Privacy Policy

1Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Lingonex operates an online language school for adults.

2What Is Personal Data?

Personal data is any information relating to an identified or identifiable natural person, such as a name, email address, IP address, or user behavior.

3How We Obtain Personal Data

We process personal data in the following ways:

a) Data you provide directly

When you:

• Contact us via the website or email
• Subscribe to our newsletter
• Purchase services
• Create a user account
• Download learning materials
• Participate in programs or online lessons

b) Data collected automatically

When you visit our website, certain technical data is automatically processed (see Section 6).

If required personal data is not provided, we may be unable to provide our services or respond to inquiries.

4Categories of Personal Data Processed

Depending on your interaction with us, we may process the following categories of personal data:

• Identification data (e.g. name, username)
• Contact details (e.g. email address, phone number)
• Billing and payment data
• Contract and service data
• Technical and usage data
• Course participation and profile data (e.g. language level)
• Marketing preferences (newsletter subscription)

5Purposes of Processing

We process personal data for the following purposes:

• Responding to inquiries
• Providing and managing language courses and services
• Contract execution and customer management
• User account administration
• Processing payments
• Sending newsletters (only with consent)
• Ensuring website security and functionality
• Compliance with legal obligations

6Automatically Collected Technical Data

When visiting our website, the following technical data may be processed:

• IP address
• Date and time of access
• Browser type and operating system
• Referrer URL
• Pages accessed

This data is processed to ensure website security, stability, and proper functionality.

7Legal Bases for Processing

Processing of personal data is based on one or more of the following legal bases:

• Art. 6(1)(a) GDPR – Consent (e.g. newsletter)
• Art. 6(1)(b) GDPR – Performance of a contract
• Art. 6(1)(c) GDPR – Legal obligations (tax and accounting law)
• Art. 6(1)(f) GDPR – Legitimate interests (IT security, service improvement)

8Newsletter (Mailchimp)

If you subscribe to our newsletter, your email address and optional name are processed via Mailchimp, a service provided by Intuit Inc., USA.

• Subscription is voluntary
• Double opt-in is used
• You may unsubscribe at any time via the link in each email

Mailchimp processes data based on EU Standard Contractual Clauses (SCCs) approved by the European Commission.

9Payments

Payments for services may be processed via:

• Stripe Payments Europe Ltd.
• Bank transfer

Payment providers process personal data independently as separate controllers. Their respective privacy policies apply.

10Online Classes & Communication

Online lessons and communication may take place via Google Meet / Google Workspace, provided by Google LLC, USA.

This may involve processing:

• Names
• Email addresses
• Communication content

Online sessions are not recorded unless explicitly announced in advance and conducted with consent.

11Cookies

Our website uses technically necessary cookies to ensure basic functionality and security.

We do not use tracking, analytics, or marketing cookies at this time.

If this changes, we will update this Privacy Policy and implement a consent mechanism where required.

12Hosting & Data Storage

Our website is hosted by Hostinger.

Personal data is stored only for as long as necessary to fulfill the stated purposes or as required by law.

13Data Retention Periods

Unless stated otherwise, personal data is stored as follows:

• Contact inquiries: up to 6 months
• Contract and billing data: 10 years (tax law)
• Newsletter data: until consent is withdrawn
• User account data: until account deletion
• Technical logs: up to 30 days

14Data Sharing

We do not sell personal data.

Personal data is shared only with trusted service providers where necessary (hosting, email, newsletter, payment providers) and based on GDPR-compliant agreements.

15Data Transfers to Third Countries

Some service providers (e.g. Mailchimp, Google) are located outside the EU/EEA.

In such cases, data transfers are safeguarded through EU Standard Contractual Clauses (SCCs) in accordance with Art. 46 GDPR.

16Mobile App – Einbürgerung Master (Android)

We offer the Android app “Einbürgerung Master” via Google Play. This section describes data processing specific to the app; the controller (Section 1) and your rights (Section 17) apply equally.

On-device data

Your study progress, bookmarks, answer history, app settings, and any downloaded translations are stored only on your device. We do not receive or access this data. Uninstalling the app deletes it.

In-app purchase (Google Play Billing)

The optional one-time “unlock translations” purchase is processed by Google Play Billing. Payment is handled entirely by Google; we do not receive or store your name, email, or payment/card details. To activate and protect the purchased content, the app sends the Google Play purchase token to our server (api.lingonex.de), which verifies it with Google’s Play Developer API. We store the purchase token, order ID, purchase state, and purchase timestamp to confirm your entitlement and deliver the paid content. The token is re-checked when you open the app, so a refunded or cancelled purchase loses access.

Paid content delivery

After a verified purchase, the English and Persian translations are downloaded from our server (hosted by Hostinger, see Section 12) and cached on your device.

Recipients / third countries

Purchase verification involves Google. Transfers outside the EU/EEA are safeguarded as described in Section 15. Google processes your purchase under Google’s own privacy policy.

No advertising or tracking

The app contains no advertising and no third-party analytics or tracking SDKs, and does not use an advertising identifier.

Retention

App purchase records are retained in line with Section 13 (contract and billing data).

17Your Rights Under the GDPR

You have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data
• Restrict processing
• Data portability
• Object to processing
• Withdraw consent at any time

You may exercise your rights by contacting: dpo@lingonex.de

18Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority.

19Adults Only

Our services are intended exclusively for adults (18+).

We do not knowingly collect personal data from minors.

20Changes to This Privacy Policy

We reserve the right to update this Privacy Policy when necessary.

The current version is always available on our website.