1 PRIVACY POLICY FOR VITA LINGUA
We handle personal data in accordance with the provisions of the German Data Protection Act (which includes the EU General Data Protection Regulation – GDPR). Even in our global activities, we adhere to the German Data Protection Act unless local equivalent laws are stronger.
We operate the website https://www.vitalingua.com and collect certain data from our visitors and customers as necessary.
With this privacy policy, Vita Lingua aims to inform you about how your personal data is processed and how some of this data is accessible to other users. In the following privacy policy, you will learn what we do with your data, so-called personal data, and why we do it. We will also inform you about how we protect your data, when the data will be deleted, and what rights you have under data protection laws.

2 SCOPE
These privacy terms apply to all uses of Vita Lingua’s online offerings. The translation of this document into English, Spanish, French, and Chinese is provided for information purposes only. In case of any discrepancies, the German version of this document is the only legally binding version.

3 CONSENT STATEMENT
By using the Vita Lingua online offerings, you consent to the data protection provisions outlined below. Your consent will be logged by us. You can withdraw your consent at any time with future effect to Vita Lingua via email (email address to be provided). Withdrawing your consent means you will no longer be able to use the Vita Lingua online offerings or only to a limited extent.
In addition to the data processing on our website, this privacy policy explains the data processing in the services we offer, which our customers can register for. This privacy policy informs you about:
– What data Vita Lingua collects and what we do with it.
– What technologies we use for providing and personalizing our services.
– What data protection rights you have and how you can exercise them.

4 CONTACT
The trust of our users is important to us. Therefore, Vita Lingua is always available to answer questions regarding the processing of personal data. If you have any questions that this privacy policy does not answer or if you need more detailed information on any point, please contact us at the following contact details.
Responsible for this website:
Vita Lingua, José Delgado
Schmarjestr. 42 22767 Hamburg
email: mail (@) vitalingua.com
You can also reach our data protection officer or another data protection contact through these contact details. Please contact us at any time if you have specific questions about your data, its deletion, or your rights. In this context, we process data exclusively for the purpose of communication with you.
The legal basis for data processing is contract fulfillment according to Art. 6 (1) sentence 1 lit. b GDPR.

5 CONTACT
Personal data is collected by us when you provide it voluntarily, for example, when you contact us. Providing this information is voluntary and is initiated by you. If this involves communication channels (email address, phone number), we will use these channels to contact you according to your request.
Legal Basis for Data Processing
The legal basis for processing the data you provide during contact is Art. 6 (1) sentence 1 lit. 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 receive in the course of contact as soon as it is no longer needed to achieve the purpose for which it was collected, i.e., when your request is fully processed and no further communication with you is required or desired.
Right to Object and Removal
If the user contacts us by email, they can object to the storage of their personal data at any time.

6 WHAT ARE YOUR RIGHTS?
You can contact us at any time if you have questions about your rights or wish to exercise the following rights:
– Right of withdrawal according to Art. 7 (3) GDPR
– Right to information according to Art. 15 GDPR (You can contact us if you want to know what data we have stored about you)
– Correction according to Art. 16 GDPR (You can contact us if your email address has changed and we need to replace the old email address)
– Deletion according to Art. 17 GDPR (You can contact us if we need to delete certain data we have stored about you)
– Restriction of processing according to Art. 18 GDPR (You can contact us if you want us to use your email address only for sending essential emails)
– Data portability according to Art. 20 GDPR (You can contact us if you want to receive your stored data in a compressed format)
– Objection according to Art. 21 GDPR (You can contact us if you disagree with any of the advertising or analytics methods mentioned here)
– Right to complain to the competent supervisory authority according to Art. 77 (1) GDPR (You can also directly address complaints to the data protection supervisory authority in your federal state)

Competent Supervisory Authority in Hamburg
The Hamburg Commissioner for Data Protection and Freedom of Information
Ludwig-Erhard-Str. 22
20459 Hamburg

Exercising Your Rights Regarding the Processing of Your Personal Data
To exercise your rights, you need to send us a request in writing, by mail, or by email. You can also contact us by phone if you wish to speak with someone personally. We will need you to provide:
. proof of your identity
. proof of your residential address
. all information we need to locate the information you requested (e.g., details about Vita Lingua or employees you have contacted and the time period)
We will only begin searching for your information after we have confirmed your identity.

7 DELETION OF DATA AND STORAGE DURATION
Unless otherwise specified, we delete your data as soon as it is no longer needed. Data will also be blocked or deleted when a legally required retention period expires unless further retention of the data is necessary for contract conclusion or contract fulfillment. Certain data may need to be kept longer for legal reasons. You can, of course, request information about the stored data at any time.

8 SERVER LOG FILES
When you visit our website, we do not collect personal data, except for the data transmitted by your browser to enable the visit to the website. The provider of the site – Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (Germany) – automatically collects and stores information in so-called server log files, which your browser transmits to us automatically. These include:
– File names of the accessed pages and files
– Date and time of access – transmitted data volume
– 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 privacy protection measure, we delete or anonymize the IP address after specified periods. Thus, the other potentially associated data can no longer be traced back to you and is only used for anonymous, statistical purposes to optimize our website. The purpose of temporary storage of data is both the technical necessity for establishing a connection and the correct and error-free display of our website. The IP address and the previously mentioned technical data are necessary to display the website, avoid display problems for visitors, and fix errors.
The legal basis is the so-called legitimate interest, which has been checked in the context of the aforementioned protection measures and in accordance with the European data protection requirements according to Art. 6 (1) sentence 1 lit. f GDPR.

9 GOOGLE FONTS
For the visual enhancement of the typography, Google Fonts provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA are used. When you access a page, your browser loads the required web fonts into its browser cache to correctly display texts and fonts. For this purpose, the browser must establish a connection to Google’s servers. This enables Google to know that our website has been accessed via your IP address. If your browser does not support web fonts, a standard font from your computer will be used. More information about Google Web Fonts can be found here and in Google’s privacy policy.
The use of Google Web Fonts is done in the interest of a uniform and appealing presentation of our online services. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

11 GOOGLE TAG MANAGER
This website uses Google Tag Manager. The Tag Manager does not collect any personal data. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If deactivation is performed at the domain or cookie level, it remains valid for all tracking tags implemented with Google Tag Manager. Google’s privacy notices for this tool can be found here.

12 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 websites. The information collected by cookies about your use of this website is usually transmitted to and stored on a Google server in the USA.
We use the User-ID feature. With the User ID, we can assign a unique, persistent ID to one or more sessions (and the activities within those sessions) and analyze user behavior across devices.
We use Google Signals. This collects additional information about users who have activated personalized ads (interests and demographic data) and ads can be delivered to these users in cross-device remarketing campaigns.
We use the ‘anonymizeIP’ function (so-called IP masking): Due to the activation of IP anonymization on this website, your IP address will be truncated by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. The IP address transmitted by your browser within Google Analytics will not be merged with other Google data.

During your website visit, the following data is collected among other things:
– The pages you visit, your “click path”
– Achievement of “website goals” (conversions, e.g., newsletter sign-ups, downloads, purchases)
– Your user behavior (e.g., clicks, dwell time, bounce rates)
– Your approximate location (region) – Your IP address (in truncated form)
– Technical information about your browser and devices you use (e.g., language setting, screen resolution) – Your Internet service provider
– The referrer URL (which website/advertising medium you came from to this website)

Purposes of Processing
Google will use this information on behalf of the operator of this website to evaluate your (pseudonymous [not with user-id]) use of the website and to compile reports on website activities. The reports provided by Google Analytics help us analyze the performance of our website and the success of our marketing campaigns.

Recipients
The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland as a processor. We have entered into a data processing agreement with Google for this purpose. Google LLC based in California, USA, and possibly US authorities may access the data stored at Google.

Transfer to Third Countries
A transfer of data to the USA cannot be excluded.

Retention Period
The data we send and link to cookies are automatically deleted after 14 months. The deletion of data whose retention period has been reached occurs automatically once a month.
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by:
a. not giving your consent to set the cookie, or
b. downloading and installing the browser add-on for deactivating Google Analytics.

You can also prevent the storage of cookies by adjusting the settings of your browser software. However, if you configure your browser to reject all cookies, it may lead to restrictions in functionality on this and other websites.
The legal basis and revocation option for this data processing is your consent, Art. 6 para. 1 sentence 1 lit. a GDPR. You can withdraw your consent at any time with future effect by accessing the cookie settings and changing your selection there. More information on Google Analytics terms of use and Google’s privacy policy can be found here and here.
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13 WHEN WILL DATA BE DISCLOSED?
Disclosure of the data we collect generally only occurs if:
– You have given your explicit consent according to Art. 6 para. 1 sentence 1 lit. a GDPR,
– Disclosure is necessary according to Art. 6 para. 1 sentence 1 lit. f GDPR for the establishment, exercise, or defense of legal claims, and there is no reason to believe that you have a predominant legitimate interest in not having your data disclosed,
– We are legally obliged to disclose the data according to Art. 6 para. 1 sentence 1 lit. c GDPR, or
– It is legally permissible and necessary according to Art. 6 para. 1 sentence 1 lit. b GDPR for the execution of contractual relationships with you or for carrying out pre-contractual measures that are requested by you.
Furthermore, disclosure may occur in connection with governmental inquiries, court orders, and legal proceedings if it is necessary for the enforcement or defense of legal claims.

14 LINKS
Vita Lingua may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage our users to read the privacy settings of any website that collects personal information individually.

15 AGE RESTRICTION
The Vita Lingua service is not intended for children under 16 years old and is not offered to children whose age makes the processing of their personal data illegal or requires parental consent under GDPR or other local laws.
Additionally, please note that persons under 18 years old always need permission from parents or guardians to use the service. If you are under 16 years old, do not provide us with personal data. If you are a parent of a child under the age limit and find that your child has provided personal data to Vita Lingua, please contact us via the ‘Contact’ form.

16 DATA SECURITY
All personal data is handled with the utmost care by Vita Lingua. Necessary measures are taken to ensure the security of this data. Vita Lingua implements appropriate security measures to protect its users’ data. If you provide confidential data (e.g., passwords), we encrypt it using secure SSL technology. Vita Lingua employs security precautions to protect against loss, alteration, or misuse of your data. This includes using industry-standard firewalls and other security systems. At the same time, users should be aware that due to constantly emerging viruses and other means of attacking secured data systems of internet services, a 100% protection from attacks cannot be guaranteed. Vita Lingua will pursue any discovered attacks by hackers or similar through civil and criminal means and inform users of any compromise of their data.

17 NOTICES AND REVISIONS
We reserve the right to change our privacy policies. Non-material changes take effect immediately. Material changes take effect within 30 days after their publication on this page. If we make changes, we will publish them and indicate the date they come into effect at the top of the page. If we make significant changes to these policies, we will notify you here, via email, or by notice on your homepage. We advise you to regularly review these policies to stay fully informed about our privacy practices.

Date of the Privacy Policy: January 2021
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