Privacy Policy

Last updated June 2021

Contents

I. Name and address of the controller
II. Contact information of the Data Protection Supervisor
III. Data processing on the Intuedo platform
IV. Rights of the data subject
V. Platform availability and the creation of file logs
VI Use of cookies Registration
VIII. Newsletter
IX. Email contact
X. Contact form
XI. Business pages
XII. Use of business pages in professional networks
XIII. Remarketing
XIV. Partnership programmes
XV. Useful plugins

I. Name and address of the controller

The controller, in accordance with the General Data Protection Regulation and other national regulations for the protection of data in Member States, as well as other data protection provisions in place is:

Linguedo GmbH
Friedrich-Ebert-Anlage 36
60325 Frankfurt am Main
Germany
+49 89 4111 2778
datenschutz@Linguedo.de
www.linguedo.com

II. Contact information of the Data Protection Supervisor

The Data Protection Supervisor is:

DataCo GmbH
Dachauer Straße 65
80335 Munich
Germany
+49 89 7400 45840
www.dataguard.de

III. Data processing on the Intuedo platform

This page details the provisions in place regarding the protection of personal data on the Intuedo platform. The platform is part of what’s offered by Linguedo GmbH, Friedrich-Ebert-Anlage 36, 60325, Frankfurt am Main, Germany (hereinafter “Linguedo GmbH” or “we”):

  1. Scope of processing
    The Intuedo platform (https://intue.do/) is a combined eLearning app(s) on which content and exercises for learning the German language are held. Users may practise their own knowledge of the German language with the vocabulary, interactive videos, various exercises and grammar explanations that are made available. Furthermore, Intuedo works as a social network through which students may connect with each other and find groups and forums.

Functions of the platform
e-Learning

  • German lessons in the form of modules
  • Possibility to monitor individual progress by marking off modules and sections within the modules as “complete”.
  • Introduction module with explanatory videos on how to use the platform and an introduction to German pronunciation.
  • Interactive videos with repetition materials
  • Various quizzes “your turn” to deepen the knowledge learnt.
  • Grammar explanations
  • Contact module through which the users may send questions/comments via the platform to the Intuedo administrators.
  • Verifiable Gamification aspects in the awarding of points and classification of the best

Vocabulary app

  • Registration using the Intuedo account
  • Lexicon training every day
  • Progress tracker for the vocabulary learnt
  • Possibility to create mnemonic associations (continued)
  • Vocabulary practise
  • Creation of a personal learning plan
  • Learning reminders in the form of push notifications

Social platform

  • Personal profile with which the user can present themselves and, optionally, upload a profile photo and a banner.
  • Social groups in which the users may meet and connect with one another
  • Forum in which users may find out more about certain topics
  • A timeline (“community”) in which the users may see updates about others
  • Users may write posts
  • It is possible to comment and/or like other users’ posts
  • In the paid version, users may connect to one another
  • Private messages between users (only in the paid version, not in the free version)
  • Notifications regarding new private messages, friend requests, comments in groups and in the forum

Data processed when on the website:

  • IP address of the computer being used
  • Information about the type of browser and the version being used
  • User’s operating system
  • Website through which access occurred (referrer URL), date and time of access
  • Access data

e-Learning

  • Progress in the German course (course, modules, quizzes completed)
  • Passed/failed, individual results to the questions and percentage of quizzes and exercises completed

Vocabulary app

  • Time needed by the user to add vocabulary
  • Time spent by the user on the app
  • Correct/incorrect entries made by the user when entering vocabulary
  • Data on the user’s mobile device
  • Learning progress of each user for individual vocabulary
  • Created mnemonic associations

Social platform/network

  • Access statistics (time, date, duration, type of browser)
  • Notification in the event the password is changed
  • Data entered into the profile, e.g. Profile photo
  • All the user’s activity within the platform (changes to the profile, posts, comments, likes, status updates, etc.)

  1. Purpose of the processing
  • Improvement of the platform/our product
  • Supply of the platform and app’s functions (= the product)
  • Improvement of marketing via the analysis of behaviour and characteristics of the users.

  1. Legal basis for the processing of personal data
    The legal basis for the processing of data processing for the creation and use of a user’s account is the user’s consent as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.

The processing of the technical data is in the legitimate interests of our company to supply a functional platform to users and is as per Art. 6, para. 1, pg. 1, let. F) of the GDPR.

  1. Retention period
    Personal data collected by us in the contact form will be automatically deleted following a request to do so. Personal data collected by us based upon the usage agreement will be deleted as per Art. 6, para. 1, pg. 1, let. C) of the GDPR following the passing of the obligatory retention and documentation periods in place in accordance with tax and business laws (the German business code, HGB, the tax codes, StGB and AO), unless consent is not given for this data to be retained for longer as per Art. 6, para. 1, pg. 1, let. A) of the GDPR. The personal data collected by us to make the chat function available will be deleted nine months following the last contact from the user.
  2. Withdrawal of consent
    Consent to the processing of personal data may be withdrawn at any time by sending us an informal request via the contact form or email. Our email address is available on the platform and on our website.

IV. Rights of the data subject

Whenever your personal data is processed, you are considered a data subject as per GDPR and have the rights to the following from the controller:

  1. Right to information
    You may obtain confirmation from the controller whether or not data is being processing which concerns you.

If your data is being processed, you may obtain the following information from the controller:

  • The purpose of the personal data processing which concerns you;
  • The types of personal data which is being processed;
  • Third parties, or which type of third parties to which personal data concerning you is being shared;
  • The intended retention period for the personal data or, if there is no concrete information in this regard, the criteria used to determine such a period;
  • The existence of a right to the personal data concerning you to be deleted or rectified, a right to limit processing by the controller or a right to oppose its processing;
  • The right to make a claim to a supervisory authority;
  • All information about the origin of the data if it were not collected from the data subject;
  • The existence of an automated individual decision-making process, including profiling, as per Art. 22, para. 1 and 4 of the GDPR, unless, in such cases, suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.

You have the right to obtain information about whether personal data is transferred to third parties in Member States or international organisations. In this context, you may request an overview of the appropriate safeguards regarding the transfer in accordance with Art. 46 of the GDPR.

  1. Right to rectification
    You have the right to request rectification from the controller and/or the integration of the personal data being processed is incorrect or incomplete. The controller is obligated to rectify the data as soon as possible.
  2. Right to limit processing
    If one of the following occurs, you have the right to request that the controller limits the processing of the personal data concerning you:
  • If the correctness of the personal data concerning you is contested until such time as the controller can verify the correctness of such personal data;
  • If the processing is improper and if the deletion of personal data is opposed and it is requested to limit it;
  • Notwithstanding the data controller doesn’t have a need for it for the purposes of processing, the personal data is required by them for the investigation, exercising or defence of a third party in a court of law or
  • If you are opposed to the processing as per Art. 21, para. 1 whilst waiting for the verification based upon legitimate motives by the data controller as opposed to those of the data subject.

If the processing of personal data concerning you is limited, such data are processed, unless for retention, only with your consent or for investigation, exercising or defence of a third party in a court of law, or for the protection of the rights of another person or legal entity or for reasons of public interest relevant to the European Union or a Member State.

If you have obtained a limitation on processing based upon one of the conditions mentioned above, you will be informed by the controller before the limitation is revoked.

  1. The right to be forgotten
  2. a) Deletion obligation
    You may request that the controller delete the personal data concerning you without due delay and the controller is obligated to delete all data without due delay if one of the following reasons exist:
  • The personal data concerning you are no longer required for the purposes they were collected or other processing;
  • You withdraw your consent for which the processing is based in accordance with Art. 6, para. 1, pg. 1, let. A), or Art. 9, para. 2, let. A) of the GDPR and if there is no other legal basis for the processing.
  • You oppose the processing as per Art. 21, para. 1 of the GDPR, and there is no legitimate reason in place to continue with the processing, or you oppose the processing as per Art. 21, para. 2 of the GDPR.
  • The personal data were processed illegally;
  • The deletion of the personal data concerning you is necessary to fulfil a legal obligation that requires the legal processing by the European Union or a Member State to which the controller is subject.
  • The personal data concerning you has been collected in regard to a direct service offer of an online company in accordance with Art. 8, para. 1 of the GDPR.
  1. b) Information to third parties
    Whenever the data controller has made the personal data public and is obligated, as per Art. 17, para. 1 of the GDPR, to delete it, taking into consideration the available technology and the costs to do so, adopts reasonable measures, including those technical, to inform the data controllers that it involves personal data of the data subject to delete any links, copies or reproductions of your personal data.
  2. c) Exceptions
    The right to be forgotten does not apply if the processing is necessary:
  • For the third party’s right to freedom of expression and information.
  • To carry out a legal obligation that requires the processing as per the law of the European Union or the Member State to which the controller is subject or the carrying out of work in the public interest or if the controller is required to carry out the work of public authorities;
  • For public interest reasons in regard to public health, in accordance with Art. 9, para. 2, let. H) and i) and Art. 9, para. 3 of the GDPR.
  • For archiving, scientific research, historical research or statistical purposes in the public interest in accordance with Art. 89, para. 1 of the GDPR, to the extent that it risks making impossible, or seriously damages the attainment of the right in para. 1 of the objectives of such processing, or
  • For the investigation, exercising or defence of a third party in a court of law.
  1. Right of notification
    If the right to rectification, deletion or limitation of processing has been asserted, the controller is obligated to communicate to all third parties to whom the personal data has been transferred the possible rectifications or deletions or limitations of the processing, unless it is impossible to do so, or there would be disproportionate effort required.

You have the right to request information about such third parties from the data controller.

  1. Right to data portability
    You have the right to receive from the data controller the personal data concerning you in a structured format, in common use which may be read by common devices; Furthermore, you have the right to transfer that data to another data controller without any impediment on the part of the data controller to whom you supplied the data:
  • The processing is based upon consent as per Art. 6, para. 1, pg. 1, let. A) of the GDPR, or Art. 9, para. 2, let. A) of the GDPR, or an agreement as per Art. 6, para. 1, pg.1, let. B; and
  • The processing occurs during automatic means.

In exercising this right, you also have the right to direct transfer of the personal data from one data controller to another, if technically feasible. This right may not infringe the rights and freedoms of others
The right to portability of data does not apply to the processing of personal data required to carry out a task in the public interest or connected to the work of public authorities in which the data controller is invested.

  1. Right to object
    You have the right to object to the processing of personal data concerning you, at any time, for reasons relating to your own situation, as per Art. 6, para. 1, pg. 1, let. E) or F) of the GDPR, including the profiling of such provisions.

The data controller abstains from further processing of personal data, unless it can demonstrate relevant legitimate reasons to continue processing which are relevant to the interests, rights and freedom of the subject or for the investigation, exercising or defence of a third party in a court of law.

In the event that the personal data are processed for direct marketing purposes, you have the right to object to the processing of the personal data concerning you for this reason at any time, including the profiling to the extent in which it is connected to direct marketing.

In the event that you object to processing for direct marking, personal data may not be used for this purpose.

In the context of the using services of online companies and without prejudice to 2002/58/CE, you have the possibility to exercise your right to object to automatic systems which use specific technology.

  1. Right to withdraw consent
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.
  2. Automated individual decision-making process, including profiling
    You have the right to not be subject to a decision based only on automated processing, including profiling, which may have legal ramifications which may concern you or which significantly affect in the same manner your person. This is regardless of the decision made
  • It can be done should it be necessary for the completion of a contract between yourself and the data controller,
  • It may also be done if authorised under European Union law or that of the Member State in to which the data controller is subject, and sets out other adequate measures to protect the rights, of its freedoms and legitimate interests
  • This is based upon explicit consent.

Still, such decisions cannot be based on certain personal data categorised in particular, in Art. 9, para. 1 of the GDPR, unless not applied in Art. 9, para. 2, let. A) or B) of the GDOR and adequate measures are adopted to protect the rights, freedoms and legitimate interests.

In the above-mentioned cases in 1–3, the data controller should take appropriate measures to protect the rights, freedoms and legitimate interests, unless the right to have a human intervention on behalf of the data controller exists, as well as the right to express one’s own opinion and contest the decision.

  1. The right to make a claim to a supervisory authority
    Notwithstanding any other administrative or legal recourse, so long as the processing of the data concerning you violates this law, you have the right to make a claim to a supervisory authority, specifically in the Member State in which you are currently living, work or in the location in which the presumed violation of the GDPR takes place.

The supervisory authority to which you must make your claim will inform the claimant of the status or possibility of a claim, including the right to any legal recourse as per Art. 78 of the GDPR.

V. Platform availability and the creation of file logs

  1. Description and scope of application for the processing of personal data
    Every time that you visit the platform, our system automatically collects data and information from the system of the computer from which the visit is being undertaken.

In this context, the following data is collected:

  • Information about the type of browser and the version being used
  • The user’s IP address
  • The user’s operating system
  • Time and date of the access

To protect our system from fraud and hacking we use a local version of Wishlist Member. In this context, there is no transfer of data.
This data is saved in our system in the file logs. This data is not stored together with the personal data of the user.

  1. Purpose of the processing
    The temporary saving of the IP address via the system is necessary so that the platform can be shown on the user’s computer. For this reason, the user’s IP address is saved until the end of the session.

This saving in log files is done to guarantee the functionality of the platform. Furthermore, this data allows us to optimise the platform and to ensure the security of our IT systems. In this context, there is no right to use such data for marketing purposes.

Among these purposes, there are also our legitimate interests to process the data as per Art. 6, para. 1, pg. 1, let. F) of the GDPR.

  1. Legal basis for the processing of personal data
    The legal basis for the temporary storing of data in regard to the usage of our business is Art. 6, para.1, pg. 1, let. F) of the GDPR.
  2. Retention period
    Data is deleted as soon as it is no longer necessary for the purposes for which it was collected. In the case of data collection to run the platform, it is deleted as soon as the session is ended.

In the case of storage in file logs, no longer than seven days. It is possible that it may be stored longer than this. In such a case the IP addresses of the users will be deleted or stored anonymously so that there is no way to discover the identity of the customer visiting the site.

  1. Right to withdraw consent and deletion
    The collection of data to run the platform and the saving of data in file logs are strictly necessary for the functionality of the platform. As a result, the user cannot object to its use.

VI. Use of cookies

  1. Description and scope of application for the processing of personal data
    Our platform uses cookies. Cookies are small text files that are saved on the internet browser or from the internet browser on the operating system of the user. If a user visits the platform, it is possible to save a cookie to the user’s operating system. This cookie has a sequence of distinctive characters which allows for the device to be recognised uniquely when it accesses the platform again.
    We use cookies to facilitate the user’s use of the platform. Some elements of our website require the browser visiting the website to be able to be identified even when the page is changed.

The following is also saved alongside cookies:

  • Access information
  • Frequency in which the website is accessed
  • Use of functions on the platform
  • Demographic data
  • Metadata of the client on the website
  • Origin of the traffic
  • Data from the eLearning quizzes
  • Completed eLearning lessons
  • Information about the functionality of the platform (e.g. error messages, time taken to load a page)
  1. Purpose of the processing
    The purpose of using the necessary cookies is to facilitate the user’s use of the platform. Some functions of our website cannot be used without the use of these cookies. Such functions require that the browser be recognised even when changing the page.

We use cookies for the following applications:

  • Technical cookies to make the platform available
  • Social network notifications
  • Group notifications
  • Social network activities
  • Membership in the groups (for users who have access)
    Wishlist registration
  • Gamipress
  • Elementor to correctly display the page
  • Cookie Consent, in other words, which cookies the user has agreed to for future visits
  • To save the login/remember me option

The data collected on the users via technical cookies are not used to create user profiles.

  1. Legal basis for the processing of personal data
    The legal basis for the processing of data via the use of technical cookies is Art. 6, para.1, pg. 1, let. F) of the GDPR.
  2. Duration to store, right to object and deletion
    Cookies are stored on the user’s computer and transferred to our page from there. For this reason, you as the user, have complete control over the use of cookies. By changing the settings on your computer’s browser you can deactivate and limit the transfer of data. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If you deactivate cookies for our platform, it may not be possible to use all the platform’s features entirely.

VII. Registration

  1. Description and scope of application for the processing of personal data
    We offer our users the possibility of registering on our website with their personal data. This data is entered into the data entry fields and transferred to us and saved. There is no transfer to third parties. During the process the following data is collected:
  • Email address
  • Pseudonym
  1. Purpose of the processing
    To access all social network functions, the user should have a unique account.
  2. Legal basis of the processing of personal data
    The processing of data occurs following your login or registration and is necessary in accordance with Art. 6, para. 1, pg. 1, let. A) of the GDPR for the purposes set out above in order to use the platform correctly and for both parties to carry out their obligations as set out in the usage agreement.
  3. Retention period
    Data is deleted as soon as it is no longer necessary for the purposes for which it was collected.

With regard to the data collected during the registration process, this occurs as soon as the registration on our website is cancelled or amended.

  1. Right to withdraw consent and deletion
    As a user, you have the right to cancel your registration at any time. You can amend your personal data at any time.

To request that your personal data be deleted, please send an email to datenschutz@Linguedo.de

VIII. Newsletter

  1. Description and scope of application for the processing of personal data
    You can sign up to the newsletter free of charge. To this end, when signing up to the newsletter the following data is entered into the data entry field and transferred to us:
  • Email address

In order to process the data, during registration, you will be asked to consent and you will be informed of our privacy policy.

In the context of data processing for the newsletter, there is no transfer of data to third parties. This data will be used exclusively to send the newsletter.

  1. Purpose of the processing
    The user’s email address is required to send the newsletter.
  2. Legal basis for the processing of personal data
    The legal basis for processing data with regard to the newsletter is the express consent of the user as per Art. 6, para.1, pg. 1, let. F) of the GDPR.
  3. Retention period
    Data is deleted as soon as it is no longer necessary for the purposes for which it was collected. The user’s email address will be saved so long as the subscription to the newsletter remains active.

Other personal data obtained during the subscription process will be automatically deleted after a maximum of seven days.

  1. Right to withdraw consent and deletion
    The user may unsubscribe from the newsletter at any time. To this end, there is an unsubscribe link contained within every newsletter.

This link also allows the withdrawal of consent to store the data collected during the subscription process.

IX. Email contact

  1. Description and scope of application for the processing of personal data
    On our platform it is possible to contact us using the email address provided. In such a case, the user’s personal data transferred by email will be saved.

This data will be used exclusively for the conversation taking place.


  1. Purpose of the processing
    In the case of email contact, the necessary legitimate interests concern the processing of data.
  2. Legal basis for the processing of personal data
    The legal basis for the processing and the express consent of the user is Art. 6, para.1, pg. 1, let. F) of the GDPR.

Legal basis for the processing of data transferred when sending an email is Art. 6, para.1, pg. 1, let. F) of the GDPR. There is a further legal basis if the email is used to conclude a contract as per Art. 6, para.1, pg. 1, let. F) of the GDPR.

  1. Retention period
    Data is deleted as soon as it is no longer necessary for the purposes for which it was collected. For personal data which is sent by email, this occurs as soon as the conversation with the user has ended. The conversation is considered finished when under the circumstances, the item in question has been clarified in a complete manner.

Other personal data obtained during the process will be automatically deleted after a maximum of seven days.

  1. Right to withdraw consent and deletion
    The user has the right to withdraw consent with regard to the processing of personal data at any time. If the user contacts us by email they may object to the retention of personal data concerning them at any time. In such a case, it will not be possible to carry on the conversation.

For this reason, please send an email to datenschutz@Linguedo.de.

All personal data saved during the contact will be deleted in this instance.

X. Contact form

  1. Description and scope of application for the processing of personal data
    On our platform there is a contact form that may be used to contact us electronically. If the user uses this option, the data entered into the data entry field will be transferred to us and saved.
    When sending the message the following data will be saved:
  • Email address
  • Name (optional)
  • IP address of the computer being used
  • Time and date

In order to process the data, when contacting us, you will be asked to consent and you will be informed of our privacy policy.

Alternatively, you can contact us using the email address provided. In such a case, the user’s personal data transferred by email will be saved.

This data will be used exclusively for the conversation taking place.

  1. Purpose of the processing
    The processing of the data entered in the data entry field is used by us only for the contact. In the case of email contact, the necessary legitimate interests concern the processing of data.

Any other personal data processed when sending are to prevent the improper use of the contact form and to ensure the security of our IT systems.

  1. Legal basis for the processing of personal data
    The legal basis for the processing and the express consent of the user is Art. 6, para.1, pg. 1, let. F) of the GDPR.

The legal basis for the processing of data transferred when sending an email is Art. 6, para.1, pg. 1, let. F) of the GDPR. There is a further legal basis if the email is used to conclude a contract as per Art. 6, para.1, pg. 1, let. B) of the GDPR.

  1. Retention period
    Data is deleted as soon as it is no longer necessary for the purposes for which it was collected. For personal data which is entered in the data entry field of the contact form and sent by email, this occurs as soon as the conversation with the user has ended. The conversation is considered finished when under the circumstances, the item in questions has been clarified in a complete manner.

Other personal data obtained during the process will be automatically deleted after a maximum of seven days.

  1. Right to withdraw consent and deletion
    The user has the right to withdraw consent with regard to the processing of personal data at any time. If the user contacts us by email they may object to the retention of personal data concerning them at any time. In such a case, it will not be possible to carry on the conversation.

For this reason, please send an email to datenschutz@Linguedo.de.

All personal data saved during the contact will be deleted in this instance.

XI. Business pages

The use of our business pages on social networks.

Facebook:
Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Republic of Ireland

On our business page we share information and offer Facebook users the opportunity to communicate with us. More information about our pages on Facebook can be found here: https://it-it.facebook.com/policy.php

Instagram:
Instagram, Part of Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2 Republic of Ireland

On our business page we share information and offer Instagram users the opportunity to communicate with us. It is possible that by interacting with our business page (for example, by commenting, posting, liking, etc.) you may make public personal data (e.g. real name or profile photo). Due to laws and the fact that we do not have any influence on the processing of your personal data collected by Instagram when you interact with Linguedo GmbH’s pages, we cannot give you any information in regard to the purpose and scope of processing.

Our business pages on social networks are used to communicate and exchange information with (potential) customers. In particular, we use our business pages to:

promote, with potential prospects, interesting partnerships with some hospitals and share other interesting information

In such a case the published material regarding our business pages can be about the following content:

  • Information about products
  • Information about services
  • Prize competitions
  • Advertising
  • Customer contact

In such a context, each user is free to decide to publish their personal data when engaging.

The legal basis for this processing of data is Art. 6, para. 1, let. A) of the GDPR.

Data transferred through our business pages is not stored on our own systems.

You can object to the processing of your personal data, which we collect in the process of you using our Instagram page, at any time and have rights as the data subject, as set out in point IV of this privacy policy. In order to do so, sent an email requesting the deletion of your data to datenschutz@Linguedo.de For anything that concerns your personal data via Instagram and the right to object, you can find more information here:

Instagram: https://help.instagram.com/519522125107875

YouTube:
YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States

On our business page we share information and offer YouTube users the opportunity to communicate with us. It is possible that by interacting with our business page on YouTube (for example, by commenting, posting, liking, etc.) you may make public personal data (e.g. real name or profile photo). Due to laws and the fact that we do not have any influence on the processing of your personal data collected by YouTube when you interact with Linguedo GmbH’s pages, we cannot give you any information in regard to the purpose and scope of processing.

Our business pages on social networks are used to communicate and exchange information with (potential) customers. In particular, we use our business pages to:

promote, with potential prospects, interesting partnerships with some hospitals and share other interesting information
In such a case the published material regarding our business pages can be about the following content:

  • Information about products
  • Information about services
  • Prize competitions
  • Advertising
  • Customer contact

In such a context, each user is free to decide to publish their personal data when engaging.

The legal basis for this processing of data is Art. 6, para. 1, let. A) of the GDPR.
Data transferred through our business pages is not stored on our own systems.

You can object to the processing of your personal data, which we collect in the process of you using our YouTube page, at any time and have rights as the data subject, as set out in point IV of this privacy policy. In order to do so, sent an email requesting the deletion of your data to datenschutz@Linguedo.de For anything that concerns your personal data via YouTube and the right to object, you can find more information here:
YouTube: https://policies.google.com/privacy?gl=DE&hl=de

TikTok
TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Republic of Ireland

On our business page we share information and offer TikTok users the opportunity to communicate with us. It is possible that by interacting with our business page on TikTok (for example, by commenting, posting, liking, etc.) you may make public personal data (e.g. real name or profile photo). Due to laws and the fact that we do not have any influence on the processing of your personal data collected by TikTok when you interact with Linguedo GmbH’s pages, we cannot give you any information in regard to the purpose and scope of processing.
Our business pages on social networks are used to communicate and exchange information with (potential) customers. In particular, we use our business pages for:

  • Advertising
  • Prize competitions
  • Information about offers
  • Information about products
  • Customer contact

The published material via our business pages can be about the following content:

  • Information about products
  • Prize competitions
  • Advertising
  • Customer contact
  • Current or possible

In such a context, each user is free to decide to publish their personal data when engaging.

The legal basis for this processing of data is Art. 6, para. 1, let. A) of the GDPR.
We save published activities and personal data collected via our TikTok business page up until the time when consent is withdrawn. Furthermore, the retentions periods applicable by law are valid.
Furthermore, we process the data collected from our business page in our systems. Such data is stored for the following time period: 12 months
You can object to the processing of your personal data, which we collect in the process of you using our TikTok page, at any time and have rights as the data subject, as set out in point IV of this privacy policy. In order to do so, sent an email requesting the deletion of your data to datenschutz@Linguedo.de For anything that concerns your personal data via TikTok and the right to object, you can find more information here:
TikTok: https://www.tiktok.com/legal/privacy-policy?lang=de

XII. Use of business pages in professional networks

  1. Scope of the processing
    We take advantage of being able to be present as a business on professional networks. Our company has a presence on the following professional networks:

LinkedIn:
LinkedIn, Unlimited Company Wilton Place, Dublin 2, Republic of Ireland

On our business page we share information and offer users the opportunity to communicate with us.

Our business page is used for candidates, information/PR and Active Sourcing.

We do not have information with regard to your personal data which is held at the other responsible party for our business page at our company. You can find more information about the processing of data by

LinkedIn here:
https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

It is possible that by interacting with our business page (for example, by commenting, posting, liking, etc.) you may make public personal data (e.g. real name or profile photo).

  1. Legal basis for the processing of personal data
    The legal basis for the processing of data in regard to the usage of our business page is Art. 6, para.1, pg. 1, let. F) of the GDPR.
  2. Purpose of the processing
    Our business page allows us to inform users about our services. In such a context, each user is free to decide to publish their personal data when engaging.
  3. Retention period We save published activities and personal data collected via our business page up until the time when consent is withdrawn. Furthermore, the retentions periods applicable by law are valid.
  4. Right to withdraw consent and deletion

You can object to the processing of your personal data, which we collect in the process of you using our business page, at any time and have rights as the data subject, as set out in point IV of this privacy policy. In order to do so, please send an email to the address available in this privacy policy.

You can find more information about the right to withdraw and deletion here:

LinkedIn:
https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

XIII. Remarketing

We use IP addresses and other information provided by the user (in particular, the postcode entered during registration or an order process) for geotargeting purposes.

Remarketing communication is used, for example, to allow users to see local offers and adverts which are more relevant to them. The legal basis for using an IP address and any other information provided by the user (in particular, the postcode), is Art. 6, para. 1, let. F) of the GDPR, which is based upon our interests in using precise geotargeting communication and, therefore, supplying offers and adverts which are more relevant to the user.

In this context, some of the IP addresses, as well as additional information supplied by the user (in particular, the postcode), are only extracted and are not stored separately.

You can avoid the use of geotargeting by using a VPN or proxy server, which prevents your precise location from being used.

We use geotargeting on our platform for the following purposes:

  • Advertising
  • Marketing

XIV. Partnership programmes

Furthermore, we use the following partnership programmes:

DigiStore24
1. Scope of application for the processing of personal data
We use DigiStore24 as a reseller to upgrade our product. In the case of an upgrade, with the user’s consent, we transfer the pseudonym, email address and user’s ID to DigiStore24 in order to carry out the upgrade. You can find more information about the processing of data by DigiStore24 here:

Imprint
https://www.digistore24.com/page/imprint
Usage conditions
https://www.digistore24.com/page/terms
Data protection
https://www.digistore24.com/page/privacy

  1. Purpose of the processing
    The transfer of data as mentioned above to DigiStore24 occurs in order to upgrade the user’s account.
  2. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  3. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.
  4. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.

XV. Used plugins

We use plugins for various purposes. The plugins used are listed below:

Cookiebot use

  1. Scope of application for the processing of personal data

We use the functionality of Cookiebot from Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark to collect cookie consent.

Cookiebot offers software which collects consent for the use of cookies and to track users online. Cookiebot informs users of our website about the cookies used on the website. Furthermore, you have the possibility to deactivate groups of cookies, except functional cookies (necessary for the website to be displayed correctly). As per Art. 7, para. 1 of the GDPR we are required to document your consent or your refusal to consent to cookies.
By doing so, the following personal data, in particular, is processed via Cybot:
– IP address of the end user in an anonymous manner (the last three digits are transferred with “0”).
– time and date of consent
– end user’s browser
– URL entered for consent
– encrypted, anonymous and causal key
– state of end user’s consent, which is proof of authorisation.

In order to do this Cybot adds a cookie to your computer
The key and the state of consent are also saved on the end user’s browser as a cookie (CookieConsent), in order to allow the website to automatically read and apply the user’s consent for all future visits to the page and the end user’s future sessions up to a maximum of 12 months. The key is used to prove authorisation and as an option through which the authorisation stored on the end user’s browser can be verified and has not been changed since original consent was given via Cybot.
If the function “Multiple Authorisations” is active, you can authorise consent to multiple websites with one authorisation, Cybot will then save a separate, unique, causal ID, with the end user’s consent. If all the following criteria are satisfied, this key will be stored in the end user’s browser as an encrypted cookie “CookieConsentBulkTicket”.

All data is hosted in an Azure data centre from the provider Cloud Microsoft Ireland Operations Ltd, South County Business Park, One Microsoft Court, Carmanhall and Leopardstown, Dublin, D18 P521, Republic of Ireland.
You can find more information about the processing of data by Cybot here:
https://www.cookiebot.com/de/privacy-policy/

  1. Purpose of the processing

The use of Cookiebot is for the creation and display of information about cookies to the end user and for the saving and display of cookie scan reports in the privacy policy. By doing so we can comply with our IT obligations in regard to the users of our website as per Art. 13, 14 of the GDPR, and collect and document consent in accordance within the framework of the GDPR for the use of cookies.

Furthermore, we use Cookiebot to receive aggregated information on the choices of users regarding the types of cookies they accept and a graphic representation of this in the service manager.

  1. Legal basis of the processing of personal data

The legal basis for this processing of data is Art. 6, para. 1, let. F) of the GDPR. In this context, our legitimate interests consist in the purposes mentioned in point 2 for the processing of data. The interests and rights of the users are also protected via the anonymity of the IP address.

  1. Retention period

Your personal information will be stored by Cybot for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.

The cookies used by Cookiebot will be stored for a maximum of 12 months on the user’s device.

  1. Right to withdraw consent and deletion

By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Cybot, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net) or Ghostery (https://www.ghostery.com) on your browser.

You can find more information about the right to withdraw and cancellation regarding Cybot here
https://www.cookiebot.com/de/privacy-policy/

Use of Facebook Pixel

  1. Scope of application for the processing of personal data
    Via our online business page we use Facebook Pixel, provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA and its representative in the European Union, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal H, D2 Dublin, Republic of Ireland (hereinafter Facebook). Thanks to their support we can trace the actions of users after they have seen or clicked on a Facebook post. Through this process, some data may be saved and evaluated, in particular, that relevant to the user’s activity (such as which pages were visited and which elements were clicked on), information about the device and the browser (such as the IP address and the operating system), data on the posts viewed (such as which posts appeared and which ones were clicked on) as well as commercial partner data (such as user ID in a pseudonym). In this way, we can review the effectiveness of Facebook posts for statistical and market research purposes.
    In this context, it is possible that the data is transferred to Facebook servers in the USA. The data collected in this way, is anonymous for us, this is to say, that we cannot see individual user’s data. The storage and processing of such data are carried out by Facebook. Facebook may connect this data with your Facebook account and also use it for promotional purposes in accordance with Facebook’s policy on using data.

You can find more information about the processing of data by Facebook
https://de-de.facebook.com/policy.php

  1. Purpose of the processing
    The use of Facebook Pixel is to analyse and optimise promotional material.
  2. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  3. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.
  4. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.

You can find more information about the right to withdraw and cancellation regarding Facebook here
https://de-de.facebook.com/policy.php

Use of Facebook Retargeting

  1. Scope of application for the processing of personal data
    We use the functions of the Facebook Retargeting plugin from Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Republic of Ireland (hereinafter Facebook Retargeting).

Facebook Retargeting is used to develop advertising campaigns and interactions with them. Via Facebook Retargeting some users are reminded of products which they have searched for or considered but not purchased. In order to do this Facebook adds a cookie to your computer
By doing so, the following personal data, in particular, is processed via Facebook:

– information of the user’s activities

– websites visited

– which products were shown

– which posts were clicked on

– information about the device, in particular, the type of device, IP address

– users Facebook account, if they logged into Facebook

In such context, the data is processed on Facebook Inc’s servers, Facebook, Inc., 1601 Willow Road, Menlo Park, California 94025 in the United States. Facebook has joined the agreement between the European Union and the United States, The EU/USA Privacy Shield and has been certified. In this context, Facebook is obligated to respect the standards and laws set out by the European Union on the protection of data. You can find more information on the following paragraph by following this link: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
Other receivers of data are suppliers and employees of Facebook Inc., e.g. for analysis purposes.
You can find more information about the processing of data by Facebook
https://de-de.facebook.com/privacy/explanation

  1. Purpose of the processing
    The use of Facebook Retargeting is to activate adverts on different platforms and to analyse user interactions with these advertising posts. By doing so, we seek to show users personalised adverts which are, therefore, more relevant.
  2. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  3. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.
  4. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.

By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Facebook, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.

To deactivate personalised advertising for Facebook users, they must be logged in and use the following link:
https://www.facebook.com/settings/?tab=ads

You can find more information about the right to withdraw and cancellation regarding Facebook here:

https://de-de.facebook.com/privacy/explanation

Use of Facebook Lookalike Audience

  1. Scope of application for the processing of personal data
    We use the functions of the Facebook Lookalike Audience from Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Republic of Ireland (hereinafter Facebook Retargeting).

With Facebook Lookalike Audience we can add other Facebook users to our target audience if they have similar attributes to our customers and users of Facebook Custom Audience by Facebook Inc. As a result, these users will receive personalised marketing content from our company within Facebook. Facebook chooses target people through Lookalike Audience registering users’ common characteristics on Facebook Custom Audience, for example, demographic information and interests and then comparing them.

In order to do this Facebook adds a cookie to your computer
By doing so, the following personal data is processed via Facebook:

  • Demographic information
  • User data

You can find more information about the processing of data by Facebook
https://www.facebook.com/legal/terms/customaudience

https://www.facebook.com/about/privacy

https://www.facebook.com/policies/cookies

  1. Purpose of the processing
    The use of Facebook Lookalike Audience is to expand our target groups and display marketing content via Facebook’s advertising services to our target group.
  2. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  3. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.
  4. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.

By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Facebook, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.

You can find more information about the right to withdraw and cancellation regarding Facebook here:

https://www.facebook.com/legal/terms/customaudience

https://www.facebook.com/about/privacy

Use of Google Analytics incl. Google Analytics Remarketing

  1. Scope of application for the processing of personal data
    We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Republic of Ireland (hereinafter Google).

Google Analytics analyses, for example, the visitors’ origin, their time spent on a single page as well as the search engine used and allows for better monitoring of advertising campaign success. In order to do this Google adds a cookie to your computer By doing this, some data may be saved and evaluated, such as:

  • The user’s activity (in particular, which webpages were visited and which elements were clicked on);
  • Information about the devices and browser (in particular, the IP address and the operating system);
  • Data on the posts viewed (in particular, which posts were displayed and if the user clicked on them);
  • Commercial partner data (in particular, user ID as a pseudonym).

We use Google Analytics to evaluate your use of our online business pages, to create reports on their use and to use further Google services connected to the use of our online presence and the use of the internet.

Furthermore, we use Google Analytics Remarketing with which personal data concerning you is collected and evaluated to present you with adverts seen before. To use this Google service, we also associate data with our Google Ads account. Google Ads is also provided by Google.

We requested the anonymisation of IP addresses, therefore, Google shortens your IP address as soon as possible and in accordance with technical possibilities. Only in exceptional cases will the complete IP address be transferred to a Google server in the USA and then abbreviated there.

Google transfers personal data concerning you to partner companies as well as others responsible for the processing.

You can find more information about the processing of data by Google here:
https://policies.google.com/privacy?gl=DE&hl=de

  1. Purpose of the processing
    The use of Google Analytics, including Google Analytics Remarketing, is done to evaluate the use of our online business page as well as the display of advertising to people who have already expressed an interest due to them visiting our website.
  2. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  3. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes. The advertising data remains anonymous in records on servers with Google, as declared by Google itself, and partial IP addresses and cookie information will be deleted after 9 or 18 months.
  4. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.

By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Google, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net) or Ghostery (https://www.ghostery.com) on your browser.

You can find more information about the right to withdraw and cancellation regarding Google here:
https://policies.google.com/privacy?gl=DE&hl=de

Furthermore, you can prevent the collection of data generated by cookies and which refers to your online presence (incl. Your IP address) by Google and the processing of this data by Google by downloading and installing the browser plugins available at this link: https://tools.google.com/dlpage/gaoptout?hl=de

Using the following link you can deactivate the use of your personal data from Google: https://adssettings.google.de

Use of Google Tag Manager

  1. Scope of application for the processing of personal data
    We use Google Tag Manager (https://www.google.com/intl/de/tagmanager/), a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the European Union, Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Republic of Ireland (hereinafter Google). With Google Tag Manager it is possible to manage the tags of Google services and third party providers and integrate them together on online pages. The tags are small elements of code about an online page, which occur, for example, to measure the number and behaviour of visitors, to register the effect of online advertising and social networks, to carry out remarketing campaigns and orient them to target groups and to test and optimise online pages. When a user visits an online page, the current configuration of the tag is sent to the user’s browser. This configuration contains information on which tags should be activated. Google Tag Manager can activate other tags, which under certain circumstances, can cause the collection of data themselves. You will find information with regard to this in the passages relative to using corresponding services in this privacy policy. Google Tag Manager does not have access to this data. You can find more information about Google Tag Manager at https://www.google.com/intl/de/tagmanager/faq.html and in Google’s privacy policy:
    https://policies.google.com/privacy?hl=de
  2. Purpose of the processing
    The purpose of the processing of this data is the clear group management and efficient integration of third parties.
  3. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  4. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy or as is necessary by law. The advertising data remains anonymous in records on servers with Google, as declared by Google itself, and partial IP addresses and cookie information will be deleted after 9 or 18 months.
  5. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.
    By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Google, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.
    Furthermore, you can prevent the collection of data generated by cookies and which refers to your online presence (incl. Your IP address) by Google and the processing of this data by Google by downloading and installing the browser plugins available at this link:
    https://tools.google.com/dlpage/gaoptout?hl=de
    With the following link you can disable the use of your personal data by Google:
    https://adssettings.google.de
    You can find more information about the right to withdraw and cancellation regarding Google here:
    https://policies.google.com/privacy?gl=DE&hl=de

Use of Google AdWords

  1. Scope of application for the processing of personal data
    We use Google AdWords, a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the European Union, Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Republic of Ireland (hereinafter Google). With this service we post advertisements. In order to do this Google adds a cookie to your computer Through this process, some data may be saved and evaluated, in particular, that relevant to the user’s activity (such as which pages were visited and which elements were clicked on), information about the device and the browser (such as the IP address and the operating system), data on the posts viewed (such as which posts appeared and which ones were clicked on) as well as commercial partner data (such as user ID in a pseudonym).
    You can find more information about the processing of data by Google here: https://policies.google.com/privacy?gl=DE&hl=de
  2. Purpose of the processing
    We only receive information on the total number of users who have reacted to our posts. No information is shared which would allow us to identify you. The use does not allow your identity to be discovered.
  3. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  4. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.
  5. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.
    By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Google, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.
    Using the following link you can deactivate the use of your personal data from Google:
    https://adssettings.google.de
    You can find more information about the right to withdraw and cancellation regarding Google here:
    https://policies.google.com/privacy?gl=DE&hl=de

Use of Google Optimize



  1. Scope of application for the processing of personal data
    We use functions of Google Optimize, a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the European Union, Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Republic of Ireland (hereinafter Google).
    Google Optimize is used to increase the attractiveness, the functionality and the content of websites by evaluating different usage statistics.
    In order to do this Google adds a cookie to your computer By doing so, the following personal data is processed via Google:
  • IP address (anonymised)
  • User ID

In this context, it is possible that the data is transferred to Google servers in the USA. Google has joined the agreement between the European Union and the United States, The EU/USA Privacy Shield and has been certified. In this context, Google is obligated to respect the standards and laws set out by the European Union on the protection of data. You can find more information on this using the link below: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
You can find more information about the processing of data by Google here: https://policies.google.com/privacy?gl=DE&hl=de

  1. Purpose of the processing
    The use of Google Optimize is to increase the attractiveness of web content.
  2. Legal basis for the processing of personal data
    The legal basis for the processing of data is Art. 6, para.1, pg. 1, let. F) of the GDPR. In this context, our legitimate interests consist in the purposes mentioned in point 2 for the processing of data.
  3. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.

Cookie

duration

_gaexp

3 months

You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.

  1. Right to withdraw consent and deletion
    By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Google, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.
    You can find more information about the processing of data by Google here: https://policies.google.com/privacy?gl=DE&hl=de

Use of Hotjar

  1. Scope of application for the processing of personal data

We use Hotjar, a web analytics service provided by Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141, Malta (hereinafter Hotjar).


We use Hotjar to better understand the needs of our users and to optimise the service and experience. Hotjar is a technological service which helps us to better understand our users’ experience (e.g. how long they send on which pages, which links do they click on, what do they like and dislike, etc.) and this allows us to create and sustain our service using the users’ feedback. Hotjar uses cookies and other technology to collect data about our users’ behaviour and their devices: Device IP address (collected during the session and stored in a way that it cannot be identified), screen dimensions, type of device (unique identifiers of the device), browser information, location (only the country) and the preferred language to display our website. Hotjar remembers this information on our behalf in an anonymised user profile. Hotjar is contractually banned from selling information collected on our behalf.

For more detailed information, see the “Information about Hotjar” on the Hotjar support site.

  1. Purpose of the processing
    The use of Hotjar, including Google Analytics, allows us to evaluate the use of our online pages as well as to better understand our users’ requirements and to optimise the service and experience.
  2. Legal basis of the processing of personal data

The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.

  1. Retention period

Your personal information will be stored by Hotjar for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.

  1. Right to withdraw consent and deletion

You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal.

By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Google, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net) or Ghostery (https://www.ghostery.com) on your browser.

Use of Bootstrap

  1. Scope of application for the processing of personal data
    We use the OpenSource Framework Bootstrap This is loaded via the content delivery network bootstrapcdn.com. The provider of this service is MaxCDN DBA StackPath, 2021 McKinney Ave., Suite 1100, Dallas, TX 75201, USA (hereinafter StackPath). By using BootstrapCDN cookies are added to your computer and usage data is saved. By doing this some data in relation to the user’s activities can be stored and evaluated (in particular, which pages were visited and which elements were clicked) and information about the devices and browser (in particular, the IP address and the operating system). You can find more information about the processing of data by StackPath here:
    https://www.bootstrapcdn.com/privacy-policy/
  2. Purpose of the processing
    The use of Bootstrap allows us to improve our web pages and their ease of use.
  3. Legal basis for the processing of personal data
    The legal basis for the processing of data is Art. 6, para.1, pg. 1, let. F) of the GDPR. In this context, our legitimate interests consist in the purposes mentioned in point 2 for the processing of data.
  4. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.
  5. Right to withdraw consent and deletion
    By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by StackPath, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such, as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.
    You can find more information about the right to withdraw and cancellation regarding StackPath here:
    https://www.bootstrapcdn.com/privacy-policy/

Use of Google Webfonts

  1. Scope of application for the processing of personal data
    We use Google Webfonts, a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the European Union, Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Republic of Ireland (hereinafter Google). Webfonts are transferred in browser caches when opening a webpage in order to allow the use of different information in their optimised version. In cases in which the browser does not support Google Webfonts or access is prohibited, the text will be shown in a standard font. When opening the page, cookies are not stored on the user’s device: The data which is transferred when opening the page is sent to a specific domain for each resource https://fonts.googleapis.com or https://fonts.gstatic.com. By doing this some data in relation to the user’s activities can be stored and evaluated (in particular, which pages were visited and which elements were clicked) and information about the devices and browser (in particular, the IP address and the operating system).
    The data is not linked to or used in connection with other data collected when using other Gmail services such as Gmail.
    You can find more information about the processing of data by Google here:
    https://policies.google.com/privacy?gl=DE&hl=de
  2. Purpose of the processing
    The use of Google Webfonts is to allow for our texts to be displayed in a pleasing manner. If your browser does not support this function, it will be displayed using the computer’s standard font.
  3. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  4. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.
  5. Right to withdraw consent and deletion
    By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Google, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such, as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.
    Using the following link you can deactivate the use of your personal data from Google:
    https://adssettings.google.de
    You can find more information about the right to withdraw and cancellation regarding Google here:
    https://policies.google.com/privacy?gl=DE&hl=de

Usage of MailChimp

  1. Scope of application for the processing of personal data
    To send our newsletter we use the service MailChimp from the provider The Rocket Science Group, LLC, 512 Means Street, Suite 404, Atlanta, GA 30318, USA (hereinafter MailChimp). MailChimp is an email marketing service and allows us to have direct contact with potential customers by sending them newsletters via email. If you subscribe to the newsletter, the data entered by you, during the subscription process, will be transferred to MailChimp and stored there. By doing this some data in relation to the user’s activities can be stored and evaluated (in particular, which pages were visited and which elements were clicked) and information about the devices and browser (in particular, the IP address and the operating system).
    To this end, your data is also stored by MailChimp. With regard to the newsletter, your data is not transferred to third parties and MailChimp does not have any right to divulge your data to third parties. Following your subscription to the newsletter, MailChimp will send you a confirmation email. Furthermore, MailChimp offers different analysis methods when opening and viewing the newsletter, for example, how many users have already received the mail, if newsletters have been resent to users and if the users have cancelled their subscription after receiving the email. You can find more information about the processing of data by MailChimp here:
    https://MailChimp.com/legal/privacy/
  2. Purpose of the processing
    The personal data collected when subscribing to the newsletter is used exclusively to send our newsletter, possibly to invite you to events, and if you are already a customer, to send emails to customers. Furthermore, those subscribed to the newsletter may receive an email with the required information to run the newsletter service or about subscription, e.g. in the event of modifications to the newsletter service or in the event of changes to technical information.
  3. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  4. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy or as is necessary by law. Furthermore, you can contact MailChimp to request the deletion of your data.
  5. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal. You can withdraw your consent to the storage of data, as well as its use by MailChimp to send the newsletter at any time. You can exercise your right to withdraw consent at any time by sending an email to MailChimp or clicking on the corresponding link in all newsletters. You can find more information about the right to withdraw and cancellation regarding MailChimp here:
    https://MailChimp.com/legal/privacy/

Use of Wordfence Security

  1. Scope of application for the processing of personal data
    Our online pages use functions from Defiant Inc., 800 5th Ave., Suite 4100, Seattle, WA 98104, USA (hereinafter Defiant). Wordfence Security secures our online pages and by doing so protects visitors to our website from viruses and malware. When you visit a page with a plugin, a direct connection between your computer and the Defiant server is created. The plugin uses cookies to recognise if the visitor is a human or bot. By doing this some data in relation to the user’s activities can be stored and evaluated, in particular, information about the device and browser (IP address and the operating system);
    There exists the possibility to evaluate the behaviour from the notifications sent (e.g. how many times a page is opened). To protect from Brute Force or DDoS attacks or spam comments the IP addresses are saved on the Wordfence servers. The IP addresses evaluated as safe are added to the White List.
    You can find more information about the processing of data by Defiant here:
    https://www.wordfence.com/privacy-policy/
  2. Purpose of the processing
    On our online pages we use the plugin to protect from viruses and malware and to defend from criminal IT attacks.
  3. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  4. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy, or as is necessary by law, e.g. for tax and accounting purposes.
  5. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal. By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Wordfence Security, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser. You can find more information about the right to withdraw and cancellation regarding Wordfence Security here:
    https://www.wordfence.com/privacy-policy/

Use of Vimeo



  1. Scope of application for the processing of personal data
    We use the video plugin Vimeo from Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA. Vimeo is an online video streaming portal. By visiting our website, your browser creates a connection with the Vimeo servers in the United States. By doing so, information relating to your visit to our website and your IP address is transferred to Vimeo. This happens regardless of whether you have created an account with Vimeo or are logged in. If you are logged in, Vimeo can link the data collected to your account. You can find more information about the processing of data by Vimeo here: https://vimeo.com/privacy
  2. Purpose of the processing
    The availability of the Vimeo plugin is to display and integrate videos.
  3. Legal basis for the processing of personal data
    The user’s consent is the fundamental legal basis for the processing as per Art. 6, para. 1, pg. 1, let. A) of the GDPR.
  4. Retention period
    Your personal information will be stored for the period necessary to complete the above-mentioned purpose in this privacy policy or as is necessary by law.
  5. Right to withdraw consent and deletion
    You have the right to withdraw consent with regard to the processing of personal data at any time. The withdrawal of consent does not affect the legality of the processing based on consent prior to the withdrawal. By using the function “Do Not Track” on a supported browser, you can prevent the collection and processing of personal data by Vimeo, preventing third-party cookies being saved on your computer, deactivating script codes on your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser. You can find more information about the processing of data by Vimeo here: https://vimeo.com/privacy

This privacy policy has been created with the support of DataGuard.

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