Privacy policy
Data controller
SayPeter SARL, 9, rue Raymond Poincaré, L-2342 Luxembourg is the controller for the processing of your personal data in Medborgarklar. Contact: hej@medborgarklar.com. Full seller identification is in the terms.
What data we process
- Account data: your email address and a cryptographically hashed password (we never store the password in clear text).
- Study data: your answers to questions, which areas you have practised, results of diagnostics and mock exams, and the times of those events.
- Session data: a session identifier in a cookie, plus the time the session is created and expires.
- Language choice: your choice of Swedish or English, stored in a cookie.
- Watch lists: see the dedicated section below.
We do not ask for gender, age, citizenship, country of origin or details of your migration application, and we process no special categories of personal data.
The watch lists (an email about the date, and about the pass mark)
You can leave your email address to get one email when a specific fact is published. There are two separate lists and you may be on either, or both:
- Date of the next sitting: one email the day UHR publishes the date and the locations.
- The pass mark: one email when UHR publishes the pass mark.
Double opt-in is always required. When you submit the form the address is stored as unconfirmed, and the only email that can ever go to it is a confirmation email. If you do not click the link in that email within 14 days, the address is never used for anything. We do not store the confirmation link itself, only a cryptographic fingerprint of it.
| What is stored | Why |
|---|---|
| Your email address | It is the whole point: it is where the email goes |
| Which list, and whether the signup is unconfirmed, confirmed or ended | So that only confirmed addresses can ever be mailed |
| Your language choice (Swedish or English) | So the announcement reaches you in your language |
| The time of the signup, of the confirmation and of any unsubscribe | So we can show that consent exists and when it was given or withdrawn |
| The page the form stood on, and the exact sentence you agreed to | So we can show what you said yes to, not merely that you did |
| Fingerprints (hashes) of the confirmation and unsubscribe links | So the links work without being readable out of the database |
| Your IP address | Not stored. We do not log it at signup and do not attach it to the address |
| Name, phone number or any other detail about you | Not asked for and not stored |
Legal basis: consent (Article 6(1)(a) GDPR). The consent is freely given, specific to each list, and can be withdrawn at any time without affecting anything else in the service.
Withdrawing takes one click. Every email we send contains an unsubscribe link that takes effect the moment you click it: no login, no account, no confirmation step and no reason required. You can also write to hej@medborgarklar.com and we will delete the address entirely.
How long: an unconfirmed signup is deleted automatically 30 days after the confirmation link expires. A confirmed signup is kept until the fact you are watching has been published and the email has gone out, and for at most 12 months after that, or until you unsubscribe, whichever comes first. If you unsubscribe we keep only the fact that the address unsubscribed, so it cannot be added again by accident; if you want that deleted too, write to us.
The list never leaves us. We do not share it with, and never upload it to, Meta, Google or any other advertising network, in any form: not as a file, not as hashed addresses, and not to build lookalike audiences. That is a binding promise and the application deliberately has no export function. If we ever wanted to change it, this policy would have to change first and a separate, specific consent would have to be obtained.
Diagnostic without an account
Your score appears immediately. When you request the review, we save your email address, language and capture time with your result to show the area breakdown, explanations and next practice step. The legal basis is performance of a contract (Article 6(1)(b) GDPR). After a free test, when you create an account or when you start a purchase, we send a few emails about the course to the address, and every email has an unsubscribe link that works with one click. The address is not shared with advertising networks. These records are kept for 90 days without an account; a result you save to an account follows the account retention period.
Before you submit your email address, the diagnostic result is stored with no link to an identified person. In detail:
| What is stored | For how long |
|---|---|
| A randomly generated id for the run | 90 days |
| Your score and the number of questions | 90 days |
| Which question identifiers you were given and whether each answer was right or wrong, per area | 90 days |
| The time of the run | 90 days |
| Your IP address | Not stored at all with the result |
| Name, email or any other identifier | Not stored |
After 90 days anonymous diagnostic results are deleted automatically. If within that time you create an account and choose to save the result, it is linked to your account and then follows the account data rules below.
Email about the course
After a free test, when you create an account or when you start a purchase, we send a few emails about the course to the address you gave. Next to every email address we ask for there is also an optional box that is never pre-ticked: after the test, when you create an account, at the watch lists and at checkout. The text is: “I want to receive offers and news from Medborgarklar by email. I can unsubscribe at any time.” Everything works the same without the tick: the result, the account, the watch and the purchase.
- What we store: your answer in the box (yes or no), which version of the text you saw and the time, on your lead, account, watch-list entry or order. It is a recorded preference for offers and news.
- After a purchase: at checkout we show that we send offers about similar courses to the address you buy with, and we store that you saw it.
- Unsubscribing: every email has a one-click link, you can unsubscribe on unsubscribe and you can write to hej@medborgarklar.com. We then keep only the fact that the address unsubscribed, so it is not added again by accident.
Why we process it and on what legal basis
- To give you access to your account and save your progress: performance of a contract (Article 6(1)(b) GDPR).
- To keep the service secure and prevent abuse: legitimate interest (Article 6(1)(f)).
- To meet accounting and consumer law obligations once payment is switched on: legal obligation (Article 6(1)(c)).
- For anonymous statistics on how the diagnostic performs: legitimate interest (Article 6(1)(f)), on data not linked to an identified person.
- To send the emails you asked for from the watch lists: consent (Article 6(1)(a)), which you can withdraw in one click.
- For advertising measurement through Meta Pixel and Conversions API: consent (Article 6(1)(a) GDPR).
Cookies and consent to Meta
We use necessary cookies for login and language. On your first visit both choices appear in the same panel, one click each: Accept all and Only necessary cookies, with a link to this policy. Nothing is pre-ticked. Your choice is saved in local storage and the mk_marketing_consent_v2 cookie for 12 months, after which we ask again. Change or withdraw your choice using Change cookie choice in the footer.
The page contains an advertising pixel, but Meta’s script loads and marketing events are sent only after you accept. Meta may then use _fbp and _fbc. Only necessary stops new events; consent is optional and withdrawing it does not affect the service. The mk_v cookie, which remembers which landing page you came to, is set only after you accept all.
Where you came from: your first visit
When you choose Accept all, we store in the mk_ft cookie (readable only by our server, for at most 12 months and never longer than your consent) which page you arrived on first, which website you came from and the campaign parameters in the address (utm_source, utm_medium, utm_campaign, utm_content, utm_term, gclid, fbclid and gbraid), together with the time. The page address is stored without its query string, and the latest page is refreshed on each visit. If you choose Only necessary cookies, or have not chosen yet, no such cookie is set and none of this is stored.
When you buy, and when you give your email address to receive your result, the first visit is copied to your order and your contact record, and to the payment at our payment provider as reference fields (ft_landing, ft_utm_source and others). We use it to know which channel produced the sale. The legal basis is consent (Article 6.1 a). If you withdraw your choice, the cookie and the copy on an unpaid order and on your contact record are erased. A paid order's copy follows the order's retention period, and contact records are deleted 90 days after they were given.
Reporting a mistake in a question
Under every question and explanation there is Report a mistake. When you send a report we store the question's id, the type of mistake you chose, your comment if you wrote one, the page you were on (without its query string), the language and the time. No login is needed. To limit reports per sender we use a keyed hash of your IP address; the IP address itself is not stored and the hash is erased after 24 hours. Reports are emailed once an hour to our support and used to correct questions, and are deleted after 12 months. The legal basis is legitimate interest (Article 6.1 f) in keeping the questions correct.
Measuring how the site is used
We measure how the site is used with our own measurement, on our own server. That measurement uses no cookie and no advertising network, and is a different thing from the conversion reporting described in the section after this one.
- We record events such as “diagnostic started”, “diagnostic completed”, “result shown”, “guide read” and “account created”, together with the page address, the language and the time.
- We record where the visit came from: a search engine, an ad campaign or a linking site, taken from the address parameters or the referring domain.
- So that we can tell whether the same visit both started and finished the diagnostic, a random identifier is kept in the browser's session storage and disappears when you close the tab. It cannot be linked to you and does not follow you between visits or between sites.
- We do not store your IP address, your email address or any individual answers alongside these events.
The legal basis is legitimate interest (Article 6(1)(f)) in knowing whether the service works. The data is used in aggregate and is not shared with anyone.
Conversion reporting to Meta (Facebook and Instagram)
The legal basis is consent (Article 6(1)(a) GDPR). After acceptance we send page views through the pixel and conversion events through Meta’s Conversions API: initiated checkout, confirmed purchase, account creation, offer views and completed diagnostics (and watchlist signups without their email addresses). Browser and server purchases share an event ID to avoid double counting.
We send the time, page address without query parameters, IP address, browser user agent, available _fbp/_fbc and ad click identifiers, value and currency. Account IDs and email addresses are SHA-256 hashed before transfer. At checkout we retain consent and these matching details with the order to report a later confirmed payment, even if the browser has closed. This uses consent recorded at checkout and does not run if that consent is missing or expired. Browser withdrawal stops new browser events and new checkout events; contact us to withdraw consent for an existing pending order before payment is confirmed.
We never share passwords, individual answers or watchlist email addresses with Meta. The recipient is Meta Platforms Ireland Limited, Dublin, Ireland. We and Meta are joint controllers for collection; Meta then processes data for its own purposes. US transfers use standard contractual clauses and the EU-US Data Privacy Framework. See Meta’s privacy policy.
Processors
We use the following processors. All of them process data on our instructions and under a data processing agreement.
| Processor | Role | Where data is processed |
|---|---|---|
| Neon (Neon Inc.) | Database holding account and study data | EU, Frankfurt, Germany |
| Cloudflare, Inc. | Delivery of the website, running the application at the edge, protection against overload | EU nodes; transfers to third countries under the EU standard contractual clauses |
| Transactional email provider | Sending confirmation emails and the notifications you asked for | EU. The provider is named here before sending opens to the public |
| Payment provider | Handling card payment and receipts for the full-access purchase | Processing within the EU/EEA. We store no card details. |
Recipients that are not processors
Meta Platforms Ireland Limited receives conversion events as described in the section above. Meta does not process them on our instructions but as a joint and thereafter independent controller, and is therefore not a processor.
We do not sell data. The only advertising network that receives anything is Meta, to the extent described above. That holds in particular for the watch lists: they are never uploaded to Meta, Google or any other advertising platform, in any form, and the addresses on them are excluded from the conversion events as well. We will not store card numbers.
How long we keep it
- Account data and study data: as long as you have an account.
- Login sessions: 90 days.
- Anonymous diagnostic results without an account: 90 days, then automatic deletion.
- An unconfirmed watch-list signup: deleted 30 days after the confirmation link expires.
- A confirmed watch-list signup: until the watched fact is published and the email has gone out, then at most 12 months, or until you unsubscribe.
- Records required by accounting law once payment is switched on: for as long as the law requires.
- The ad click id and the origin of the visit (campaign, source): 12 months in our own database, tied to the visit and not to an identified person. Data already disclosed to Meta is governed by Meta's own retention periods.
If you ask for deletion we remove your account, your answers and your results within 30 days, except for data we are legally required to keep.
Your rights
You have the right of access, rectification, erasure, restriction, data portability and to object to processing. Write to hej@medborgarklar.com and we will reply within 30 days. You also have the right to complain to a supervisory authority: in Luxembourg the Commission nationale pour la protection des données (CNPD), or the authority in the EU country where you live, in Sweden the Swedish Authority for Privacy Protection (IMY).
Children and young people
The service is aimed at people aged 16 and over, in line with the knowledge requirement applying from the age of 16. A person aged 16 or 17 is a minor; see the section on age and capacity to contract in the terms.
Changes
We update this policy when the processing changes, for example when payment opens. The date of the latest change is shown below.
Last updated: 8 October 2026.