Privacy Policy – Alemanzo

This Privacy Policy provides an overview of all information regarding the processing of personal data by Alemanzo, an app owned and operated by Alemanzo GmbH a company registered under the laws of Germany, at Mühlenstr. 8a, 14167 Berlin, Germany, hereafter referred to as Alemanzo, we, our or us.

Alemanzo is strongly committed to protecting your privacy and complying with your choices. You will be in full control of all data relating to yourself. Both personal and non-personal data and information collected is safeguarded according to the highest privacy and data protection standards adopted worldwide. Specifically, we are in compliance with the EU General Data Protection Regulation, (the “Data Protection Legislation”). We strive to make you feel safe when we collect or share your data and therefore, we want to be transparent on how we collect, use, share and store the information about you and the choices available to you as data subject.

As such, this Privacy Policy is about how we handle the personal information of users of Alemanzo (the Privacy Policy). The Privacy Policy applies to the entire Alemanzo platform, which includes the mobile app (the App), the website located at (the Website), and any other services and platforms offered by Alemanzo.

We reserve the right to make changes to this Privacy Policy at any time. We will notify you when updates are made to give you an opportunity to withdraw previously given consent or to deny further use of your data. We may have to update the Privacy Policy in case of new developments, activities, online services or when applicable legislation changes.

1. What is the aim of this Privacy Policy?

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The App and Website are not intended for children, and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. Usage of personal data

We use and collect your personal data for the following purposes:

To offer you the functionalities of the App and/or Website and for the technical and functional management thereof.

We strive to make our Website easily accessible and to offer you the best possible experience and functionalities. We process technical data of everyone who visits and uses our Website in order to manage it and improve its performance. We may also need to process your personal data so that you can save your data (or preferences) to configure your device to give you a personalized experience. The functionalities of the Website are largely made available through the use of functional cookies. You can read more about our use of cookies in our Cookie Policy.

For relationship management and marketing:

Alemanzo uses the information in the contractual relationships database to send you updates you on developments within Alemanzo. We also may use your personal data for the development, execution and analysis of market research and marketing strategies.

To create an account and to use our services:

If you want to use our App and/or Website, we need to process your data to be able to set up an account for you so that you will be able to use the services we offer. This data is processed on the basis of our contract with you, which is created once you accept the applicable Terms of Service.

To provide user support:

We want to offer you the best experience possible when using our App and Website. Therefore, we are ready to handle any questions or complaints you might have. When you get in touch with us at our office, via social media, via a contact form, or in any other way, we will use your personal data in order to reply to you, answer your question, or handle your complaint.

To process your payment:

In order to use our services, you will need to enter into an subscription agreement for payment thereof. We will process your payment data in order to handle the payments, and for administrative purposes such as sending you invoices or refunds.

3. Legal bases for collecting your personal data

The legal basis we have in order to collect your personal data will depend on the type of data collected. In any case, it will be either of the following:

  • We need to perform our obligations under a contract with you
  • You have given us explicit consent
  • It is in our legitimate business interest
  • To comply with our legal obligations

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, and/or text message with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation, and you will always have the opportunity to opt-out.

4. Which personal data do we collect?

We collect the following types of personal data:

  • Identity Data: first name, last name, username or similar identifier, title.
  • Contact Data: billing address, email address and telephone number.
  • Financial Data: bank account and payment card details.
  • Transaction Data: details about payments to and from you and details of in-App purchases.
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.
  • Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback.
  • Usage Data: includes details of your use of our App or your visit to our Website, such as traffic data and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

5. How do we collect your personal data?

Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App and the Website (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register on the App, subscribe to any of our services, search for an App or service, make an in-App purchase, share data via an App's social functions, enter a competition, promotion or survey, and when you report a problem with any of Our Sites. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device. Each time you visit one of Our Sites, we will automatically collect personal data including Device and Usage Data. We collect this data using cookies and other similar technologies. Please see our Cookie Policy for further details.

Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:

  • We collect certain personal data through Our Sites as a result of our use of Google AdMob. This may include personal information, such as your name and/or email address; your device information such as its model and/or operating system; and user interactions, such as the clicks, features, and other engagement metrics. The data collected through Google AdMob is used for the following purposes:
  1. Ad Targeting: We utilize data for the purpose of personalizing ads within Our Sites to enhance user experiences.
  2. Analytics: Collected data is employed for analytical purposes, helping us improve Our Sites’ performance and content.

6. How do we use your personal data?

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

Where you have consented before the processing.

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Where we need to perform a contract we are about to enter or have entered with you.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Where we need to comply with a legal or regulatory obligation.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

7. For which purpose do we collect your personal data?
Purpose/activity Type of data Lawful basis for processing
To install the App and register you as a new service user Identity, Contact, Financial, Transaction, Device Your consent
To process in-App purchases and deliver services including managing payments and collecting money owed to us. Identity, Contact, Financial, Transaction, Device, Marketing and Communications Your consent; Performance of a contract with you; Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any services Identity, Contact, Financial, Profile, Marketing and Communications Your consent; Performance of a contract with you; Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services); Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business and this App including troubleshooting, data analysis and system testing Identity, Contact, Device Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you; To make recommendations to you about goods or services which may interest you Identity, Contact, Device, Content, Profile, Usage Consent; Necessary for our legitimate interests (to develop our products/Services and grow our business)
To measure and analyse the effectiveness of the advertising we serve you; To monitor trends so that we can improve the App Marketing and Communications Location

8. How long do we retain your personal data?

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data. See below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the Our Sites for a period of 24 months, we will treat the account as expired and your personal data may be deleted.

9. Cookies

Alemanzo uses cookies when offering its services. Please see our Cookie Policy for more information.

10. Minors

We insist on not processing any personal data of children under the age of 16, unless this is explicitly consented to by a parent or legal guardian. However, as it is hard to detect whether we are doing so, we strongly encourage you to inform us if you have reason to believe we process the personal data of a minor. We will delete this personal data instantly.

11. Which parties have access to your personal data?

Within Alemanzo, our employees, contractors, agents and directors have access to personal data, but only to the extent necessary to properly perform their individual tasks.

Alemanzo only shares personal information with third parties if it is necessary to serve the applicable purpose as set out above. When a third party processes your personal data, this is only possible according to the instructions of Alemanzo. They therefore act as our data processor. In all cases, we will ensure that third parties with access to your personal information have implemented appropriate technical and organizational measures to maintain our intended level of privacy and security. We will conclude the necessary agreement with the data processor(s), whereby we include obligations to ensure that your personal data is only processed so that the data processor can fulfil his duty to provide services to us.

Under these conditions, the following third parties will have access to your personal data:

  • Information regarding your use of the website and other information gathered through cookies is shared with web analytics, session recording, and online marketing services. Read more about the use of cookies in our Cookie Policy.
  • We may professional advisors such as insurers, accountants, consultants, and legal professionals.
  • The relevant tax authority, regulators and other authorities acting as processors or joint controllers.
  • When your activity gives us any indication to do so, we may disclose information with the relevant authorities necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to safety, or violations of the Terms of Service.
  • We may collect, process, analyse and share aggregate or de-identified information about used with third parties for marketing, advertising, research or similar purposes.
  • If we are in any negotiation with a third party which will involve the transfer of all or substantially all of our assets, we may transfer certain personal data as required.
  • Apple and/or Google have access to your payment details as they handle and process all subscription fees.
  • Providers of newsletter services.
  • IT-providers.
  • Google Cloud is used for storage of personal information.

In all other cases, your personal information will not be provided to third parties, unless required by law. Alemanzo will never sell your personal data.

12. Personalized Advertising with Google AdMob and Google AdSense

Personalized advertising, also known as interest-based advertising, involves using data to customize the ads you see based on your interests, demographics, and online behaviour. We employ personalized advertising within our app to enhance your overall experience and provide you with more relevant content and advertisements.

In addition to the information mentioned in our Privacy Policy, we also collect and process certain data for the purpose of serving personalized ads through Google AdMob and Google AdSense. The following paragraphs outline how your data is used in relation to these services.

Google AdMob: Our Sites may use Google AdMob to display ads. Google AdMob is an advertising service provided by Google Inc. Information collected by Google AdMob includes device information, such as your device's advertising identifier, IP address, and geolocation information. This information is used to personalize the ads you see and to measure the effectiveness of the ads. You can learn more about Google AdMob's data collection and usage by visiting their Privacy Policy.

Google AdSense: On Our Sites, we may use Google AdSense to display ads. Google AdSense is an advertising service provided by Google Inc. Google AdSense may use cookies and web beacons to collect non-personally identifiable information about your visit to our website, including your IP address, browser type, and the pages you viewed. This information is used to provide relevant ads and analyze ad performance. You can find more information about how Google AdSense collects and uses data in their Privacy Policy.

By using our website or mobile app, you consent to the data collection and processing practices described above. You can opt out of personalized advertising by adjusting your device settings or using Google's Ad Settings.

We will only use Google AdMob to show ads in the free version of the App.

In all other cases, your personal information will not be provided to third parties, unless required by law. Alemanzo will never sell your personal data.

You can learn more about how Google might collect, share, and use your data by visiting the following links:

13. Security

Alemanzo has taken all reasonable technical and organizational measures to secure your personal information and to protect it from unauthorized access. However, we cannot guarantee that your personal information will be 100% secure, as the security will also depend on other factors, such as your Internet provider, network, or whether you share your credentials. If you believe your personal data is not secure, please contact us immediately.

We value the protection of your privacy. We have taken strong security measures to protect your data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We further ensure that personal data is only accessible to those specific persons who are authorized based on their function. In addition, we have implemented measures to guarantee your safe visit to and use of our App. This way we prevent misuse of your data. These measures include computer security and protected files and facilities. Your connection to our Website is safe through activation of Secure Socket Layer (SSL).

All passwords used on our App are hashed and are never stored in text-form. Other personal data entered on the App is non-public, unless the user chooses to make information public, such as their username, bio, picture, known languages, translations, learning progress. Users should be aware that any of this contains personal information, such as a username containing your actual name, this information will be publicly available.

Alemanzo has taken the necessary technical and organizational measures to prevent, identify, report and deal with data protection breaches. However, in the event that a data breach occurs, Alemanzo will, without undue delay and where possible, not later than 72 hours after being notified, report the breach of personal data to the German Data Protection Authority.

14. Your rights

As the owner of the personal data, you have the following rights:

  • Right of access: You have the right to receive a copy of the personal information we hold about you to verify that we are lawfully processing the data.
  • Right to correction: You may request any incomplete or incorrect information that we may have about you to be corrected or supplemented.
  • Right to be "forgotten": If there is no good reason to keep your personal information, we will stop processing. You also have the right to ask us to delete your personal information.
  • Right to limit the processing of your personal data: You can submit a request not to process your personal data, either temporarily or permanently.
  • Right to portability: You can submit a request to transfer your personal data to a person or institution designated by you.
  • Right to object to processing: Under certain circumstances you can object to the processing of personal data altogether.
  • Right to withdraw consent: You also have the right to withdraw your previously granted permission to process your personal data or to object to the processing of your personal data by Alemanzo.

Every request is subject to applicable law, which means that we may have to store the personal information. We also want to remind you that you have the right to make a complaint to your national Data Protection Authority if you think we are not compliant with the applicable data protection legislation.

If you want to exercise any of your rights as set out above, you can do so here at any time:


15. How can you access your personal data?

If you want to know what personal data we have about you, you can ask us for details and a copy (if we hold personal data). This is known as a “subject access request”. All subject access requests should be made in writing and sent by email.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

16. External Links

Our App may display links to other websites. Unless these other websites are affiliated with Alemanzo, we are not responsible for the privacy policies that these other websites use, nor for its content and security. We advise you to inform yourself by reading the privacy policies on these websites.

17. Questions or comments?

If you still have questions after reading this Privacy Policy or if you have suggestions or comments about its content, you can always contact us via:

Please let us know if, for any reason, you believe we have not adhered to the principles in this Privacy Policy. We will do our best to promptly make corrections.