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
• Take our placement test

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
• Running our placement test and sending you its results
• 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 (Brevo)

If you subscribe to our newsletter, we process your email address. You can subscribe with the newsletter form on our website, by ticking the newsletter box before a placement test, or by registering for an event on our website, as the registration form states.

• Double opt-in is used: your address is only added once it is confirmed through a link we emailed to it – our confirmation email, or the link for your event registration or placement test
• As a record of your consent, we store when and where you signed up and confirmed, with the IP address and browser used each time
• You can decline single kinds of email, such as event announcements or the monthly newsletter, or unsubscribe from everything at any time via the link in each email

The subscriber list is kept on our own website (see Section 12). Newsletters are sent through Brevo, a service provided by Sendinblue SAS, France, which processes the data on our behalf under a data processing agreement (Art. 28 GDPR). Brevo receives your email address, the kinds of email you have declined, and a personal link to your email preferences.

Brevo records whether each email was delivered and opened and which of its links were clicked, and tells us about unsubscribes, bounces and spam complaints. Brevo also delivers the other emails our website sends, such as registration confirmations, and records the same for them.

Sign-ups that are never confirmed are deleted after 30 days. If you unsubscribe, we keep your email address and the date on a blocklist so that you are not sent the newsletter again; on request, we delete it.

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 you unsubscribe; after that, only your address and the date, on a blocklist (see Section 8)
• Placement tests: 12 months for tests taken on the public test page; tests we send you, until you ask us to delete them (see Section 18)
• 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. 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 19) 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).

17Mobile App – Konjunex (iOS & Android)

We offer the app “Konjunex” for practising German verbs via the Apple App Store and Google Play. This section describes data processing specific to the app; the controller (Section 1) and your rights (Section 19) apply equally.

No personal data collected

The app has no user account and no sign-in. It does not send any information about you or about your use of the app to us or to anyone else. It contains no advertising and no analytics or tracking tools, and does not use an advertising identifier.

On-device data

Your practice progress, saved verbs, statistics and app settings (such as app language, colour scheme, pronunciation voice and speed, and reminder time) are stored only on your device. We do not receive or access this data. Uninstalling the app deletes it.

Pronunciation and reminders

When you have a verb read aloud, it is spoken by your device’s own speech engine; the app passes it only the word to be spoken. The optional daily reminder is a notification scheduled on your device. It is only set up if you switch it on and allow notifications, and you can switch it off in the app at any time.

Fonts on Android

On Android, the app’s fonts are supplied by Google Play services, which downloads them from Google if they are not already on your device. That download is made by Google Play services, not by the app, and Google processes it under Google’s own privacy policy. On iPhone and iPad, the fonts are built into the app.

Feedback by email

The app’s feedback options open your email app with a message addressed to us. If you send it, we receive your email address and your message and use them only to reply and to improve the app.

App stores

Downloads and updates are handled by Apple and Google under their own privacy policies. If you have allowed it in your device settings, Apple or Google may share crash reports and usage statistics about the app with us, in a form that does not identify you. The app is free and has no in-app purchases.

Retention

Feedback emails are retained in line with Section 13 (contact inquiries).

18Placement Test

You can take our German placement test on our website: on the public test page, or through a personal link we email you.

What we process

• Your name and email address. On the public test page both are optional; for a test we send you, we enter them ourselves
• Your answers, your score for each level, and when you started and finished
• Whether you ticked the newsletter box
• The IP address and browser of the device that started the test

Purpose

We use this data to show you your results, to email them to you if we have your email address, and to advise you on a suitable course. Results from the public test page are emailed with your answer sheet as a PDF; the PDF is created when the email is sent and is not stored. Result emails are sent through Brevo (see Section 8).

Protection against misuse

Before the test starts, the public test page has your browser solve a small calculation. This happens on your device and involves no third-party service. We also count how many tests are started from one IP address per hour and how many result emails go to one email address per day. These counters store only a scrambled (hashed) form of the IP or email address and are deleted automatically within two days.

If you tick the newsletter box, you are only added to our newsletter once your address is confirmed (see Section 8).

Retention

Tests are stored on our website (see Section 12). A test taken on the public test page is deleted automatically, with its answers and results, 12 months after it was started. A test we send you is kept until you ask us to delete it. You can ask us to delete either at any time (see Section 19).

19Your 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

20Right to Lodge a Complaint

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

21Adults Only

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

We do not knowingly collect personal data from minors.

22Changes to This Privacy Policy

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

The current version is always available on our website.