PRIVACY POLICY pursuant to Art. 13 GDPR

speakeasy München GmbH – Vienna location (hereinafter referred to as “speakeasy” or “we”) operates a language school together with the associated website accessible at www.speakeasy.at and its respective subpages (hereinafter referred to as the “Website”).

speakeasy would like to use this privacy policy to explain which data is processed and in what manner: when you visit our website and when you register at our language school. At the same time, we fulfill our information obligations pursuant to Art. 13 of the General Data Protection Regulation (GDPR).

I. Controller and contact details of the Data Protection Officer

The controller responsible for data processing carried out at our school and on our website is:

speakeasy München GmbH – Vienna location
Schwarzenbergplatz 2
1010 Vienna
Austria
E-mail: info@speakeasy.at
Phone: +49 89 44443363 0

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

II. Personal Data, Purposes, and Legal Basis for Data Processing

1. General Use of the Website

We do not collect or store any personal data during your visit to our website.

Notwithstanding the foregoing general principle, the web server of our hosting provider (Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany) automatically records access to the website and, in particular, your IP address.

In addition, our hosting provider creates so called log files to ensure the security of its systems. These log files contain the following information:

Date of Access
die URL
Content accessed
Information transmitted
Your IP address

This information remains anonymous to us. It is therefore not possible for us to identify you personally.

The processing of your IP address during the establishment of the connection is necessary to make our website available to you. The subsequent storage serves to ensure the security and integrity of our systems.

The processing is based on Article 6(1)(f) GDPR. Our legitimate interest lies in the fast, secure, and efficient provision of our online services.

2. Chat Function

You can contact us via the chat function available on our website. For this purpose, we use the web application Helply provided by Groove Networks Holding, Inc. (2 Dearborn St., Newport, RI 02840, USA). In order to process your request, we must process the data you provide through the chat. Depending on the nature of your inquiry, this may include your name, email address, the content of your message, your telephone number, your IP address, information about your device, and information about your location.

The legal basis for the processing is our legitimate interest pursuant to Article 6(1)(f) GDPR in providing our customers with an efficient means of communication.

Transfer to Third Countries: Personal data may be transferred to third countries, in particular to the United States. Groove Networks Holding, Inc. has entered into the European Commission’s Standard Contractual Clauses. Accordingly, such transfers are carried out on the basis of the Standard Contractual Clauses approved by the European Commission pursuant to Article 46 GDPR.

3. Transfer to Third Countries: Personal data may be transferred to third countries, in particular to the United States. Groove Networks Holding, Inc. has entered into the European Commission’s Standard Contractual Clauses. Accordingly, such transfers are carried out on the basis of the Standard Contractual Clauses approved by the European Commission pursuant to Article 46 GDPR.

4. Contact Form

We offer you the opportunity to contact us by using a contact form. For this purpose, you must provide your email address so that we can respond to your inquiry. You may also provide your name, a subject line, and the content of your message.

5. 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, any additional information you disclose in your email. In order to process your request, we must process this data. The contact form is operated through our own database, which is hosted on our behalf by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany.

6. The legal basis for the processing is either the handling of contact requests in the context of contractual or precontractual relationships pursuant to Article 6(1)(b) GDPR or our legitimate interest pursuant to Article 6(1)(f) GDPR in responding to inquiries effectively. The processing of your data in connection with your inquiry is carried out in order to process and respond to your request. The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the purpose described above.

7. Registration for Language Courses or Language Examinations via the Website

You may register directly for language courses or language examinations offered by speakeasy via our website. For this purpose, you must provide your applicable title, your name, date of birth, email address, place of birth, postal address, the course or examination level, and the course or examination date.

For the purpose of processing your registration, we also store the fee for the booked service and your selected payment method. In addition, we process your booking history and student support information.

The registration is processed through our own database, which is hosted on our behalf by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. If you register for a language examination, we will transfer your data to telc gGmbH, Basler Straße 7, 61352 Bad Homburg, Germany.

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

The processing of your data in connection with registration via the website is carried out in order to process your registration and enroll you in the language course or admit you to the language examination. The legal basis is Article 6(1)(b) GDPR.

8. Registration for Language Courses or Language Examinations at the Language School

You may also register in person for language courses or language examinations at one of our language schools. 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, postal address, telephone number, the course or examination level, and the course or examination date.

The data is stored in our own database, which is hosted on our behalf by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. If you register for a language examination, we will transfer your data to telc gGmbH, Basler Straße 7, 61352 Bad Homburg, Germany.

The processing of your data in connection with registration at one of our language schools is carried out in order to process your registration and enroll you in the language course or admit you to the language examination. The legal basis is Article 6(1)(b) GDPR.

9. speakeasy Portal

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

Your account in the speakeasy Portal is then linked to your record in our participant database so that all data you provided during your registration for a language course or language examination is also available in the portal.

The portal is hosted on our behalf by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany.

The processing of your data in connection with the use of the speakeasy Portal is carried out in order to process your registration and enroll you in the language course or admit you to the language examination. The legal basis is Article 6(1)(b) GDPR.

10. 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 advertisements while using the speakeasy German Learning App. These advertisements are displayed entirely at random and are not tailored to individual users, as no personal data or information regarding the use of the app is collected, stored, or tracked.

The speakeasy German Learning App records how often each advertisement is displayed and how often it is clicked. No information is collected about the user to whom a particular advertisement was shown or which users clicked on a particular advertisement. Only the total number of advertisement impressions and clicks is counted.

11. Email Communication, Newsletters, and Marketing via Mailchimp and SmartLingua

We send emails containing information about language courses, examinations, events, special offers, and personalized communication campaigns, such as reminders, reactivation emails, notifications regarding initiated or incomplete bookings, and requests to submit reviews of our services.

For this purpose, we use our internally developed and operated customer management system, SmartLingua.

SmartLingua is a system developed by us for the internal administration of customers and registered users. It is hosted on our behalf by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. In particular, the following data is stored and used for marketing purposes:

Name
Email Address
Course and booking history
Account and registration information
Interactions with our website or booking processes
Marketing segment assignment

In addition, we use the following service providers:

Email delivery: Intuit Mailchimp, 405 N Angier Ave. NE, Atlanta, GA 30308, United States of America

Transfer to Third Countries: Personal data may be transferred to third countries, in particular to the United States. Intuit Inc. is certified under the EU US Data Privacy Framework, ensuring an adequate level of protection for the processing of personal data. In addition, Standard Contractual Clauses have been concluded.

Email delivery: Mailjet GmbH, Alt Moabit 2, 10557 Berlin, Germany
Helpdesk and Customer Service: Groove Networks Holding, Inc., 2 Dearborn St., Newport, RI 02840, USA

Marketing emails are sent exclusively on the basis of your prior express consent pursuant to Article 6(1)(a) GDPR. Your consent includes, in particular:

Sending information about courses and special offers
Sending reminders or reactivation emails
Sending notifications regarding initiated or incomplete bookings
Requesting customer reviews or feedback
Providing personalized content based on your use of our services or your interests
Analyzing email openings and clicks to optimize our communications

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

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

12. MySpeakMate App

You may use the MySpeakMate App to improve your language skills. The app enables the storage of your learning progress and provides additional learning related features.

In connection with your use of the app, we process personal data, in particular:

Registration data (email address and password)
Usage and learning data
Communication and language input within the app
Technical usage data, such as device information, log data, and the time of use

The recipient of the data is the provider of the app infrastructure, Gesellschaft für Weiterbildung mbH, Warschauer Str. 36, 10243 Berlin, Germany.

The legal basis for the processing is Article 6(1)(b) GDPR, insofar as the processing is necessary for the performance of the user relationship, and, where applicable, Article 6(1)(f) GDPR based on our legitimate interest in providing the app in a secure and user friendly manner.

13. Processing Based on Legal Obligations

In certain cases, we are legally required to process your personal data. These obligations include retaining certain data for a specified period of time. In particular, we are required by law to retain data relevant for tax and accounting purposes for periods of six or ten years for evidentiary purposes and, where necessary, to provide such data during inspections by public authorities or external auditors.

Where we process data in order to comply with our accounting and tax retention obligations, the legal basis is Article 6(1)(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 Personal Daten

Within our company, only those departments responsible for handling your request have access to your personal data. In addition, we engage external service providers where it is not practical or appropriate for us to perform the relevant services ourselves.

These external service providers primarily include providers of IT and telecommunications services. In connection with language examinations, we also transfer your data to telc gGmbH. Upon request from public authorities, such as embassies or the Berlin Immigration Office, we may disclose information where there is a legitimate interest. If your employer pays for your language course or examination, we may, upon your employer’s request, provide information about your booking history and, in the case of language examinations, whether you passed or failed. Where language students are referred to speakeasy by external organizations, the booking resulting directly from such referral is reported to the respective referring organization.

Some of the service providers we use are located in, or process personal data in, the United States. Personal data is transferred either on the basis of the Standard Contractual Clauses approved by the European Commission pursuant to Article 46 GDPR or on the basis of an adequacy decision issued by the European Commission, where such a decision exists for the respective service provider. This ensures an adequate level of data protection.

As a general rule, we do not transfer personal data to third countries unless such transfer is necessary for the performance of your request, required by law, or based on your consent.

IV. Data Retention

Our log files and your IP address are retained for 14 days.

If you contact us via our chat function, your data will be stored for as long as necessary to process your request and in accordance with the retention periods of the service provider used (https://helply.com/privacy).

We retain your emails and other inquiries for as long as necessary to process your request and subsequently for a period of three years in case you contact us again regarding your original inquiry.

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

Data processed in connection with the MySpeakMate App is retained for as long as necessary to provide your user account.

We are subject to statutory retention obligations under German tax law. These records may contain personal data. The applicable retention periods are governed by Section 257 of the German Commercial Code (HGB) and Section 147 of the German Fiscal Code (AO). Accordingly:

Books and accounting records, commercial books, inventories, annual financial statements, separate financial statements pursuant to Section 325(2a) HGB, consolidated financial statements, management reports, consolidated management reports, opening balance sheets, the working instructions and organizational documents required for their understanding, accounting records, supporting documents for bookkeeping pursuant to Section 238(1) HGB, and documents pursuant to Articles 15(1) and 163 of the Union Customs Code must be retained for a period of ten years.
Received commercial or business correspondence, copies of sent commercial or business correspondence, and other documents relevant for taxation must be retained for a period of six years.

The applicable retention period begins at the end of the calendar year in which the last entry was made in the relevant book or commercial ledger, the inventory, opening balance sheet, annual financial statements, or management report was prepared, the commercial or business correspondence was received or sent, the accounting document was created, the relevant record was made, or the respective document came into existence. Upon expiry of the applicable retention period, the documents are deleted or destroyed.

V. Obligation to Provide Personal Data

You are under no contractual or legal obligation to provide us with your personal data. However, without the data you provide, we are unable to offer you our services.

VI. Automated Decision Making (Including Profiling)

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

VII. Use of Cookies, Tracking Tools, and Third Party Services on Our Websites and Apps

We use technologies on our websites and applications for analytics and statistical purposes, marketing, and the integration of external content such as videos, reviews, and other third party content. These technologies involve the processing of personal data, often in pseudonymized form. Technologies such as cookies also store information on your device or access information already stored on your device, always subject to your prior consent where required.

We provide you with comprehensive information and a range of choices regarding the technologies we use, enabling you to control their use according to your preferences. You can access these settings at any time by clicking the paperclip icon located in the lower left corner of our website.

Alternatively, you can access the privacy settings by clicking the corresponding button in the lower left area of the website. Information already stored on your device may also be deleted at any time using your internet browser or other software. This is possible in all common internet browsers. Please note that deleting this information will also remove your selected privacy settings, which will need to be configured again upon your next visit to our services. The retention period for stored information is displayed within the privacy settings.

To manage your consent, we use the Cookie Consent Management Platform (CMP) provided by Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, Germany. The processing is based on our legitimate interest pursuant to Article 6(1)(f) GDPR.

Below, we explain the categories used in our privacy settings in greater detail. There you will also find information about the individual services and providers used on our websites and applications, as well as the purposes for which they are used. All storage, access, and processing for the purposes described below are based on your consent pursuant to Section 25 TDDDG and Article 6(1)(a) GDPR. Only the category “Necessary” is based on Article 6(1)(f) GDPR and Section 25(2) No. 2 TDDDG.

1. Necessary

These cookies and related processing activities help make the website usable by enabling essential functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

2. Preferences

Preference cookies enable a website to remember information that changes the way the website behaves or appears, such as your preferred language or the region in which you are located.

3. Statistics

Statistics cookies and the related processing activities analyze your use of our services, for example which pages you visit and which links you click. This helps us understand how visitors interact with our services and enables us to improve and optimize them. Pseudonymous user profiles may also be created for these purposes.

In addition, interactions with marketing emails, such as email opens or clicks, may be linked to existing user profiles within our SmartLingua system, provided that you have consented to receiving the respective marketing communications.

4. Marketing

Marketing cookies and the related processing activities also analyze your use of our services. However, the collected information is used to display advertisements for our services on other platforms, such as search engines, social networks, or other websites connected to advertising networks. The effectiveness of these advertisements is also measured, for example whether you click on an advertisement and subsequently make a booking with us.

5. Integration of External Content

We integrate external content such as maps and videos into our websites. This only takes place with your consent. If you choose this option, your device will establish a connection with the respective provider, which may collect data for purposes including analytics and advertising.

VIII. Links to Social Networks

We maintain profiles on various social networks. Our social media accounts complement our website and provide you with additional opportunities to interact with us. As soon as you access one of our social media profiles, the terms of use and privacy policies of the respective network operator apply.

Any data collected about you while using these services is processed by the respective social network and may also be transferred to countries outside the European Union where an adequate level of protection for personal data may not exist.

As a general rule, we have no influence over the processing of personal data carried out by social networks, as we are, like you, merely users of these platforms.

Further information about the data processed by the respective social networks and the purposes of such processing can be found in the privacy policies of the respective providers listed below.

We use the following social networks:

1. Facebook

Our Facebook page is available at:

https://www.facebook.com/speakeasyinberlin/?locale=de_DE

The network is operated by:

Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

Privacy Policy:

https://www.facebook.com/privacy/center/

2. Instagram

Our Instagram page is available at:

https://www.instagram.com/speakeasyberlin/?hl=de

The network is operated by:

Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

Privacy Policy:

https://privacycenter.instagram.com/

3. Joint Controllership

Purposes: We process personal data as an independent controller when you send us inquiries via our social media profiles. We process this data in order to respond to your inquiries.

In addition, we act as joint controllers with the following social networks for the processing activities described below pursuant to Article 26 GDPR.

When you visit our profiles on Facebook or Instagram, the respective network collects aggregated statistics (“Insights Data”) generated from certain events recorded by its servers when you interact with our profiles and their associated content. We receive these aggregated and anonymized statistics from the network regarding the use of our profiles. As a general rule, we are not able to attribute the data to individual users. To a limited extent, we may determine the criteria according to which the network compiles these statistics for us. We use these statistics to make our profiles more attractive and informative for our users.

Further information regarding the processing of Insights Data by Facebook and Instagram can be found in the Joint Controller Addendum:

https://www.facebook.com/legal/terms/information_about_page_insights_data .

Apart from the processing described above, the respective social networks are solely responsible for the processing of your personal data.

Legal Basis: The processing is based on our legitimate interests pursuant to Article 6(1)(f) GDPR. Our legitimate interest is the respective purpose described above.

Retention Period: Within the scope of the joint controllership, we do not store any personal data ourselves. With regard to inquiries submitted outside the respective social network, the information provided above under contact requests applies accordingly.

IX. Insights of Data Subjects

The General Data Protection Regulation (GDPR) grants you certain rights which you may exercise against us, provided that the applicable legal requirements are met.

Article 15 GDPR, Right of Access: You have the right to obtain confirmation as to whether we process personal data relating to you and, where that is the case, to obtain access to such personal data as well as information about the circumstances of the processing.
Article 16 GDPR, Right to Rectification: You have the right to obtain 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.
Article 17 GDPR, Right to Erasure: You have the right to request the erasure of personal data concerning you without undue delay.
Article 18 GDPR, Right to Restriction of Processing: You have the right to request the restriction of the processing of your personal data.
Article 20 GDPR, Right to Data Portability: Where the processing is based on your consent or is necessary 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. You also have the right to transmit those data to another controller without hindrance from us or to have the data transmitted directly to another controller where technically feasible.
Article 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 where such processing is based on our legitimate interests, is necessary for the performance of a task carried out in the public interest, or is carried out in the exercise of official authority.

If you object to the processing, 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 unless the processing is necessary for the establishment, exercise, or defense of legal claims.

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

Article 77 GDPR in conjunction with Section 19 of the German Federal Data Protection Act (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 your personal data infringes applicable data protection law.

X. Contact

If you have any questions regarding data protection:
info@speakeasy.at

Berlin, July 2026