error Logging, with which supporting browsers can report connection errors to Cloudflare. Details: Cloudflare privacy policy (4 November 2025), Data Processing Addendum (version 6.4, 3 April 2026), sub-processors.

The server is a virtual machine on Oracle Cloud Infrastructure (Always Free) in the Milan region, Italy (eu-milan-1). According to Oracle, it acts as a processor. For transfers from the European Economic Area, Oracle names binding corporate rules for processors or standard contractual clauses, and the EU-U.S. Data Privacy Framework. Details: Oracle Services Privacy Policy, Oracle Data Processing Agreement.

7. Optional Privacy Choices

The App separates optional processing into three independent purposes:

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

All three are off until you allow them, and the App works without them. You can allow them one by one and withdraw them later under Settings > Privacy & Data. A decision for an older notice version does not count. The App stores the notice version and your choices locally.

8. Google Analytics for Firebase

Only after usage-analytics consent, and on Android and iOS, the App sends fixed screen and feature names, actions, load, login and sync results, filters, semester, language, theme and a locally generated pseudonymous user ID. Firebase adds its own technical data such as sessions, app version, operating system and device type.

The analytics user ID is random, one per locally saved account and installation. It contains no name, email address or credentials. A person on several devices may be counted several times. These data are pseudonymous, not anonymous.

The App does not send names, email addresses, usernames, passwords, tokens, cookies, individual grades, subjects, teachers, school names, messages, homework text, absence reasons, health information, free text, full URLs, precise location, Wi-Fi names or advertising identifiers.

Advertising-related consent signals stay denied and advertising-ID collection is disabled in the App. Google Signals, personalized advertising, remarketing and user-provided data are not used.

9. Pseudonymous Academic Statistics

These require separate consent and usage-analytics consent, and they are not sent in demo mode. The App sends only:

• academic year and semester;
• the overall grade average calculated on the device, reduced to one decimal place;
• ranges for the number of grades and subjects;
• a technical 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 and absences are not sent. The contribution is linked to your pseudonymous ID. Published school groups need at least 30 different pseudonymous IDs. These data are pseudonymous, not anonymous.

10. Firebase Crashlytics

Only after diagnostics consent, and on Android and iOS, the App uses Firebase Crashlytics to find crashes and technical errors. It processes crash reports, stack traces, app and operating-system version, device type, technical app state, installation identifiers and fixed technical log entries.

Passwords, tokens, grades, school names, messages, absence reasons and free text are not included. No identifier of your school account is set.

11. Platforms

Android and iOS: Firebase Analytics and Crashlytics run only after the respective consent. The App does not ask for App Tracking Transparency permission and does not use advertising identifiers.

Microsoft Windows and Linux: the App collects no Firebase diagnostics or analytics. The optional purposes have no effect there.

12. Children and Adolescents

The App is used by pupils and by their parents. It does not ask for an age. Core functions do not depend on optional consent, and all optional purposes are off until someone turns them on.

In Italy, a person can give consent to such services alone from the age of 14 (Art. 2-quinquies D.Lgs. 196/2003). Younger users should leave the optional purposes off unless a parent or guardian agrees. The App cannot check this.

13. Purposes and Legal Bases

• core functions: you request them, the data stays between your device and the register, and the school determines the legal basis of the register itself;
• app announcements and infrastructure: legitimate interest, Art. 6(1)(f) GDPR;
• diagnostics, usage analytics, academic statistics: consent, Art. 6(1)(a) GDPR.

You are not obliged to provide data. Without login data the register cannot be used, and without connection data announcements cannot be delivered. There is no automated decision-making and no profiling with legal or similar effect.

14. Recipients

The register of your school receives what is needed for login and register functions. Cloudflare and Oracle process the announcement requests as described above. With the respective consent, Google processes the optional data:

According to Google, it is generally a processor for Firebase, while Google Analytics has separate terms. Details: Firebase privacy and security. We do not sell data and use no advertising networks. Beyond these recipients, we pass on data only where the law requires it.

15. International Transfers

Firebase processing may take place outside the European Economic Area. For transfers to the United States, Google names the EU-U.S. Data Privacy Framework. An EU BigQuery dataset does not guarantee EU-only processing for all Firebase services. For Cloudflare and Oracle see the section on infrastructure.

16. Retention

• Local data: until you delete it, the cache is replaced or the account is removed. There is no uniform period.
• Announcement requests: not stored in normal operation; system log entries after a server error are deleted after 15 days at the latest.
• Google Analytics: set to 14 months, renewed on new activity. This does not automatically apply to all aggregate reports.
• BigQuery: analytics event data may be exported daily to a dataset in the European Union and is deleted after 14 months at the latest. Advertising-ID export and the separate user-data export are off.
• Crashlytics: Google states 90 days before removal from live and backup systems begins.
• School register: determined by the school and its register provider.

17. Withdrawal

You can change or withdraw your choices under Settings > Privacy & Data. Withdrawal applies to the future. The App stops the collection, clears the analytics ID and properties it set, resets local analytics data and deletes unsent crash reports where supported. Data already transmitted is not deleted automatically.

18. Your Rights

You have the right of access, rectification, erasure, restriction and data portability (Arts. 15 to 20 GDPR), the right to object (Art. 21 GDPR) and the right to withdraw consent. Write to buccitobias774@gmail.com. We use your address and message only to answer you; the mailbox is hosted by Google. Please do not send passwords or health data.

Because announcement requests carry no account and analytics IDs are pseudonymous, we often cannot link data to a person by name.

You can complain to the supervisory authority: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, www.garanteprivacy.it.

19. Account and Data Deletion

The App creates no account of its own. Deleting local data does not delete your school account. How to remove local data and how to ask for deletion is described on the deletion page (German). Requests about official school records go to your school.

20. Platform Providers and External Links

Google Play, the Apple App Store, the Microsoft Store and other distribution channels may process data about downloads and updates under their own rules. Links to PayPal for voluntary donations, to GitHub and to other external pages open services with their own privacy rules. This page is delivered through GitHub Pages; GitHub processes connection data under its privacy statement.

21. Changes

If an optional purpose changes, the App asks for a new decision. An older consent is not treated as consent to the changed purpose.

• Version 5 (7 November 2026): added app announcements, Cloudflare and Oracle; removed the age question; added languages. The optional purposes are unchanged.
• Version 4 (1 October 2026): separate consents for diagnostics, usage analytics and academic statistics.