Privacy Policy
This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have regarding your data. We are committed to handling your data responsibly and in accordance with applicable law.
1. Who We Are
The data controller for personal data processed through german-help.com and ai.german-help.com is Alexander Groll, a self-employed individual (Persona Física) registered in Paraguay (RUC: 8928409-7). References to “we”, “us”, or “Operator” in this Policy refer to Alexander Groll.
2. What Data We Collect and Why
| Category | Data Collected | Purpose | Legal Basis |
|---|---|---|---|
| Account / Registration | Name, email address | Account creation, service access, communication | Contract performance |
| Payment | Transaction amount, date, currency, payment status | Processing purchases, issuing receipts, accounting | Contract performance; legal obligation |
| AI Tutor Session Metadata | Session start/end time, session duration, access pass status | Service delivery, outage compensation, usage verification | Contract performance |
| Booking Data | Name, email, scheduled date and time of lessons | Scheduling and confirming lessons | Contract performance |
| Technical / Log Data | IP address, browser type, access timestamps | Security, fraud prevention, technical troubleshooting | Legitimate interest |
| Tutor Profile Data | Name, photo, video, description text, contact preferences | Publishing tutor listings on the Platform | Consent (tutor submits voluntarily) |
| Communications | Email correspondence | Responding to inquiries, support | Legitimate interest; contract performance |
| Tutor Application — Public | Display name, profile photo, listing title, about text, intro video URL, price, spoken languages | Publishing the tutor’s profile on the Platform for learners to view | Consent (voluntary submission) |
| Tutor Application — Confidential | Full legal name, email address, city and country of residence, chosen password (stored hashed) | Identity verification, account creation, preventing fraud; never published | Legitimate interest; contract performance |
| Newsletter | Email address, opt-in date, opt-in source | Sending occasional updates, offers and announcements to users who have explicitly subscribed | Consent (opt-in checkbox) |
| Contact & Trial Lesson Forms | Name, email address, message text | Forwarding the enquiry to the selected tutor by email so they can respond directly. The data is not stored in the platform’s database; it is transmitted once and then held only in the email accounts of the sender and the tutor. | Legitimate interest (connecting prospective students with tutors) |
| Affiliate Registration | Name, email address, optional description of promotional channel | Setting up an affiliate account, sending personal referral link, managing the affiliate programme | Contract performance (affiliate agreement) |
| Affiliate Referral & Commission Data | Referral code (cookie gh_ref_code, 30 days), purchase amount, commission amount, date |
Attributing purchases to the referring affiliate, calculating and recording commissions | Consent (cookie banner — “Accept all” required); contract performance for recorded commissions |
We do not collect payment card details directly. Card processing is handled entirely by our payment provider (Pagopar), which operates under its own privacy policy.
We do not permanently record or store the spoken or written content of AI tutor sessions beyond what is technically necessary for the session to function in real time.
3. Third-Party Services
To provide our services, we use the following third-party providers. Each processes certain data under its own privacy policy:
| Provider | Purpose | Data Shared |
|---|---|---|
| Pagopar / ITTI USA, LLC | Payment processing | Name, email, transaction data |
| Groq, Inc. | Speech-to-text transcription (AI tutor sessions) | Audio input during active sessions |
| Cartesia AI | Text-to-speech synthesis (AI tutor voices) | Text content during active sessions |
| Cal.com | Lesson booking and scheduling (optional) | Name, email, booking details |
| Hosting / VPS Provider | Server infrastructure | Technical data stored on server |
We select providers that maintain appropriate data security standards. We do not sell your personal data to third parties.
4. How Long We Keep Your Data
| Data Type | Retention Period |
|---|---|
| Account data | For the duration of the account, plus 12 months after account closure |
| Payment records | As required by Paraguayan tax and accounting law (typically 5 years) |
| Session metadata | 12 months from the session date |
| Booking data | 12 months after the lesson date |
| Tutor profile data | Until the listing is removed or deletion is requested |
| Technical log data | 90 days |
| Email correspondence | 24 months from last contact |
5. Cookies and Tracking
When you first visit the Platform, a cookie banner asks for your preferences. You can choose between Essential only and Accept all. If you close or ignore the banner without choosing, only essential cookies remain active.
- Essential cookies: Required for the Platform to function (e.g., session authentication, access pass verification). Always active; cannot be disabled without breaking core functionality.
- Affiliate tracking cookie (
gh_ref_code): If you arrived via a partner or affiliate link and select Accept all, we store an anonymous referral code in your browser for 30 days. This allows us to attribute a subsequent purchase to the referring partner. No personal data is stored in this cookie — only an opaque code. If you choose Essential only or do not interact with the cookie banner, this cookie is not set and affiliate attribution will not function. You can delete it at any time via your browser settings. - Analytics cookies: The Platform does not currently use analytics or tracking cookies. If this changes in the future, this Policy will be updated before activation.
We do not use advertising or tracking cookies for third-party marketing purposes.
6. Your Rights
You have the following rights regarding your personal data:
- Access: You may request a copy of the personal data we hold about you.
- Rectification: You may request correction of inaccurate or incomplete data.
- Erasure: You may request deletion of your personal data, subject to legal retention obligations.
- Restriction: You may request that we limit processing of your data in certain circumstances.
- Objection: You may object to processing based on legitimate interest.
- Portability: You may request your data in a structured, machine-readable format where technically feasible.
- Withdrawal of consent: Where processing is based on your consent (e.g., affiliate tracking cookies), you may withdraw consent at any time by deleting the relevant cookie in your browser settings. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, contact us at: info@german-help.com
We will respond to requests within thirty (30) days. There is no charge for reasonable requests.
7. Data Security
We implement reasonable technical and organisational security measures to protect your personal data against unauthorised access, loss, or alteration. These include encrypted connections (HTTPS), access controls, and regular security reviews. However, no internet transmission is fully secure, and we cannot guarantee absolute security.
8. International Data Transfers
Our server infrastructure is located in the United States (Secaucus, New Jersey), hosted by Interserver, Inc. Some third-party service providers (e.g., Groq, Cartesia) process data in the United States. We rely on these providers’ security certifications and standard contractual commitments for international data transfers.
9. Children’s Privacy
The Platform is not directed at children under 13 years of age. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.
10. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be published on this page with the updated date. We will notify you of material changes by email or by a notice on the Platform. We encourage you to review this page periodically.
11. Contact and Complaints
For any privacy-related questions or to exercise your rights, contact:
Alexander Groll
Cam. al Puerto de Hohenau, 071406 Hohenau, Paraguay
info@german-help.com
If you are not satisfied with our response, you may lodge a complaint with the competent data protection authority in your country of residence.