Privacy Policy


1 PRIVACY STATEMENT FOR VITA LINGUA
We treat personal data under the Germany Data Protection Act (incorporating the EU General Data Protection Regulation - GDPR) to our global operations unless the local equivalent laws are stronger. Also, we apply the personal data under the provisions of the California Consumer Privacy Act (CCPA) in our operations in California.
We operate the website www.vitalingua.com along and collect certain data from our visitors and customers as necessary. With this privacy policy, Vita Lingua would like to explain how your personal data is processed and in what form some of this data may be accessible to other users.
In the following privacy policy, you will learn what we do with your personal data and why. We will also tell you how we protect your data, when the data will be deleted and what rights you have under data protection law.

2 SCOPE OF THIS PRIVACY POLICY
The German version of this privacy policy is deemed to be the basis for using the Vita Lingua’s online-service. Its translation into English, Spanish, French, and Chinese is provided for information purposes only. In case of contradictions, the only legally binding version of the document (which can be viewed here) is the German version.

3 DECLARATION OF CONSENT
By using the service offered on the Vita Lingua website you automatically agree to the following privacy policy. Your declaration of consent will be recorded by us. You can withdraw your declaration of consent at any time via email, however not in retrospect. Withdrawing your consent means that you may no longer use any of the services provided by Vita Lingua. In addition to the data processing on our website, we explain in this privacy policy the data processing in the services we offer for which our customers can register.
This privacy policy will explain:
- What data Vita Lingua collects and what we do with it.
- What technologies we use for provision and personalization.
- What data protection rights you have and how you can exercise them.

4 CONTACT
The trust of our users is important to us. Vita Lingua therefore wishes to provide its users with full information on the processing of their personal data at all times. If any queries remain unanswered by this privacy statement or if more detailed information is required on any point, please contact the following address at any time.
Author of this page:
Vita Lingua, José Delgado
Schmarjestr. 42 22767
Hamburg
email: mail (@) vitalingua.com
You can also reach our Data Protection Supervisor and other data protection-related contacts via these contact details. In this context, we process data exclusively for the purpose of communicating with you. The legal basis for the data processing is the performance of the contract pursuant to Article 6(1)(b) GDPR.

5 GET IN TOUCH
We collect your personal data when you provide it to us of your own accord, e.g. when you contact us. This information is communicated on a voluntary basis and in these cases is initiated by you. Insofar as this involves information regarding communication channels (email address, telephone number), we will use these channels to contact you in accordance with your request.
Legal basis for data processing
The legal basis for processing the data that you transmit to us in the course of contacting us is Art. 6 (1)(f) GDPR.
Purpose of data processing
The purpose of processing your data is to handle and respond to your request.
Duration of storage
We will delete the data we have received in the course of contacting you as soon as it is no longer required to achieve the purpose for which it was collected, i.e. your request has been fully processed and no further communication with you is required or requested.
Possibility of objection and removal
If a user contacts us by email, they can object to the storage of their personal data at any time.

6 WHAT RIGHTS DO YOU HAVE?
- Withdrawal of consent in accordance with Article 7(3) GDPR (e.g. you can contact us to withdraw consent and stop receiving the newsletter)
- Right of Access in accordance with Article 15 GDPR (e.g. you can contact us to find out which data of yours we have saved)
- Rectification in accordance with Article 16 GDPR (e.g. you can contact us if your email address has changed and you want us to update it)
- Erasure in accordance with Article 17 GDPR (e.g. you can contact us if you want us to delete any of your data that we have saved)
- Restriction of processing in accordance with Article 18 GDPR (e.g. you can contact us if you do not want us to delete your email address but only want to receive emails that are strictly necessary)
- Data portability in accordance with Article 20 GDPR (e.g. you can contact us to obtain the data we have saved on you in a compressed format as you may want to provide the data to another website)
- Objection in accordance with Article 21 GDPR (e.g. you can contact us if you do not consent to one of the advertising or analytical procedures listed in this document)
- Right to lodge a complaint with the relevant supervisory authority in accordance with Article 77(1) GDPR (e.g. in the event of a complaint you could contact the data protection supervisory authority in your state directly)

Supervisory authority in Hamburg
Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Straße 22
20459 Hamburg

Your rights concerning the processing of your personal data
To exercise your rights, you must send us a request in writing, either by post or email. If you would also like to speak to someone in person, you can contact us by telephone. You will need to provide:
. proof of identity
. proof of address
. any additional details we need to locate the information you have requested (for example, details regarding Vita Lingua or staff that you have had contact with and when).
We will not start looking for your information until we confirm your identity.

7 DELETION OF DATA AND STORAGE PERIOD
If not otherwise noted, we delete personal data as soon as it is no longer needed. Your data will also be locked or deleted if a storage period set out by law expires, unless the data must be kept in order to complete or fulfil a contract. Some data may have to be stored for a longer time period if the law requires it. You can, of course, request information regarding the personal data we have saved on you at any time.

8 SERVER LOG FILES
If you visit our website, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website. The website provider -Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (Germany)- automatically collects and stores information that your browser automatically transmits to us in "server log files". These are:
- File names of the pages and files called up
- Date and time of the visit - Amount of data transferred
- 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 identifiers)
- The previously visited page (if you accessed our website via a link)
- Online identifiers (e.g. IP address, session IDs, cookies, device identifiers)
- Geo data (e.g. city, postal code) transmitted via the IP address

As a protective measure in favour of your privacy, we delete or anonymize the IP address after specified periods. Therefore, other related data can no longer be traced back to you and may only serve anonymous, statistical purposes for the optimization of our website. The purpose of the temporary storage of the data is a technical necessity for establishing the connection, and the correct and error-free display of our website. The IP address and the technical data already mentioned are needed to display the website, to prevent display problems for visitors and to correct error messages.
The legal basis is the so-called legitimate interest which has been examined in the context of the aforementioned protective measures and in accordance with the European data protection requirements from Article 6(1)(f) GDPR.

8 COOKIES
This  portal,  like  most  Internet  portals,  uses  cookies  to  improve  the  user's  experience. Below you will find information on what "cookies" are, what type of cookies this portal uses, how to deactivate cookies in your browser and how to specifically deactivate the installation of third party cookies. Cookies  are  small  files  that  some  platforms,  like  websites,  may  install  on  your computer, smartphone, tablet or connected television. The purpose thereof can be very varied: to store your browsing preferences, compile statistical information, allow certain technical features, etc. Cookies contain information on your current and previous website visits:
- Name of the website
- Cookie expiration date
- 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. Our website uses the following three types of cookies:
- Required cookies (these are needed, for example, in order to display the website correctly for you and to temporarily save certain settings)
- Functional and performance cookies (these cookies help us, for example, to evaluate technical data from your visit and therefore avoid error messages)
- Advertising and analytics cookies (these cookies ensure that, for example, you see ads for Spanish if you had previously searched for Spanish)
You can use your browser settings to configure, block, and delete cookies. If you want change or delete cookie-settings and would like to determine which cookies have been saved to your browser, you can find this info in your browser-settings:
Chrome: Clear, enable and manage cookies in Chrome
Safari: Manage cookies and website data in Safari
Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete cookies in Microsoft Edge
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.

9 GOOGLE FONTS
This website uses Google Fonts from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, a font collection from Google, are used to visually improve the typeface. These fonts are transferred to your browser's storage folder and activated when you access this website or other websites. Using above web-fonts allow us to display our contents in a homogenious and visual attractive way which is a justifiable interest. If your browser does not support web-fonts a standard font from your computer will be used as substitute. More Information you can find using the following link.
The legal basis is the so-called legitimate interest, which has been examined in order to pursue the purpose and within the framework of the aforementioned protective measures, as well as in accordance with the European data protection requirements from Article 6(1)(f) GDPR.

10 GOOGLE ANALYTICS
If you have given your consent, this website uses Google Analytics, a web analysis service of Google LLC. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (‘Google‘).
Scope of processing
Google Analytics uses cookies that enable an analysis of your use of our website. The information collected by the cookies about your use of this website is usually transferred to a Google server in the USA and stored.
We use the function User-ID. The User ID allows us to assign a unique, permanent ID to one or more sessions (and the activities within these sessions) and to analyze user behaviour across devices.
We use Google Signals. This allows Google Analytics to collect additional information about users who have activated personalized ads (interests and demographic data). Also, ads can be delivered to these users in cross-device remarketing campaigns.
We use the function 'anonymizeIP' (so-called IP-Masking): Due to the activation of IP-anonymization on this website, your IP-address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google.
During your website visit the following data will be collected:
- The pages you visit, your ‘click behaviour‘
- Achievement of ‘website goals‘ (conversions, e.g. newsletter registrations, downloads, purchases)
- Your user behaviour (for example clicks, dwell time, bounce rates)
- Your approximate location (region)
- Your IP address (in abbreviated form)
- Technical information about your browser and the end devices you use (e.g. language settings, screen resolution)
- Your internet provider
- The referrer URL (via which website/advertising medium you came to this website)
Purposes of processing
On behalf of the operator of this website, Google will use this information to evaluate your (pseudonymous [not user id]) use of the website and to compile reports on website activity. The reports provided by Google Analytics serve to analyse the performance of our website and the success of our marketing campaigns.
Recipient
The data recipient is: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as data processor. For this purpose we have concluded a contract with Google. Google LLC, headquartered in California, USA, and, if applicable, US authorities can access the data stored at Google.
Transfer to third countries
A transfer of data to the USA cannot be excluded. Duration of storage The data sent by us and linked to cookies is automatically deleted after 14 months. Data is automatically deleted once a month as soon as the storage period is reached.
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by:
a. not consenting to cookies or
b. downloading and installing the browser add-on to disable Google Analytics here.
By setting your browser software accordingly you can also prevent the storage of cookies. If your browser is set to refuse all cookies, the functionality of this and other websites may be limited.
Legal basis and right of withdrawal Your consent is the legal basis for this data processing, Article 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future by changing your selection in the cookie settings. More information here about Google Analytics terms of use and Google's privacy policy.

12 GOOGLE TAG MANAGER
This website may uses Google Tag Manager. Google Tag Manager is a solution operated by Google LLC. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) that allows marketed website tags to be managed using an interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not register personal data. The tool causes other tags to be activated which may, for their part, register data under certain circumstances. Google Tag Manager does not access this information. If recording has been deactivated on domain or cookie level, this setting will remain in place for all tracking tags implemented with Google Tag Manager. You can find more information on data protection in Google‘s data protection policy.
The legal basis for use of this service is your consent as laid out in Article 6(1)(a) GDPR, and consent is granted via our cookie banner. Consent can be withdrawn at any time via cookie management.

13 WHEN IS DATA PASSED ON?
Data collected by us will only be passed on if:
- You have given your express consent in accordance with Article 6(1)(a) GDPR
- The disclosure is necessary for the assertion, exercise or defense of legal claims pursuant to Article 6(1)(f) GDPR and there is no reason to assume that you have an overriding interest worthy of protection in not having your data disclosed
- We are legally obligated to disclose your data pursuant to Art. 6 Par. 1 Sentence 1 lit. c GDPR or
- This is legally permissible and necessary according to Article 6(1)(b) GDPR for the processing of contractual relationships with you or for the implementation of pre-contractual measures that take place at your request In addition, disclosure may take place in connection with official inquiries, court decisions and legal proceedings if it is necessary for legal prosecution or enforcement.

14 LINKS
Vita Lingua might contain links to other internet sites. We are not responsible for the private practices on other internet sites. We encourage our users to read through every privacy setting on every internet site individually before giving away any personal data.

15 AGE LIMIT FOR THE USE OF VITA LINGUA
The Vita Lingua offer is not aimed at children under 16 years of age. The Vita Lingua offer is also not offered to children whose age makes the processing of their personal data illegal or requires the consent of their parents to the processing of their personal data in accordance with the general data protection regulation (GDPR) or other local laws.
It is also pointed out that persons under 18 years of age always require the permission of parents or legal guardians in order to use the service. If you are under 16 years of age, do not provide us with any personal data. If you are a parent of a child under the age limit and you notice that your child has submitted personal data to Vita Lingua, please contact us using the contact form.

16 DATA SECURITY
Vita Lingua takes adequate security measures to protect the user's data. When you enter confidential data (e.g. passwords) we encode them by using secure SSL technology. Vita Lingua employs safety precautions to guarantee that your data are protected against loss, modification or misuse. To this end, Vita Lingua works with constantly updated firewalls meeting the industry standard as well as other security systems. At the same time, the user should be aware of the fact that one hundred per cent protection against attacks cannot be guaranteed because of the continual appearance of new viruses and other means of attacking the protected data systems of internet services. Vita Lingua will instigate civil and criminal proceedings against any attack by hackers and the like and will inform the users of any cases in which their data have been compromised.

17 PUBLICATION AND AMENDMENTS
We reserve the right to change our privacy policy. Amendments which are not fundamental become effective right away. Fundamental amendments become effective within 30 days of being published on the Vita Lingua website. If we make any changes we will make them public and mark the date when the change becomes effective at the top of the website. If we make fundamental changes to these guidelines, we will alert you here, via email, or via an announcement on your homepage. We recommend that you regularly come back to these guidelines and re-read them so that you are always completely informed about our privacy policy.


18 INDIVIDUALS IN THE EEA
Over and above the aforementioned rights, you are entitled to submit a grievance with a relevant authority if you suspect a breach in our personal information handling procedures. We would be grateful if in the first instance you would contact us by email to allow us to investigate any misgivings.


19 CALIFORNIA AND NEVADA RESIDENTS (CCPA)
It is incumbent upon us to provide additional information to residents of California and Nevada regarding how their personal data is used and shared by us. If this applies to you, you may have additional rights regarding the way in which your data is used by us. We have laid out in the following section the details specific to California for your information.
Under certain state laws, the way in which we disclose your personal information could be viewed as a 'sale' of personal information. Those who reside in California or Nevada are entitled to refuse the sale of their personal information. If you are able to provide proof of residency in California or Nevada, you can contact us via email to request you opt-out of any possible future sales under California and Nevada law. You will hear from us regarding your request as soon as is feasibly possible and within no more than 30 days. If we are unable to comply with this time period due to some unforeseen reason, we will inform you of this as soon as possible.
CA Personal Information
We gather specific categories and pieces of data regarding individuals that, in California, are viewed as "CA Personal Information". These are as follows:
. Direct and indirect identifiers such as full name, personal or professional contact details, home address, telephone number, email, unique personal identifier, IP, device and online activity data, sex, demographics, username and password to our website or service;
. Commercial information such as records of products or services purchased or obtained, or purchasing or consuming histories or tendencies;
. The sources from which the data was collected from you and other third parties, as per our Privacy Policy.
Use of CA Personal Information
CA Personal Information may be used by us for business or commercial purposes. Further details can be found in our Privacy Policy.
Use of CA Personal Information Sold or Disclosed For Business Purposes
Within the preceding 12-month period, it is possible that we have “sold” (as per the CCPA) some categories of CA Personal Information or disclosed CA Personal Information for business purposes.
California Consumer Rights
Residents of California may have the following rights to their CA Personal Information (exemptions may apply):
(i) The right to access the CA Personal Information we collect, use, share, or sell;
(ii) The right to deletion of the aforementioned CA Personal Information;
(iii) The right to refuse the sale of the CA Personal Information we hold;
(iv) The right to request details of the CA Personal Information we have "sold" (as per the CCPA) or shared for commercial purposes within the preceding 12-month period.
In compliance with applicable law, it may be necessary for us to retain some CA Personal Information and some specific CA Personal Information is required to allow us to adhere fully to our Privacy Policy.
Exercising California consumer rights
Residents of California who wish to exercise any of these rights must do one of the following:
(a) submit a request via our contact form;
(b) access their account to update any necessary information and/or to submit a request;
(c) contact us as per our Privacy Policy.
Once you have submitted your request, we may ask you to provide further details, such as proof of ID, to allow us to confirm your identity and corroborate your request. We do not accept responsibility for requests that are submitted incorrectly or that do not provide sufficient detail. You will not be discriminated against in the prices or products we offer you as a result of making a request regarding your rights to your CA Personal Information. It is important to remember that you are restricted by law to a certain number of requests per year.
Do Not Sell My Personal Information
If you are resident in California, you have the right to refuse the sale (as per the CCPA) of your CA Personal Information to a third party. Please contact us as per our Privacy Policy if you would like to exercise this right. If you choose to appoint a designated agent to submit a request on your behalf, they must provide us with written confirmation of this fact, including written authorization with your signature, proof of your identity, and confirmation of their identity; or, as required under the California Probate Code, a valid, designated power of attorney. We will contact you if further proof of authority is required or to confirm the request. We will never "sell" the CA Personal Information of persons under the age of 16 without proper, authorized consent.

Last updated and effective as of: January 1, 2021