PRIVACY POLICY

Last revised on August 7, 2023.

This Privacy Policy for Babbel GmbH (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s websites (including the website located at www.jointoucan.com), software applications, services, tools, features and other online services, including the Toucan extension for web browsers, we provide (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material, we will use reasonable efforts to attempt to provide notice to you and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on the Services, or by other means, consistent with applicable law. However, it is your sole responsibility to review the Privacy Policy from time to time to view any such changes. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy. IF YOU DO NOT AGREE TO ANY UPDATES TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR CONTINUE TO USE THE SERVICES.

2. COMPANY'S COLLECTION AND USE OF INFORMATION

In order to provide you with particular services, we may ask you to provide us with certain details or information about you. Information that you submit through our Services may include:

  • Basic contact details, including name and email. We collect basic contact details to communicate with you and provide you with products, services and support, including to register and service your account with us.
  • Account information, including username and password. We collect account information to maintain and secure your account with us. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
  • Any other information you choose to include in communications with us, for example, when sending a message through the Contact Us web form.

Some features of the Services may require you to enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs, and other geolocation tracking technologies (“Tracking Technologies”). Usage Data may include:

  • IP Address
  • Log data
  • Device type, such as phone, computer or tablet
  • Browser type
  • Date and time stamps
  • Operating system
  • Clickstream data
  • Ad impressions
  • Other information regarding your interaction with the Services

We use the information we collect automatically to tailor features and content to you, to market to you, to provide you with offers or promotions, and to run analytics and better understand user interaction with the Services.

When you link, connect, or login to our Services with a third party service (e.g., Google or Facebook), you direct the service to send us information such as your registration and profile information as controlled by that service or as authorized by you via your privacy settings in that service.

In addition to the foregoing, we may use all of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, the rights of our users, or others.

3. HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties. Such circumstances may include:

  • With vendors or other service providers, such as
    • Payment processors
    • IT service management vendors
    • Data analytics vendors
    • Cloud database services vendors
    • Email marketing services vendors
    • Security vendors
  • With our affiliates or otherwise within our corporate group
  • To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries
  • In connection with an asset sale, merger, bankruptcy, or other business transaction
  • To enforce any applicable terms of service
  • To ensure the safety and security of the Company and/or its users
  • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations
  • With professional advisors, such as auditors, law firms, or accounting firms

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals:

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies:

You may control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Services without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Internet Explorer menu bar, select: Tools -> Internet Options -> Browsing History -> Delete to view manual and automatic options.

To opt out of tracking by Google Analytics, click here.

We may also use Flash cookies (also known as “persistent identification elements” or “local shared objects”) on certain pages. Because Flash cookies cannot be controlled through your browser settings, you may click here to adjust your preferences. You can also identify Flash cookies running on your computer by visiting the Flash Player folder. Flash cookies, or LSO files, are typically stored with a “.SOL” extension. Please note that if you block cookies, some functions otherwise available on the Services may be unavailable, and we may not be able to present you with personally-tailored content.

While we may use a variety of companies to serve advertisements on the website, you may wish to visit http://www.networkadvertising.org/choices, which provides information about Network Advertising Initiative (“NAI”) members, and your choices regarding how your information is used by these companies, including the opt-out procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit the opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt out may not, or may no longer, be effective. You may also be able to opt out of receiving third party behavioral ads by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices. Similar limitations may apply to the DAA opt-out process. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

5. HOW USERS CAN SHARE INFORMATION

The Services also host certain programs (ex. the Company’s “Own the Word” Program) and platforms which users may elect to join and/or participate in. The purpose of these features is to create a sense of community among the users and to allow users to be involved how certain portions of the Services are displayed to other users. Through your participation, you may submit, for example, a name, photo or website URL (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit UGC to any public area of the Services, your UGC will be considered “public” and will be accessible by anyone, including the Company.

Please note that we do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of UGC or what others do with information you share with them on such platforms. We are not responsible for the accuracy, use or misuse of any UGC that you disclose or receive from third parties through the forums or email lists.

6. SOCIAL FEATURES

Certain features of the Services permit you to initiate interactions between the Services and third party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to click and access the Company’s pages on certain third party platforms, such as Facebook and Twitter, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third party services, information you post or otherwise make accessible may be publicly displayed by the third party service you are using. Both the Company and the third party may have access to information about you and your use of both the Services and the third party service. For more information on third party websites and platforms, see Section 7.

7. THIRD PARTY WEBSITES AND LINKS

Our Services may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Services. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

8. CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

9. DATA SECURITY

Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you send us through any means is transmitted at your own risk.

10. THIRD COUNTRY TRANSFERS

Sometimes we may need to transfer information to countries in which applicable laws may not offer the same level of data protection as the laws of your home country.

Individuals in the EEA: When we transfer information from individuals in the EEA to countries that have not received an adequacy finding under Article 45 of the GDPR, we rely on the safeguards set forth in Article 46 of the GDPR or derogations for specific situations set forth in Article 49 of the GDPR in order to transfer your information across international borders.

11. BASES FOR PROCESSING

The legal bases for our processing activities include:

  • Toucan exercising its rights and performing its obligations in connection with entering into or performing under any contract it makes with you (Article 6(1)(b) General Data Protection Regulation);
  • Compliance with our legal obligations (Article 6(1)(c) General Data Protection Regulation);
  • Legitimate interests that are not overridden by your interests or your fundamental rights and freedoms (Article 6(1)(f) General Data Protection Regulation).

12. YOUR CHOICES AND RIGHTS

To the extent required by law, we provide you with (i) reasonable access to your personal information collected through our Services, and (ii) the ability to review, correct, export, or delete your information, restrict its processing, or object to its processing. You may exercise the foregoing rights by contacting us using any of the mechanisms detailed in the “Contact Us” section.

Individuals in the UK, EEA and Switzerland: In addition to the foregoing rights, you have the right to lodge a complaint with a supervisory authority if you believe we have processed your information in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern by emailing us at toucan@babbel.com.

13. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at toucan@babbel.com or contact us at Babbel GmbH, Andreasstraße 72, 10243 Berlin, Germany.