Data Protection Policy for Language Buddy

Effective Date: 7 July 2025

1. Basics

This data protection policy applies to all persons who use the services of Benjamin Meixner, Fritz-Schmerold-Gasse 36, 2331 Voesendorf, Austria (hereinafter "Language Buddy"). We hereby inform you about the type, scope, and purpose of the collection and use of your personal data by our service. We respect your privacy and strive to strictly comply with the legal provisions for the processing of your personal data (EU Regulation No. 679/2016 (GDPR), Austrian Data Protection Act (DSG)). All your personal data will be processed on this legal basis.

The controller responsible for data processing is:

Benjamin Meixner

Fritz-Schmerold-Gasse 36

2331 Voesendorf, Austria

Email: benjamin@meixner.org

2. Information in Accordance with Art. 13 and 14 GDPR

For our service to function, we require and process the following personal data:

• Your master data: Last name, first name.
• Contact data: Your phone number, which is essential for using the WhatsApp-based service.
• Payment data: We do not store your credit card or bank details ourselves. Payments are processed exclusively via our partner, Stripe. Stripe processes data related to the payment method and in connection with payments.
• Chat data: The content of your conversations with the Language Buddy chatbot via WhatsApp will be saved to provide and improve the service.

This data is necessary for our services. This includes providing the chatbot functionality, managing your user account, processing payments, and personalizing the learning experience.

We do not use profiling or automated decision-making that produces legal effects concerning you or similarly significantly affects you. Your chat data is used to improve the general service for all users, but not to make automated decisions about you specifically.

The legal bases for these data processing activities are:

• The fulfillment of our contractual and pre-contractual obligations to you in accordance with Art.6(1)(b) GDPR (i.e., providing the Language Buddy service you signed up for).
• Your explicit consent obtained from you at the beginning of our interaction ("ACCEPT") in accordance with Art.6(1)(a) GDPR.
• Our statutory, contractual, or other legal obligations in accordance with Art.6(1)(c) GDPR (e.g., documentation obligations under tax and accounting law).
• Our legitimate interests in accordance with Art.6(1)(f) GDPR (e.g., improving our customer service and the AI model, or protecting our own legal interests).

The duration of storage is determined by the duration of our business relationship, the consent you have given, and the statutory retention requirements and legal obligations that apply to us (e.g., financial data must be retained for 7 years under Austrian law). We retain chat data to ensure continuity of service and for service improvement, until you request its deletion.

3. Transfer to Third Parties / Obligations of Processors

Your personal data may be transmitted by us to processors as well as to third parties who must be involved in providing the service you request. All of our partners have committed to complying with applicable data protection standards.

• WhatsApp (Meta Platforms, Inc.): The entire service is provided via the WhatsApp messaging platform. By using Language Buddy, your phone number and chat data are necessarily processed by WhatsApp. WhatsApp is operated by Meta Platforms, Inc., a US-based company. Please be aware that this involves the transfer of your data to the USA.
• Stripe, Inc.: For payment processing, we use the services of Stripe. When you make a payment, your payment data is sent directly to Stripe. Stripe is a US-based company, and this also involves a transfer of your data to the USA. You can find Stripe's privacy policy here: https://stripe.com/en-at/legal/privacy-center.

Important Note on Data Transfers to the USA:

The European Court of Justice has ruled that the level of data protection in the USA is not equivalent to that within the EU. In particular, there is a risk that your data may be accessed by US authorities for control and monitoring purposes, possibly without any legal remedy.

By replying 'ACCEPT' and using our service, you explicitly agree to the transfer of your personal data (phone number, chat data, payment information) to these necessary service providers in the USA for the purpose of fulfilling our contract with you, in accordance with Art.49(1)(a) and Art.49(1)(b) GDPR. If you do not agree to these terms, we will unfortunately not be able to provide the service to you.

4. Your Rights as a Data Subject

You can request information about your personal data stored by us at any time, free of charge. As a data subject, you also have the following rights:

• Right to Rectification: You can correct any inaccurate data.
• Right to Erasure ("Right to be forgotten"): You can request the deletion of your data.
• Right to Restriction of Processing: You can limit how we use your data.
• Right to Data Portability: You can request that we provide your data to you in a machine-readable format.
• Right to Object: You have the right to object to our processing of your data. Since we process data for direct marketing (e.g., service updates), you can object to this at any time.

You may revoke your consent for data processing at any time. A revocation means that we will no longer process your data for the purposes stated from that point on. The legality of the processing carried out up to the time of revocation is not affected by the revocation.

To exercise these rights or for further information, please contact us at any time:

Email: benjamin@meixner.org

Post: Benjamin Meixner, Fritz-Schmerold-Gasse 36, 2331 Voesendorf, Austria

If you believe that the processing of your data violates data protection law, you have the right to lodge a complaint with the responsible supervisory authority. In Austria, this is the:

Austrian Data Protection Authority (Datenschutzbehörde - DSB)

Barichgasse 40-42

1030 Vienna, Austria

Website: www.dsb.gv.at 

5. Miscellaneous

We have implemented organizational and technical security measures, which we continuously evaluate and adapt as necessary, to protect your personal data that we store and process.

We reserve the right to amend this data protection policy at any time to adapt it to new developments. The new version will be effective from the time it is made available on our website. The current version of the data protection policy is available at any time on the website at: https://languagebuddy-test.maixnor.com/static/privacy.html.