+B Privacy Policy This Privacy Policy describes how Babbel, a service of Babbel GmbH and its affiliates (collectively “Babbel,” “us,” or “we”) process personal data and other information through Babbel websites, applications, and other online platforms (our “Services”). This Privacy Policy explains what types of information we collect, how we use it, our sharing practices, and your choices. Babbel is the controller for purposes of this Privacy Policy. You can contact Babbel’s data protection officer by using the mechanisms identified in the “Contact Us” section at the end of this Privacy Policy. 1. Information We Collect Babbel collects information from you directly, automatically through its Services, and from third parties. Each collection mechanism is described in more detail in this Privacy Policy. 1.1 Information You Provide When you register your account, we require you to provide us with your email address, your name, and your password. In addition, when you subscribe to our Services or place an order with us, we collect payment details and record your agreement to our Terms and Conditions. You may choose to provide us with additional details in your personal profile once you establish an account with us. We also collect audio recordings from your device during your language lessons in order to check your pronunciations and measure your progress. If you apply for a job with Babbel, we require you to provide us with your name, email address, and resume. You can also submit your phone number, a cover letter, links to your LinkedIn profile or a personal website, and educational background information. You can also apply for a job with us through LinkedIn. 1.2 Automatically Collected Information We automatically collect the following types of information when you use our Services: pages and files accessed; time of access; amount of data transferred; browser version; app version; operating system; language settings; device ID; previously visited pages (if you access our website via a link); IP address; session ID; and cookies, as explained in more detail below. 1.2.1 Cookies When you visit our websites, we store certain information from your browser using cookies or similar technologies such as web beacons. A cookie is a small text file that is stored on your device through your browser. The cookies used by our Services include both first party and third party cookies. First party cookies allow us to collect analytics data, remember your language settings, and perform other useful functions that help simplify your user experience. Third party cookies are used by third parties for advertising, retargeting, analytics, and tracking. Additional details about the cookies we and third parties use is available here: 2. How We Use Your Information We use your information: to provide and improve our Services (including our speech recognition tools); in a pseudonymized form to monitor interactions with our marketing emails; in a pseudonymized, anonymized, or aggregated form to facilitate research in machine learning, artificial intelligence, and natural language processing; in a pseudonymized or anonymized form to conduct surveys; to process subscriptions to our Services; to protect our interests or the interests of third parties; to maintain and enhance the security of our Services; to prevent abuse of our Services; to comply with our legal obligations; to communicate with you; for analytics and advertising, including personalized ads; to perform or enforce our agreements; to conduct hiring; for any other purpose with your consent. We use cookies: for login authentication and login status; for load distribution and corresponding optimization of our Services; to save your language settings; to provide and improve our Services; to analyze user behavior on different devices for analytics and advertising. 2.1 More about Analytics and Advertising We use Google Analytics to help track how our services are used across platforms. Google Analytics’ privacy policy is available at http://www.google.com/analytics/terms/us.html. Information on how to opt out of Google Analytics tracking is provided in the “Your Choices and Rights” section of this Privacy Policy. We also use third party cookies or web pixels for online advertising personalization. Third- party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by third-party advertisers and others or the use of the information that such third parties collect. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. 3. Third Party Sharing We disclose information: to other Babbel companies in connection with your use of our Services or our business relationship with you; to contractors, service providers, and other third parties we use to support our Services, including advertising service providers and payment processing service providers; to fulfill any purpose for which you provide it; for any other purpose disclosed to you when you provide the information; or with your consent. We may also disclose your information: to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets; if we believe disclosure is necessary or appropriate to protect our rights, property, or interests, our investors, or others. 4. Third Country Transfers Sometimes we may need to transfer information to countries in which applicable laws may not offer the same level of data protection as the laws of your home country. Individuals in the EEA: When we transfer information from individuals in the EEA to countries that have not received an adequacy finding under Article 45 of the GDPR, we rely on the safeguards set forth in Article 46 of the GDPR or derogations for specific situations set forth in Article 49 of the GDPR in order to transfer your information across international borders. When relying on derogations under Article 49, we only collect and transfer your information to third countries: (i) with your consent; (ii) to perform a contract with you; or (iii) to establish, exercise, or defend legal claims. You may request a copy of any applicable Article 46 agreements by contacting us as detailed in the “How to Contact Us” section. 5. Third-Party Platforms and Social Media This Privacy Policy applies only to Babbel and not to any other platforms, websites, or applications operated by third parties. Our Services contain links to other platforms, websites, and applications which we believe may be of interest to you. Our Services also contain links that allow you to connect with us on social media. Babbel is not responsible for the privacy practices of any platforms, applications, or websites not controlled by Babbel. We encourage you to review the privacy policies of any website, application, or platform you use outside of our Services before providing any information to or through them. 5.1 Social Plugins Our website uses AddThis share buttons to allow you to connect with us on social media platforms via external links. AddThis’ privacy policy is available here. When you click on a plugin, you will be connected to the social media platform you selected. Babbel currently uses plugins for the following social media platforms: Twitter: Provided by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA. An overview of Twitter plugins are available here: https://developer.twitter.com/. Twitter’s privacy policy is available here: https://twitter.com/privacy. Facebook: Provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and Facebook Ireland Limited, Hanover Reach, 5–7 Hanover Quay, Dublin 2, Ireland. An overview of Facebook plugins are available here: https://developers.facebook.com/docs/plugins/. Facebook’s privacy policy is available here: http://www.facebook.com/policy. YouTube: Provided by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube’s privacy policy is available here: https://policies.google.com/privacy. Instagram: Provided by Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA. Instagram’s privacy policy is available here: http://instagram.com/about/legal/privacy/. LinkedIn: Provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. An overview of LinkedIn plugins are available here: https://developer.linkedin.com/plugins. LinkedIn’s privacy policy is available here: https://www.linkedin.com/legal/privacy-policy. 6. Bases for Processing The legal bases for our processing activities include: Your consent (Article 6(1)(a) General Data Protection Regulation); Babbel exercising its rights and performing its obligations in connection with entering into or performing under any contract it makes with you (Article 6(1)(b) General Data Protection Regulation); Compliance with our legal obligations (Article 6(1)(c) General Data Protection Regulation); Legitimate interests that are not overridden by your interests or your fundamental rights and freedoms (Article 6(1)(f) General Data Protection Regulation). 7. Data Retention We only store information for as long as is needed to fulfil our contractual or legal obligations or any other permissible purpose for which we have collected it, including to detect and prevent fraud or security incidents. When the applicable retention period has expired, we take measures to permanently delete the information, aggregate it, or anonymize it. 8. Security We use commercially reasonable administrative, physical, and technical measures to safeguard your information and help protect it from unauthorized access. However, we cannot guarantee complete protection of your information since transmission via the internet is not 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us as detailed in the “Contact Us” section. 9. Children Our Services are not directed to children, as defined under applicable law. If you believe that a child has provided their information to us through our Services, please contact us as detailed in the “Contact Us” section, so that we can take steps to delete it. 10. Your Choices and Rights You can control the use of cookies and can adjust your settings to provide consent or reject certain cookies by clicking on the “Change cookie settings” button at the top of this Privacy Policy. You can also change your cookie settings within your browser. However, please note that disabling some or all cookies may affect the functionality of our Services. Our website does not respond to browser “Do Not Track” signals. While we may use a variety of companies to serve advertisements on the website, you may wish to visit http://www.networkadvertising.org/choices, which provides information about Network Advertising Initiative (“NAI”) members, and your choices regarding how your information used by these companies, including the opt-out procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit the opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt out may not, or may no longer, be effective. You may also be able to opt out of receiving third-party behavioral ads by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices. Similar limitations may apply to the DAA opt-out process. We are not responsible for effectiveness of or compliance with any third- parties’ opt-out options. You can opt out of Google Analytics tracking here. If you register for our Services we may send you promotional emails. You can opt out of these promotional emails by sending an email to privacy@babbel.com, changing your account settings, or clicking on the “unsubscribe” link within any promotional email. To the extent required by law, we provide you with (i) reasonable access to your personal information collected through our Services, and (ii) the ability to review, correct, export, or delete your information, restrict its processing, or object to its processing. You may exercise the foregoing rights by contacting us using any of the mechanisms detailed in the “Contact Us” section. Individuals in the EEA: In addition to the foregoing rights, you have the right to lodge a complaint with a supervisory authority if you believe we have processed your information in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern by emailing us at privacy@babbel.com. California Residents: This Privacy Policy discloses the categories of personal information we have collected about California residents over the past twelve months, the sources of collection, how we use that information, and the categories of third parties with whom we share that information for a business or commercial purpose. The categories of personal information we have sold or disclosed to third parties in the preceding twelve months for business or commercial purposes are: (i) identifiers, and (ii) internet or other electronic activity information. The categories of third parties to whom we disclosed or sold personal information are: advertising networks, data analytics providers, and social networks. Babbel has no actual knowledge of selling the personal information of minors under 16 years of age. California residents have the right to request that we disclose information about the personal information we collected, used, disclosed, and sold about them during the past twelve months and the right to request specific pieces of their personal information. California residents also have the right to request deletion of the personal information we have collected about them. California residents or their authorized agent can submit a request by calling +1 (888) 901-2932 or by emailing privacy@babbel.com. Requestors will need to provide us with certain personal information for us to match with our records in order to verify their identity and residency. The personal information that we use to verify a requestor’s identity and residency will not be used for any other purpose. California residents have the right not to be discriminated against for exercising their CCPA privacy rights and we do not discriminate against California residents who exercise their CCPA privacy rights. California and Nevada Residents: We may share your personal information in ways that could be considered a “sale” of personal information under certain state laws. Residents of California and Nevada have the right to opt out of the sale of their personal information. To do so please click here. 11. Changes to This Privacy Policy We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. We will update this Privacy Policy to reflect any changes to our practices. If we make any material changes, we will notify you in accordance with applicable law prior to the changes becoming effective. 12. Contact Us If you have any questions or comments regarding this Privacy Policy, our privacy practices, or if you wish to exercise your individual rights, please contact us using one of the following methods: Email: privacy@babbel.com Phone: +1 (888) 901-2932 (US) +44 20 3322 1969 (UK) +49 30 568 373876 (DE) Mail: Babbel GmbH, Andreasstraße 72, 10243 Berlin, Germany Last updated: April 29, 2021 The Babbel Method Babbel app Babbel Magazine Babbel for Business Careers Press Inside Babbel Tech Blog Help / FAQ Babbel as a Gift © 2021 Babbel GmbH Imprint Terms & Conditions Privacy Statement