Privacy Policy

1. Data Controller under GDPR

2. Collection and Processing of Personal Data

We process personal data only to the extent necessary to provide the interactive simulation and evaluation features on PassKlar.

• Connection Data & Server Logs: When accessing the website, our hoster (Vercel) automatically logs network connection data (IP address, browser agent, request timestamp, and requested URL) for security, debugging, and traffic management.
• Calculator & Test Inputs: Information entered into the naturalization calculator or language simulators (e.g. residence times, income status, test answers) is processed to calculate eligibility or scores.
• Document Audit uploads: PDF documents uploaded for compliance checks are read dynamically in-memory. Extracted text is evaluated, and the original files are purged immediately. No files are kept on our server.
• AI Case Chat: Queries submitted to our counselor chatbot are processed to generate conversational answers.

3. Data Sharing with Artificial Intelligence APIs

To offer AI-powered case assessments (Chatbot JURIS_OS and Document Auditor), text inputs and extracted file texts are transmitted to the Google Gemini API.

This transmission is encrypted and processed via Google Cloud Platform server nodes located inside the European Union (AWS/Google Cloud Frankfurt AWS Region).

Under our terms of service and Google API security agreements, your data is used exclusively to generate the response. It is never retained or used to train or improve AI models. All session data is purged immediately after output generation.

4. Legal Bases of Processing

Processing of your data is based on the following provisions under Article 6(1) GDPR:

• Art. 6(1)(a) GDPR (Consent): For uploading document files to check compliance via the Document Auditor.
• Art. 6(1)(f) GDPR (Legitimate Interests): For rendering, maintaining, and securing website interfaces, protecting system nodes, and recording server metrics.

5. Your Rights as a Data Subject

You possess the following rights regarding your data under the GDPR:

• Right of Access (Art. 15 GDPR): Request detail on your processed data.
• Right to Rectification (Art. 16 GDPR): Request correction of incorrect data.
• Right to Erasure (Art. 17 GDPR): Request immediate deletion of data.
• Right to Restriction (Art. 18 GDPR): Request limiting of data processing.
• Right to Data Portability (Art. 20 GDPR): Request data in a structured machine-readable format.
• Right to Object (Art. 21 GDPR): Object to data processing actions.
• Automated Decision-Making (Art. 22 GDPR): You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

To exercise these rights, please contact us at contact@sarwechodho.com. You also have the right to lodge a complaint with a data protection supervisory authority.

6. Cookies & Local Storage

PassKlar utilizes your browser\'s Local Storage to hold tool states (such as active calculator inputs or current test questions) locally on your device. This data is never sent to our servers.

We do not use any third-party marketing, analytics, or tracking cookies.