German Language School Stuttgart

PRIVACY POLICY pursuant to Art. 13 GDPR

The speakeasy Berlin GmbH (hereinafter as “speakeasy” or “we”) runs a language school with a corresponding website available under www.speakeasy-munich.de and the corresponding subdirectory (hereinafter “the website”).

With this Privacy Policy, speakeasy would like to explain which data are processed and in what way when you visit our Website and when you register with our language school. At the same time, we hereby comply with our information obligations towards you pursuant to Art. 13 of the General Data Protection Regulation, GDPR.

I. Controller and contact details of the Data Protection Officer

The controller under data protection law for the data processing activities taking place at our school and on our Website is

speakeasy München GmbH
E-Mail: info@speakeasy-munich.de
Telefon: 089 4444 33630

Our Data Protection Officer can be contacted at:
m.nikolov@gfw.education

II. Personal data, purposes and legal basis of data processing

1. Personal data

Under the GDPR, personal data means “any information relating to an identified or identifiable natural person, hereinafter referred to as the ‘data subject’; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

a) General use of the Website

When you visit our Website, we do not collect or store any personal data.

Notwithstanding the above general principle, the web server of our hosting provider automatically logs access to the Website and, in particular, your IP address.

In addition, our hosting provider creates log files in order to maintain system security. These log files contain the following information:

  • date of access
  • the URL
  • content accessed
  • the information transmitted
  • your IP address

This information remains anonymous to us. It is therefore not possible for us to draw conclusions about a specific person.

Your IP address is processed during the establishment of the connection in order to make our Website available to you. Subsequent storage takes place in order to ensure the security and integrity of our systems. These processing activities are based on Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the respective purpose stated above.

b) Chat function

You may contact us via a chat function on our Website. In order to process your request, we must process the data you provide to us in the chat. Depending on the nature of your inquiry, this may include your name, your email address, the content of your message, your phone number, your IP address, information about your device and information about your location.

c) Contact form

We offer you the opportunity to contact us using a form. For this purpose, you must provide us with your email address so that we can respond to your inquiry. In addition, you may provide us with your name, a subject line and your specific message.

If you contact us using the email address provided on our Website, you will at least provide us with your email address and, where applicable, further information that you disclose in your email. In order to process your request, we must process these data.

d) Registration for language courses or language examinations via the Website

You have the option to register directly via our Website for language courses or language examinations at speakeasy. For this purpose, you must provide us with the form of address applicable to you, your name, your date of birth, your email address, your place of birth, your address, the course or examination level, and the course or examination date.

For the purpose of processing the registration, the amount of the booked service and your payment method are also stored. In addition, your booking history and support information are processed.

If you register for a language examination, we pass your data on to telc gGmbH, Basler Straße 7, 61352 Bad Homburg.

If the registration process is aborted, the data entered up to that point will nevertheless be stored.

e) Registration for language courses or language examinations at the language school

You may also register in person at our language school for language courses or language examinations. In this case, you must provide us with the following data so that we can process your registration: name, email address, gender, nationality, native language, date of birth, address, phone number, course or examination level, and course or examination date.

If you register for a language examination, we pass your data on to telc gGmbH, Basler Straße 7, 61352 Bad Homburg.

For the purpose of processing the registration, the amount of the booked service and your payment method are also stored. In addition, your booking history and support information are processed.

f) speakeasy portal

For your registration in the speakeasy portal, we process the following mandatory information from you: email address.

Your account in the speakeasy portal is then linked to your entry in our participant database, so that all data you provided when registering for your language course or language examination will also appear there.

g) speakeasy German learning app

The speakeasy German learning app does not collect or store any personal data of its users. Users may be shown customer specific advertising during the use of the speakeasy German learning app. This advertising is displayed entirely at random and is not tailored to the individual user, as no personal data or data regarding the use of the app are collected, stored or tracked.

The speakeasy German learning app tracks how often each advertisement is displayed and how often users click on that advertisement. No information is collected about the user to whom the respective advertisement was displayed, nor about which users clicked on the respective advertisement. Only the number of displays and clicks on the advertisement is counted.

h) Email communication, newsletters and marketing via Mailchimp and SmartLingua

We send emails containing information about language courses, examinations, events and offers, as well as personalized communication campaigns, for example reminders, reactivation emails, notices regarding started or uncompleted bookings, or requests to submit reviews of our services.

For this purpose, we use our internally developed and operated customer data management system “SmartLingua” as well as the email delivery service Mailchimp.

SmartLingua is a system developed by us for the internal administration of customers and registered users. In particular, the following data are stored there and used for marketing purposes:

  • name
  • email address
  • course and booking history
  • account and registration information
  • interactions with our Website or booking processes
  • marketing segmentation data

These data may be transferred to Mailchimp, Intuit Inc., USA, for the purpose of carrying out email campaigns and may be processed there.

Marketing emails are sent exclusively on the basis of your prior express consent. This consent includes, in particular:

  • sending information about courses and offers
  • reminders or reactivation emails
  • notices regarding started or uncompleted bookings
  • requests to submit customer reviews or feedback
  • personalized content based on your usage or interests
  • analysis of opens and clicks in order to optimize our communication

The legal basis is Art. 6 para. 1 lit. a GDPR.

You may withdraw your consent at any time with effect for the future. Every email contains an unsubscribe link, opt out. Alternatively, you may contact us at info@speakeasy-munich.de.

If you submit a review via a link provided by us, your data will be processed by the respective platform. In that case, the privacy policy of the respective provider shall apply.

i) Processing due to legal obligations

In some cases, we are obliged to process your data due to legal obligations. These obligations consist in having to retain certain data for a specific period of time. For example, we are legally required to retain data relevant under tax law and or accounting law for evidentiary purposes for a period of 6 or 10 years and, where applicable, to provide them in the event of audits by authorities or external auditors.

j) Purposes and legal basis of data processing

Your IP address is processed during the establishment of the connection in order to make our Website available to you. This processing is based on Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the purpose stated above.

Data are processed in the context of contacting us in order to process and respond to your inquiry. The legal basis is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the purpose stated above.

Data are processed in the context of registration, whether via the Website or in person at the school, in order to process your registration and admit you to the language course or language examination. The legal basis is Art. 6 para. 1 lit. b GDPR.

Data are processed in the context of using the speakeasy portal in order to process your registration and admit you to the language course or language examination. The legal basis is Art. 6 para. 1 lit. b GDPR.

Where we process data due to our retention obligations under accounting and tax law, this is done on the basis of Art. 6 para. 1 lit. c GDPR in conjunction with Section 257 of the German Commercial Code, HGB, and Section 147 of the German Fiscal Code, AO.

III. Recipients of the data

Within our company, those departments that are responsible for processing the relevant matters have access to your data. In addition, we use external service providers where we do not or cannot reasonably perform services ourselves. These external service providers are, in particular, providers of IT services and telecommunications services. In the case of language examinations, we also transmit your data to telc gGmbH. Upon request from authorities such as embassies or the Berlin immigration authority, we also provide information where there is a legitimate interest. If your employer pays for your course or your language examination, we provide your employer, upon request, with information about your booking history and, in the case of language examinations, your result, passed or failed. Where language students are referred to speakeasy by external bodies, the booking of the language students directly resulting from that referral is reported to those external bodies.

Some of the service providers we use are located in the USA and process personal data there. The transfer of personal data takes place on the basis of the Standard Contractual Clauses approved by the European Commission pursuant to Art. 46 GDPR or on the basis of an adequacy decision of the European Commission, where such a decision exists for the respective service provider. This ensures an adequate level of data protection.

For the administration of customer and marketing data, we use the internal system SmartLingua. For the sending of email campaigns, we use the service provider Mailchimp, Intuit Inc., USA. For this purpose, personal data may be transferred from SmartLingua to Mailchimp and processed there.

Mailchimp processes personal data in the USA. The transfer takes place on the basis of the Standard Contractual Clauses approved by the European Commission pursuant to Art. 46 GDPR or an adequacy decision of the European Commission, EU US Data Privacy Framework. This ensures an adequate level of data protection.

As a rule, we do not transfer data to third countries unless such transfer is necessary for the performance of your orders, required by law, or you have given us your consent to do so.

IV. Storage period

Our log files are stored for 14 days. We store your emails and contacts for as long as is necessary to process your inquiry and subsequently for a period of 3 years in case you contact us again with reference to your original question.

If you register for a language course or a language examination with speakeasy, we store your data for the duration of the contractual relationship and thereafter for a period of 3 years beginning at the end of the year in which the contractual relationship ended.

We are subject to statutory retention obligations for documents under tax law. These documents may contain personal data. Their storage period is determined by Section 257 of the German Commercial Code, HGB, and Section 147 of the German Fiscal Code, AO. According to these provisions, the following must be retained:

  • books and records or commercial books, inventories, annual financial statements, individual financial statements pursuant to Section 325 para. 2a HGB, consolidated financial statements, management reports, group management reports, the opening balance sheet, as well as the work instructions and other organizational documents necessary to understand them, and accounting records, supporting documents for entries in the books to be kept pursuant to Section 238 para. 1 HGB, and documents pursuant to Article 15 para. 1 and Article 163 of the Union Customs Code, for a period of 10 years, and
  • received commercial or business letters, reproductions of sent commercial or business letters, and other documents insofar as they are relevant for taxation, for 6 years

The retention period begins at the end of the calendar year in which the last entry was made in the book or commercial book, the inventory, the opening balance sheet, the annual financial statements or the management report were prepared, the commercial or business letter was received or sent, the accounting record came into existence, the record was made, or the other documents came into existence. After expiry of the retention period, the documents are destroyed.

V. Obligation to provide data

You are under no contractual or legal obligation to provide us with personal data. However, without the data you provide to us, we are not in a position to offer you our services.

VI. Existence of automated decision making, including profiling

We do not use automated decision making that produces legal effects concerning you or similarly significantly affects you.

VII. Internet specific data processing

a) Cookies

Our Website uses cookies. These are small files that are stored on your end device and saved in your browser. Cookies serve the purpose of improving our offering in terms of user friendliness, security and effectiveness and of recognizing your browser on your next visit.

We distinguish between the following four categories of cookies: necessary, preferences, statistics and marketing. When visiting our Website, you may consent to the use of cookies, consent to restricted use, or decline their use. If you disable cookies, the use of the Website may be restricted.

b) Google Maps

We use Google Maps to display an interactive map. By using Google Maps, information, including your IP address, is transferred directly to a Google server. If you are logged into your Google account, Google also uses cookies in order to provide you with personalized functions. We have no influence over these processing activities. If you do not want Google to set corresponding cookies, please log out of your Google account before using the service.

The legal basis for the use of this service is Art. 6 para. 1 lit. f GDPR. The legitimate interest lies in the increased convenience we provide to our users. In this context, we do not store any personal data.

c) Google Analytics

The Website uses Google Analytics. This is a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies, small text files that are stored in your browser and make it possible to analyze your use of our Website. The information made available by the cookies about your use of our Website is transmitted to a Google server in the USA and stored there.

IP anonymization

By means of the IP anonymization function activated on our Website, your IP address is shortened before transmission to a Google server in the USA. Only in exceptional cases is the shortening carried out after transmission to a Google server in the USA. Google uses the transmitted information on behalf of our Website in order to analyze your use of our Website, “to compile reports on website activity and to provide other services relating to website activity and internet usage to the website operator.” Your IP address transmitted to Google Analytics is not merged with other Google data. The remaining collected data are deleted after 26 months.

The legal basis is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the purpose stated above.

Demographic characteristics

Our Website uses the “demographic characteristics” function of Google Analytics. This function makes it possible to generate reports containing statements about the age, gender and interests of website visitors. These data originate from interest based advertising by Google and from visitor data of third party providers. These data cannot be assigned to a specific person. You may deactivate this function at any time via the ad settings in your Google account.

d) YouTube

“Our Website uses plugins from the Google operated site YouTube. The operator of the pages is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit one of our pages equipped with a YouTube plugin, a connection to the YouTube servers is established. In doing so, the YouTube server is informed which page you have visited.

If you are logged into your YouTube account, you enable YouTube to assign your browsing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

Further information on data processing by Google can be found in Google’s privacy notices, which are available at www.google.com/privacypolicy.html.”

e) Adroll

Our Website uses Adroll, a retargeting service. Adroll also works with cookies that are stored in your browser when you visit our Website. This allows Adroll to create a list of all visitors and to show you advertising from speakeasy, even when you are on other websites or social media platforms.

f) Mouseflow

This Website uses Mouseflow, a web analytics tool that provides valuable information about how users interact with and move around this Website. The information collected is used to make the Website faster and more user friendly. Mouseflow offers functions such as session replay, heatmaps, funnel analysis, form analysis, feedback surveys, user journeys and similar features.

Mouseflow may collect your clicks, mouse movements, scrolling behavior, pages visited, time spent on the Website, browser and operating system information, device type, desktop, tablet or smartphone, screen resolution, visitor type, first time visitor or returning visitor, referrer, anonymized IP address, location, city or country, responses to feedback surveys, preferred language and similar metadata.

The data collected by Mouseflow are not used to personally identify visitors to this Website. Mouseflow does not capture information on pages where it is not installed and does not track or collect any data outside your web browser.

Further information about Mouseflow and its services can be found at https://www.mouseflow.com. Mouseflow’s privacy policy can be found at https://mouseflow.com/legal/company/privacy-policy/.

The legal basis for the setting of Mouseflow cookies is your consent, Art. 6 para. 1 lit. a GDPR. You may deactivate these cookies at any time via your cookie settings. Alternatively, you may object here: https://mouseflow.com/opt-out.

The legal basis for the subsequent processing of the data collected by Mouseflow, such as use, analysis and storage, is the legitimate interest, Art. 6 para. 1 lit. f GDPR, in improving and optimizing this Website.

In addition, interactions with marketing emails, for example opens or clicks, may be linked to existing user profiles in our SmartLingua system, provided that you have consented to the relevant marketing communication.

VIII. Rights of data subjects

The General Data Protection Regulation grants you certain rights which you may assert against us, provided that the legal requirements are met.

  • Art. 15 GDPR, right of access by the data subject: You have the right to obtain from us confirmation as to whether personal data concerning you are being processed and, if so, which data these are, as well as further details of the processing.
  • Art. 16 GDPR, right to rectification: You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  • Art. 17 GDPR, right to erasure: You have the right to obtain from us the erasure of personal data concerning you without undue delay.
  • Art. 18 GDPR, right to restriction of processing: You have the right to obtain from us restriction of processing.
  • Art. 20 GDPR, right to data portability: In the case of processing based on consent or for the performance of a contract, you have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine readable format and to transmit those data to another controller without hindrance from us, or to have the data transmitted directly to the other controller where technically feasible.
  • Art. 21 GDPR, right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on our legitimate interests or on the performance of a task carried out in the public interest, or carried out in the exercise of official authority.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

Where we process your personal data for the purposes of direct advertising or marketing communication, for example newsletters or informational emails, you have the right to object at any time or to withdraw your consent. This applies in particular to newsletters or other informational emails. If you object to processing for the purposes of direct advertising, we will no longer process your personal data for these purposes.

  • Art. 77 GDPR in conjunction with Section 19 BDSG, right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint at any time with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes applicable law.

IX. If you have comments or questions

We take every conceivable precaution to protect and secure your data. Your questions and comments regarding data protection are welcome. Please simply send an email to info@speakeasy-munich.de.

Berlin, March 2026

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