+B Privacy Policy Manage settings 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. This privacy policy sets out the following: What data we collect and what we do with it What technology we use Which advertising services we use What data protection rights you have and how you can exercise your rights 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 laws prior to the changes becoming effective. Who can I contact? 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 Mail: Babbel GmbH, Andreasstraße 72, 10243 Berlin, Germany Our Data Protection Officer or another data protection relevant contact can be reached at the email provided above. What are my rights? You may contact us at any time if you have any questions concerning your data privacy rights or if you wish to exercise any of the following rights afforded to you under the General Data Protection Regulation (2016/679; the “GDPR”). You have the: Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you can contact us if you wish to cancel a previously given consent to receive our newsletter) Right to access your data in accordance with Art. 15 GDPR (e.g. e.g. the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing. Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your e-mail address has changed and you would us to update the details we hold) Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you can contact us if you want us to delete certain data that we have stored about you) Right to limit data collection in accordance with Art. 18 GDPR (e.g. you can contact us if you only want us to send you absolutely necessary e-mails) Right to data portability in accordance with Art. 20 GDPR (e.g. you can contact us to receive your data in a commonly used and machine-readable format if you want to upload it to another website) Right to object how your data is handled in accordance with Art. 21 GDPR (e.g. you can contact us if you do not agree us using your data for analytics as described within this privacy policy) Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 lit f GDPR (e.g. you can contact the data protection supervisory authority directly) If you wish to file a complaint with a national supervisory authority regarding our processing of your personal data, you may do so by contacting your local data protection authority (“local” meaning where you live or work, or where an alleged data breach has occurred). The relevant authority in Berlin, Germany is: Berlin Commissioner for Data Protection and Freedom of Information Friedrichstraße 219, 10969 Berlin Storage periods and deletion of data We only store your 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. Visiting our website If you merely wish to browse our website, we do not collect any personal data, with the exception of the data that your browser sends to us, e.g.: Pages and files accessed Date and time of access Transmitted data volume Browser version Status messages (i.e. whether the data transfer was successful) Information about your device (e.g. browser version, app version, operating system, language settings, device IDs) Previously visited pages (if you access our website via a link) Online identifiers (e.g. IP address, session IDs, cookies, device identifiers) Geographic data (e.g. city, postal code) (transmitted via IP address) As a safeguard to protect your privacy, we delete or anonymise the IP address according to set deadlines. Therefore, all other data possibly attached to it can no longer be traced back to you. The information we retain is in anonymous form and is only used for statistical purposes to optimise our website. The purpose of temporarily storing this data is to establish a necessary connection between your device and our server as well as ensuring that our website loads effectively. Such data is therefore required to display the website on your screen, to avoid display problems and other technical error messages. The legal basis is our legitimate interest as laid out under Art. 6 para. 1 s. 1 lit f GDPR. Providing the Babbel services We process your data for the fulfilment of our contract with you and for the purpose of providing and implementing further services requested by you, as described in this Privacy Policy This also includes The provision, personalisation and customisation of our Babbel services (including their respective websites, apps and cross-device functions), Ensuring the general security, operability and stability of our services, including the prevention of cyber- attacks, Communication in regards to technical/security issues as well as contractual amendments (e.g. fraud warnings, account suspension or contract amendments) and, The implementation of campaigns and competitions. Insofar as the purpose is the implementation of a contract agreed with you or the provision of a service requested by you, the legal basis is Art. 6 para. 1 s. 1 lit. b GDPR. Otherwise, the legal basis is Art. 6 para. 1 s. 1 lit f GDPR, whereby our legitimate interest lies in the above-mentioned purposes. Your Babbel account In order to use our Babbel language courses, you need to register on our website/app. When you register on our website, we collect and store your basic data such as (user) name, e-mail address and 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. As a protective measure, the data you enter is transmitted via an encrypted connection - just like when you visit our website. After successful confirmation, your data will be stored until you decide to delete your information or your entire user account. The purpose of the requested data is to create a user account for the use of extended functions on the website. Registration is voluntary and can be revoked or the user data deleted at any time. The legal basis is your consent as laid out in Art. 6 para. 1 s. 1 lit a GDPR. Contact You have the possibility to contact us in different ways on our website or in our app. You can get in touch with us about general requests by writing to our customer service at support@babbel.com or contacting us through the methods described in our Help Centre found here. In this context we process data exclusively for the purpose of communicating with you. The legal basis for data processing is the fulfilment of the contract in accordance with Art. 6 para. 1 s. 1 lit b GDPR. Personal vocabulary Whenever you complete a course in our app or on our website, all practised words and sentences as well as any exercise results of yours are stored in your personal vocabulary section. This data cannot be viewed by other users. The legal basis for data processing is the fulfilment of the contract in accordance with Art. 6 para. 1 s. 1 lit b GDPR. Babbel Live Our Babbel Live service offers Babbel users the opportunity to take part in digital language lessons in small groups (1-6 users). For this service, users meet together with a teacher and take part in a lesson. As part of the lesson, learning objectives are defined and language exercises are carried out, and the teacher supports the users as they learn the language. The personal data entered during registration by the user is processed as part of this service. The user’s name will therefore be visible to the teacher and to other participants. Babble Live lessons are hosted on Zoom, a US-based online meeting platform (https://zoom.us). We have signed a data processing agreement with Zoom which includes the EU standard contractual clauses to ensure the safe transfer of your data. In doing so, we have configured our settings provided by Zoom in such a way that only necessary personal data is processed in order to provide the virtual lessons. Features such as attention tracking and other analytical options are always deactivated. For further information on Zoom’s privacy policies please see: https://zoom.us/privacy. Research, artificial intelligence and machine learning We process the data collected about our customers for scientific research in fields relevant to Babbel. These are in particular the fields of machine learning, artificial intelligence, natural language processing and deep learning as well as tracking the efficiency of online learning processes. Babbel’s research focuses on solving real, everyday problems of learning new languages and is intended to improve and develop the existing service offering. It goes without saying that we comply with recognised scientific data protection standards. This also means that we only process your data in anonymised or pseudonymised form, for example by replacing all identifiable data such as your name with other information. Research at Babbel includes the following purposes: The development of machine-learning methods that enable estimates, forecasts and analyses of the needs and interests of our users; The development of technical solutions to real customer problems that our customer service department encounters in everyday business; The improvement of speech recognition and the optimisation and individualisation of our learning units; The development of technical solutions to enhance and improve the user experience and prevent fraud. The legal basis for the processing of your data for the research purposes described above is Art. 6 para. 1 s. 1 lit f GDPR, whereby our legitimate interests lie in the above-mentioned purposes. Registration via Social Networks In addition to our standard registration process, we offer you the ability to register with us using your existing account in Facebook (collectively referred to as “Social Networks”) using the following plugins “Facebook Sign In”. If you want to use one of these functions, you will be redirected to the page of the respective provider and navigated through the registration process. To ensure the protection of your privacy, any data you submit is transmitted via a secure connection through the corresponding platform. We do not use your login details to access any personal information such as your friend lists or contacts, nor do we store any of this information for our own purposes. There is no permanent link between your Babbel account and your account on Facebook. For further details on what kind of information Facebook collects on you please see their respective privacy statements: Facebook (https://facebook.com/policy.php). The purpose of the data requested is the registration via an existing user account to use extended functionality on the Babbel website. Registration via Social Networks is voluntary and can be withdrawn at any time by logging out of the relevant social media account. The legal basis is your consent as laid out under Art. 6 para. 1 s. 1 lit a GDPR. Newsletter If you are interested in receiving updates about our company or our products, you can subscribe to our newsletter. You will then receive an email in which you must click on a link to confirm receipt of the newsletter. We store the email address you provided until you unsubscribe from our newsletter. For this purpose, you will find a corresponding link to unsubscribe in every email of our newsletter. The delivery of the newsletter is carried out by a professional service provider. As a safeguard to protect your privacy, we ask for a so-called “Double-Opt-In” to ensure that the registered email address actually belongs to you. Furthermore, we have entered into a data processing agreement with the assigned service provider. You also have the possibility to unsubscribe from the newsletter at any time and thus delete your email address from the service provider’s database. The purpose of the data requested is to send the newsletter to your personal email address in order to fulfil your request for updates about our company or our products. The legal basis is your consent in accordance with the European data protection requirements under Art. 6 para. 1 s. 1 lit a GDPR. If you register for our Babbel services, we will also send you marketing emails (advertising to existing customers). You can object to receiving these at any time by sending an e-mail to privacy@babbel.com or opting out in the account settings of your Babbel customer account (at http://de.babbel.com/users/settings/edit). There is also a corresponding unsubscribe link in every marketing email. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR, based on our justified interest in advertising our products and services. We use embedded graphics known as pixels in our newsletter emails to track whether or not an email has been opened and which links in the email have been clicked on in order to optimize our offers. We collect this data in pseudonymous form for general statistical evaluations as well as for the optimisation and further development of our content and customer communication. The data is not linked to your personal data. The legal basis for this is our aforementioned legitimate interest in accordance with Art. 6 para. 1 s. 1 lit. f GDPR. We use our marketing emails to share content that is most relevant to you and to better understand what our users are actually interested in. If you do not want us to analyse your usage behaviour, you can unsubscribe from our marketing emails or deactivate graphics in your email program by default. The data on your interaction with our marketing emails are stored pseudonymously to improve deliverability and to remedy technical defects; they are then eventually completely anonymised. Apps In addition to our website, we also offer applications (“apps”) for various smartphone operating systems. We also collect data regarding the use of these applications using software from third party providers, in order to detect and correct errors and to improve the applications. In doing so, however, no data is collected from which a third-party provider could directly link the data to a specific person. This allows us to collect aggregated information regarding how the apps are used and which features are particularly popular, so that we can draw conclusions in terms of future improvements for product development. You can prevent this analysis by choosing to opt out here: https://www.tune.com/optoutmobile/. In addition – provided that you have given permission via your device settings – we will be informed in the event of program crashes. These crash reports are performed by third-party service providers. In doing so, however, no data is processed from which a third-party provider could link the data to a specific person. Zendesk We use the service of Zendesk Inc., 989 Market Street #300, San Francisco, CA 94102, USA. The legal basis for the use of this service is our legitimate interest in accordance with Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest in using this service is to be able to answer user enquiries quickly and efficiently. Zendesk will only use your data to forward your enquiries to us. Your data will not be passed on to third parties. The service can also be used under a pseudonym. In the course of processing service requests, it may be necessary to collect additional data (e.g. first name, last name, address, etc.) The use of Zendesk is optional. If you do not agree to Zendesk collecting your data, we offer you alternative ways of contacting us to submit service requests by phone or mail. For more information, please refer to the Zendesk Privacy Policy: https://www.zendesk.de/company/customers-partners/privacy-policy/. Refer a Friend On our website we offer you the possibility to invite your friends to join Babbel. For this, we work together with the company Talkable (https://www.talkable.com). In order to invite your friends, you will have to enter their: First name and e-mail address A personal link will then be created which can be sent to the invited friend. We have concluded a data processing agreement with Talkable that meets the requirements of Art. 28 GDPR. Cookies Our website uses cookies in some instances. Cookies are small text files that are usually stored in a folder in your browser. Cookies contain information on your current and previous website visits: Name of the website Expiration date of the cookie Any cookie value Provided that cookies do not contain a specific expiration date, they are only saved temporarily and automatically deleted as soon as you close your browser or turn off the device. Cookies with expiration data remain saved even after you have closed your browser or turned off your device. These cookies are only removed once they have reached their expiry date or if you manually delete them. We use the following three types of cookies on our website: required cookies (e.g cookies that required to display the website correctly for you and to store certain settings temporarily) functional and performance-related cookies (cookies that help us improve our website, e.g. to evaluate technical data from your visit and therefore avoid error messages) advertising and analytics cookies (cookies that provide analytics and personalized ads, e.g. you see ads for shoes if you had previously searched for shoes) You can use your browser settings to configure, block, and delete cookies. If you delete all cookies from our website, you may find that some website features are not displayed properly. You can find helpful information and instructions for common browsers on the website of the German Federal Office for Information Security: https://www.bsi-fuer-buerger.de/BSIFB/DE/Empfehlungen/EinrichtungSoftware/EinrichtungBrowser/Sicherheitsmassnahmen/Cookies/cookies_node.html Cookies are only activated after you have granted express permission, with the exception of those cookies that are required for the technology to work. You can withdraw this permission at any time. You can find information on how to withdraw permission, as well as additional information, in the cookie configuration options. YouTube We use YouTube to integrate videos. YouTube is operated by YouTube LLC with headquarters at 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc. with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When playing the embedded videos, a connection to the YouTube servers is established and your IP address is transmitted for technical reasons. If you are also logged into your YouTube user account, YouTube will assign information on the videos you have viewed to your personal user account. You can prevent this assignment by logging out of your YouTube account and other Google Platform accounts before using our website. The security standards of the Google Platform and the associated Google Privacy Policy (http://www.google.com/intl/de-DE/privacy) apply as protective measures. The purpose of the data transfer is the integration of YouTube videos on our website, in order for our users to be able to access the displayed videos comfortably without leaving our website. The legal basis is your consent in accordance with Art. 6 Para. 1 a GDPR. Usabilla Our website uses “Usabilla for Websites”, a service of Usabilla B.V. (Rokin 16, 1012 KR Amsterdam, The Netherlands, hereinafter referred to as “Usabilla”). Usabilla collects feedback from website visitors to enable us to analyse and improve the use of our website and to detect any errors that occur. If a user uses the feedback button that appears on the website or uses another type of feedback option, cookies are set on his or her computer and the user’s browser establishes a direct connection to the Usabilla server. In the process, Usabilla collects information such as device, operating system, browser, screen resolution and stores it in a pseudonymised user profile. Additional data such as an e-mail address and feedback text are only collected if a user actively enters them. The cookie is only set if the user clicks on the corresponding button. You can object to the collection of cookies by deleting the cookies from your browser and blocking them. However, this block only applies until you click on a feedback button again. As protective measures, we have concluded a data protection agreement with Usabilla in accordance with Art. 28 GDPR. Information on data protection at Usabilla can be found at https://usabilla.com/gdpr/. The purpose of using Usabilla is to collect and receive feedback from our users. The legal basis is your consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR. Google Fonts For the visual improvement of the fonts we use Google Fonts (https://fonts.google.com) from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”), a font collection from Google. These fonts are transferred to the storage folder of your browser and activated when you visit this website or other websites. If this is not supported, the text on the web page will only be displayed in a default font. To make this possible, a request is sent to domains such as fonts.googleapis.com or fonts.gstatic.com, which for technical reasons contains your IP address. However, your data will not be merged with other data or traced back to your person. As a safeguard to protect your privacy, we have assured ourselves that the retrieval of Google’s font collection does not merge your data with other Google services, e.g. if you have a Google user account. Information on data protection at Google Fonts confirms this (https://developers.google.com/fonts/faq). In addition, the security standards of the Google platform and the associated privacy policy of Google (http://www.google.com/privacy) apply. The purpose of transmitting the data is the correct display of the fonts in the layout specified by us. The IP address is required to connect to Google’s servers to download the font library if it is not already stored on the device. The legal basis is our legitimate interest as laid out under Art. 6 para. 1 s. 1 lit. f GDPR. Google Analytics This website uses Google Analytics, a web analysis service provided by Google Inc. (Google). Google Analytics uses cookies, which are text files saved on your computer that make it possible to analyse how you use the website. Since we have activated anonymization of the data, your IP address will be shortened by Google within the European Union Member States or other states party to the agreement regarding the European Economic Area and only then transferred to the USA. The full IP address will only be transferred to a Google server in the USA and shortened there in exceptional cases. Google uses this information on behalf of the operator of this website to evaluate your use of the website, in order to compile reports regarding website activities and in order to perform additional services for the website provider connected to website use and internet use. The IP address transmitted from your browser for use in Google Analytics will not be connected to other data from Google. You can prevent the cookies from being saved by selecting the appropriate setting in your browser software; please note that in this case you may not be able to fully use all features available on the website. You can find additional information on Google Analytics’ use of data and data protection at https://marketingplatform.google.com/about/analytics/terms/de/ or at https://marketingplatform.google.com/about/. Babbel only uses Google Analytics in combination with the gat._anonymizeIp(); expansion, so that IP addresses are only recorded in a shortened, i.e. anonymized form. As a safeguard to protect your privacy, we use the anonymization feature offered by Google as mentioned above, where analytics are not based on you as a person, but only in aggregated form for statistical analyses. In addition, the security standards of the Google platform and its data privacy policy apply (http://www.google.com/privacy). We have also concluded a data protection agreement with Google, which ensures the protection of your data through technical and organizational security measures. The purpose of the use of Google Analytics is to anonymously analyze usage behavior of our websites. The information helps us to improve our services. The legal basis is our legitimate interest as laid out under Art. 6 para. 1 s. 1 lit. f GDPR. Google Conversion Tracking Our website uses Google Conversion Tracking from Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (subsequently: Google), in order to record statistics on the use of our website and for the purpose of evaluating optimization of our services for you. Google AdWords places a cookie on your computer in the event that you have reached our website via a Google ad. If the user visits specific pages on the AdWords customer’s website, and if the cookie has not yet expired, Google and the customer can see that the user clicked on the ad and was directed to this page. Every AdWords customer receives a different cookie. Cookies can therefore not be tracked via AdWords customer’s websites. The information collected with help from the conversion cookies serves to create conversion statistics for AdWords customers who have decided to make use of conversion tracking. We receive information on the total number of users who have clicked on the advertisement and were forwarded to a page containing a conversion tracking tag. However, we do not receive any information that can be used to personally identify users. The legal basis for use of this service is your consent as laid out in Art. 6 para 1 s. 1 lit. a GDPR, and consent is granted via our cookie banner. Consent can be withdrawn at any time via the cookie management portal. Google Tag Manager We use Google Tag Manager, a service of Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (“Google”). Google Tag Manager allows you to manage website tags through a single interface. According to Google, Google Tag Manager is a cookie-free domain that does not collect personal information. Google Tag Manager triggers other tags that may collect data. Google Tag Manager does not access this data. If disabled at the domain or cookie level, it will remain disabled for all tracking tags implemented with Google Tag Manager. For more information about Google’s privacy policy, please see the Google Privacy Policy: https://policies.google.com/privacy?hl=en-US. The legal basis for use is your consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR, which can be granted in our cookie banner. This consent can be revoked at any time via our cookie management tool. Criteo We collect and store pseudonymous information about the browsing behaviour of our website visitors for marketing purposes using technology from Criteo SA, 32 Rue Blanche, 75009 Paris, France. This data is stored in cookies on our visitors‘ computers. Criteo SA uses an algorithm to analyse the pseudonymously recorded surfing behaviour and can then display targeted product recommendations as personalised advertising banners on other websites (so-called publishers). Under no circumstances can this data be used to identify you personally as a visitor to our website. The data collected is only used to improve our services. This information is not otherwise used or passed on to third parties. For more information on the technology used, please refer to Criteo SA’s privacy policy: https://www.criteo.com/privacy/. As a protective measure, the evaluation of this data is not based on your person but is only used for statistics in aggregated form. In addition, the security standards of Criteo apply. We have also concluded an agreement with Criteo in accordance with Art. 26 GDPR according to which both we and Criteo are responsible for the processing of your data. You can therefore contact us as well as Criteo on questions concerning data processing. Contact details of Criteo can be found at https://www.criteo.com/legal/. The purpose of using Criteo is to analyze your usage patterns on our websites in an anonymous manner and to provide interest-based advertising. The legal basis for this is your consent in accordance with Art. 6 para. 1 S. 1 lit. a GDPR, which you can grant through our cookie banner. This consent can be revoked at any time via our cookie management tool. HubSpot This website uses HubSpot for our online marketing activities. HubSpot is a software company from the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Telephone: +353 1 5187500. Our log-in services allow people who use our website to find out more about our company, download content, and provide their contact information, as well as additional demographic information. This information, as well as the contents of our website, is saved on servers belonging to our software partner HubSpot. It can be used by us to contact those who visit our website and determine which of our company’s services they are interested in. All information we collect is subject to this Privacy Policy. We only use the information collected to optimise our marketing measures. On some of the subpages of our website, we also use the HubSpot live chat service “Messages” (round chat icon on the bottom right of the screen) to send and receive notifications in order to improve the user experience. If you agree to and use this function, the following data will be sent to the HubSpot servers: contents of all chat messages, both sent and received context information (e.g. the page on which the chat was opened) optional: the user’s email address (if the user provided their address during the chat) HubSpot’s services are used on the legal basis of Art. 6 para 1 S. 1 lit. f GDPR – legitimate interest. Our legitimate interest in regard to the use of this service is optimization of our marketing measures and improving the quality of service on our website. More information on the HubSpot privacy policy» More information from HubSpot regarding the EU Data Protection Regulations» You can find more information on the cookies used by HubSpot here & here. Data shared with Facebook (only applies to registered users of Facebook) We participate in a statistical program run by Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA, which identifies Facebook users who have a similar usage profile to our existing customers (“Facebook Custom Audiences - Statistical Twins”). As part of this program, email addresses of customers are transferred to Facebook in an anonymised form (as a so-called “hash”). It is no longer possible to derive the email address from the transmitted data. Facebook uses the same method to create a hash from the email addresses of their users, compares this anonymised data and determines whether one of our users is registered with Facebook with the same email address. Facebook guarantees that they will not store this match or use it outside of this program. On this basis, third parties are then identified who use Facebook in a similar way to our customers and we are given the opportunity to address these people in a targeted manner. You will not receive any additional advertising or messages from us or from Facebook. If you are not registered with Facebook under the same e-mail address you used to register with us, then Facebook will not receive any information about you. We will not under any circumstances be informed as to whether you are registered with Facebook and will also not receive any additional data on you. For additional information on the purpose and scope of data collection and further processing and use of the data by Facebook, as well as your options for settings to protect your privacy, please see the Facebook privacy policy, which can be found at https://www.facebook.com/about/privacy/. Hotjar We also use the web analytics service Hotjar from Hotjar Ltd. Hotjar Ltd. is a European company with their headquarters in Malta (Hotjar Ltd, Level 2, St. Julian’s Business Centre, 3, Elia Zammit Street, St. Julian‘s STJ 1000, Malta, Europe). This tool is used to record movement on websites using Hotjar (heat maps). This provides information, for example, on how far down the page users scroll, which buttons the users click and how often. It is also possible to get feedback directly from website users using this tool. This allows us to access valuable information in order to design our websites so that they are faster and more customer friendly. When using this tool, we pay particular attention to protecting your personal data. We are only able to see which buttons were clicked, how the mouse moved, how far down the page you scroll, the device’s screen size, the type of device and browser information, geographical location (only the country), and the preferred language for displaying our website. Areas of the website that show personal data from yourself or a third party are automatically hidden by Hotjar and we are therefore restricted from accessing this information at any time. The legal basis for use of this service is your consent as laid out in Art. 6 para. 1 S. 1 lit. a GDPR, and consent is granted via our cookie banner. Consent can be withdrawn at any time via our cookie management tool. LinkedIn Insight Tag Our website uses the LinkedIn Insight Tag conversion tool from LinkedIn Ireland Unlimited Company. This tool creates a cookie in your web browser which allows the collection of information such as: IP address, device and browser characteristics and page events (e.g. page views). This data is encrypted, anonymised within seven days and then deleted within 90 days. LinkedIn does not share any personal data with us, but rather offers anonymized reports regarding the website’s target audience and advertising performance. LinkedIn also offers the option of retargeting via the Insight Tag. Using this data, Babbel can show targeted advertising outside of their website, without identifying you as the visitor to the website. You can find more information on data protection at LinkedIn in the LinkedIn privacy policy. LinkedIn members can adjust settings regarding the use of their personal data for advertising purposes via their account settings. The legal basis for use of this service is your consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR, which can be granted in our cookie banner. The consent can be revoked at any time via our cookie management tool. Adjust In order to constantly improve and optimise our product, we use mobile tracking technology. For this we use the services of Adjust GmbH, Saarbrücker Str. 38a, 10405 Berlin, Germany (). We use Adjust to collect statistical data to help us improve our product. When you use our app, information from your mobile device is transmitted to us. The following data is collected: IP address, which is immediately anonymised, MAC address, anonymised Device ID (IDentifier For Advertisers - IDFA or Google Advertiser ID - GAID), browser type, language, Internet Service Provider, network status, time zone, URL of the access and exit page, time and date of access, clickstream data and other statistical information about the use of our services. There is no direct personal reference. The data collected in this way is used to create anonymous user profiles. We do not use this data to personally identify visitors to our websites without their consent. **As a protective measure**, we do not use individual data. We only use data in aggregated form for statistical evaluation. **The purpose** of processing is to provide interest-related advertising content. **The legal basis** is your consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR. Online advertising We use service providers to optimise our online advertising outside of Babbel. By optimisation, we mean that our advertising (e.g. ads on Facebook and Twitter, in Google search results or on other websites that make your advertising space available via an advertising network) is aimed at addressing only those people who might actually be interested in our offers (“personalisation”). For example, we can avoid showing Babbel ads to individuals who have already signed up to our product. Personalised advertising also enables us to adapt our advertisements to the interests of other users who have never interacted with Babbel before. For this purpose, Babbel services, as well as the services (especially websites, apps) of other companies that participate in the same advertising networks as we do (e.g. Google advertising network), contain special cookies or comparable technologies (e.g. pixel procedures) that are set by the respective providers and provide them with certain access data when using these services. Using this data, the respective providers can create a user profile to determine which websites and apps you use and derive your interests from this (your IP address is only transmitted for technical reasons but is not used for personalisation). The operator of an advertising network can then use this data to display personalised advertisements to you on all advertising spaces connected to their advertising network. For example, if you search for Italian language courses on Google, Google may use this information to show you our advertising for a free Italian test on another page that is also connected to the Google advertising network. Since we participate in the Facebook advertising network, we may, for example, ask Facebook to display our Facebook Ads only to Facebook members who have visited our site in the last month. We process the personal data for the above-mentioned purposes on the basis of your expressly given consent. Social Plugins Our website uses a plug-in from the provider ShareThis, Inc., 4009 Miranda Avenue, Suite 200, Palo Alto, CA 94304, USA (“ShareThis”) with which you can share content on social media platforms. If you visit a page on our website in which such a plug-in is integrated, your browser establishes a direct connection to the servers of ShareThis as well as to the social networks listed below. This informs ShareThis that your browser has called up the corresponding page of our website and stores a cookie on your device to identify your browser. This information is transmitted by your browser to a ShareThis server in the USA and stored there. ShareThis uses the data to create anonymous user profiles, which serve as a basis for interest-related advertising to visitors of Internet pages with ShareThis plug-ins. You can object to data collection by ShareThis for the future by setting a so-called opt-out cookie. For this purpose, you can click on the button “Click here to Opt-Out” in the ShareThis privacy policy: https://sharethis.com/privacy/. Data connections to social networks can be established via ShareThis. The social network receives the information that you have called up the corresponding page of our Internet presence or the contents of a page. If you are logged in to the social network, it can assign the visit to your account. If you do not want social networks to collect data about you via our website, you must log out of these networks before you visit our website. However, even if you are not logged in to the network, websites with social media plug-ins can send data to social networks via a cookie. To prevent this, you can select the “Block third-party cookies” function in your browser settings. Our app allows you to share content using the standard features of your mobile device through other services, such as email or social networking sites whose apps you have installed. Only when you actually tap the share feature will the data be transferred to the operating system of your mobile device and from there to the app (e.g. Twitter, Facebook, email client). The further processing of the data is governed by the data protection declarations of the respective apps. The purpose and scope of the data collection and the further processing and use of the data by social networks as well as your rights and settings options for protecting your privacy can be found in the privacy policies of the respective networks: Twitter, Inc, 1355 Market St, Suite 900, San Francisco, California 94103, USA, Privacy Policy. Google Inc, 1600 Amphitheater Parkway, Mountainview, California 94043, USA, Privacy Policy. Facebook Inc, 1601 S California Ave, Palo Alto, California 94304, USA, Privacy Policy. Instagram LLC, 1601 Willow Rd., Menlo Park CA 94025, USA, Privacy Policy. YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, Privacy Policy. When is your data shared? Data collected by us will only be passed on if: you have given your express consent in accordance with Art. 6 para. 1 s. 1 lit. a GDPR, the disclosure pursuant to Art. 6 para. 1 s. 1 lit. f GDPR is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data, we are legally obliged to pass on the information in accordance with Art. 6 para. 1 s. 1 lit. c GDPR; or this is legally permissible and, according to Art. 6 para. 1 S. 1 lit. b GDPR, is necessary for the processing of contractual relationships with you or for the implementation of pre-contractual measures which are carried out at your request. In addition, information may be passed on in connection with official enquiries, court orders and legal proceedings if this is necessary for legal prosecution or enforcement. Trustpilot You have the opportunity to rate Babbel via the service “Trustpilot” from Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark. Babbel has no influence on the rating invitations, which are controlled by Trustpilot. However, we sometimes send invitations to our customers to voluntarily provide a review. In order to submit a rating or provide your feedback, it is necessary to create a user profile at Trustpilot. If the link in the Babbel invitation email is used to submit a rating in the Trustpilot service, the necessary data is transferred to Trustpilot once the link has been clicked and automatically entered into the Trustpilot registration form in order to make the rating experience as simple as possible. In addition to a rating for the inviting company, ratings for any company can then be entered on Trustpilot’s rating portal. When you participate in this feedback system, your rating will be published on Babbel and on Trustpilot’s websites. The legal basis is Art. 6 para. 1 s. 1 lit. f GDPR, based on our legitimate interest in continuously improving our services. You can find further information on data processing in the Trustpilot privacy policy. Payment Service Provider We use payment service providers. Depending on which payment method you select on checkout, the payment service providers commissioned by Babbel are responsible for collecting and processing your payment details (e.g. bank details or credit card data). In this respect the data protection declaration of the respective payment service provider applies. Data security Babbel takes security precautions to guarantee that your data is protected from loss, alteration, or misuse. Babbel does this with industry standard firewalls that are constantly being updated as well as other security systems. At the same time, the user should be aware that we cannot offer one hundred percent protection from attacks, due to the constant barrage of new viruses and means of attack on internet service’s secure data systems. Babbel will pursue every attack on the data, regardless of who carried it out, under both civil and criminal law, and inform users in the event that their data has been compromised. Last updated: May 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 What do we use Cookies for? We use Cookies to personalize the content and ads you see, provide social media features, tell us which parts of our websites people have visited, and to help us measure the effectiveness of ads and web searches. To make individual choices about cookies and get details on the cookies in use, click “Manage settings” or go to the "Privacy Statement" link in the footer of any page.Privacy Statement Manage settings Accept cookies