evelin.

Privacy Policy

Controller

AdPageGurus GmbH, Vitalis Str. 387, 50933 Cologne, Germany · E-mail: [email protected]

What data we process

  • Account data: e-mail address, name (optional), password (stored encrypted).
  • Quiz answers: your onboarding answers (goals, starting point) used to personalize your learning path.
  • Learning data: exercise answers, progress, lesson feedback, completed missions.
  • Journal entries: free-text reflections you write yourself. Depending on their content and the product, they may contain special categories of personal data (e.g. health data, Art. 9 GDPR).
  • Payment data: processed exclusively by the payment provider that acts as merchant of record for your purchase (Paddle.com Market Ltd. or Dodo Payments LLC; the payment window and your receipt show which one); we never store card details. To fulfil the contract and to diagnose payment problems we store from the payment provider the transaction status, the chosen payment method (for example card or PayPal, never the card number), error codes, amount, currency and the country of the billing address, and from the payment window technical events (opened, method chosen, error, closed) with device type and browser family. The legal basis is Art. 6(1)(b) GDPR; no consent is required for this.
  • Usage/access data: technically required server logs.

AI processing of your input

How to Improve Your Communication Skills is an adaptive learning product. Your personal lessons, missions, practice and tools are generated by an AI model. For this, your quiz answers, learning progress, lesson feedback, mission notes and your input in the tools are transmitted to the OpenAI API (OpenAI, L.L.C., USA).

  • The legal basis is our contract with you (Art. 6(1)(b) GDPR): the personalized course is the service you sign up for, and it cannot be created without this processing.
  • OpenAI processes the data as our processor (Art. 28 GDPR) and, under its API terms, must not use it to train models.
  • Transfers to the USA rely on appropriate safeguards (EU-US Data Privacy Framework or EU Standard Contractual Clauses, Art. 44 et seq. GDPR).
  • Content is generated automatically; no automated decision with legal effect on you takes place (Art. 22 GDPR).

Journal and chat with Evelin (only with your consent)

Your journal, the chat with Evelin and the question chat inside lessons accept free text. What you write there can contain personal details, including about how you feel or your health (special categories of personal data, Art. 9 GDPR). So that Evelin can read and answer these texts, they are also transmitted to the OpenAI API.

  • The legal basis is your explicit consent (Art. 9(2)(a) GDPR), which you give separately inside the product the first time you open the journal or the chat. Without it, no text is stored or transmitted there.
  • You can withdraw this consent at any time in Settings. After that, no new entries or messages are processed; your course, lessons and missions continue unchanged. Entries you already wrote stay visible to you until you delete your account.
  • We record when consent was given or withdrawn and which text version you saw (proof under Art. 7(1) GDPR).

Emails after you create an account

When you create an account in the quiz (email step), we send you a welcome email with your login link and, if you have not started a plan, a reminder and up to six short emails over 14 days about your saved plan (Art. 6 (1) (b) and (f) GDPR: performing the contract and our legitimate interest in reminding you of the plan you created). Every email has a one-click unsubscribe link; after that we only send emails that are necessary for your account. Members receive course emails (reminders, weekly recap) which they can switch off in their settings.

Retention

We keep account and learning data for as long as your account exists. Technical data such as IP address, browser identifier and advertising identifiers is deleted or anonymized after 90 days; anonymous usage statistics are kept for up to 13 months. You can request deletion of your account at any time ([email protected]).

Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection (Art. 15–21 GDPR), and the right to lodge a complaint with a supervisory authority.

Ad measurement with Meta (only with your consent)

If you consent in the cookie banner, we use the Meta Pixel and the Meta Conversions API (Meta Platforms Ireland Ltd., Ireland) to measure the effectiveness of our advertising and to deliver more relevant ads. Events such as page views, quiz usage, registration and purchases are transmitted to Meta — server-side together with your email address in hashed form (SHA-256), IP address, browser identifier and the Meta cookies (_fbp/_fbc). The legal basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via "Change cookie settings" (Cookie Policy); transfers to the USA rely on the EU-US Data Privacy Framework. Without consent, no data is transmitted to Meta.

Usage analysis with Microsoft Clarity (only with your consent)

If you consent in the cookie banner, we use Microsoft Clarity (Microsoft Ireland Operations Ltd., Ireland) to understand how our pages are used and to improve them. Clarity captures interaction data such as mouse movements, clicks and scrolling, pages visited, and device and browser information, and creates session recordings and heatmaps from it. Text entered into form fields is masked. The legal basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via "Change cookie settings" (Cookie Policy). Possible transfers to the USA (Microsoft Corporation) rely on the EU-US Data Privacy Framework. Microsoft stores session recordings for up to 30 days and aggregated heatmap data for up to 13 months. Without consent, Clarity is not loaded.

Web analytics with Google Analytics (only with your consent)

If you consent in the cookie banner, we use Google Analytics 4 (Google Ireland Limited, Ireland) to understand how visitors use our pages and features, for example which quiz steps are completed, which tools are used and which purchases are made. Google sets the cookies _ga and _ga_… (stored for up to 2 years) and receives usage data such as pages visited, triggered events, device and browser information and a truncated IP address. We also send purchases, renewals and refunds server-side (Measurement Protocol) with a pseudonymous identifier of your account; Google Analytics never receives your name or email address. Content from your journal or chat is never sent, only the fact that a feature was used. The legal basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via "Change cookie settings" (Cookie Policy). Possible transfers to the USA (Google LLC) rely on the EU-US Data Privacy Framework. Google keeps event data for up to 14 months. Until you consent, the Google tag runs in consent mode without cookies: it only sends the consent status and the page view without a user identifier to Google, and click identifiers are removed (Art. 6(1)(f) GDPR, our legitimate interest in reach measurement without personal reference). Cookies, user identifiers and the hashed email address described below are only added after you accept.

Ad measurement with Google Ads (only with your consent)

If you consent in the cookie banner, we use Google Ads (Google Ireland Limited, Ireland) to measure whether a click on one of our ads led to a registration, an email entry in the quiz or a purchase. Google sets the cookies _gcl_au and _gcl_aw (stored for 90 days). We store click identifiers from the ad URL (gclid, gbraid, wbraid) with your quiz session and your account so that conversions can later be attributed to the ad. On registration, email entry and purchase, your browser sends your email address to Google in hashed form (SHA-256, so-called enhanced conversions) so that Google can match the conversion to the ad click; on purchase also the amount, currency and transaction number, never payment details. The legal basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via "Change cookie settings" (Cookie Policy). Possible transfers to the USA (Google LLC) rely on the EU-US Data Privacy Framework. Without consent, no cookies are set and no email address is sent; the cookieless consent mode described above applies.

Recipients

  • OpenAI, L.L.C. (USA): AI generation of your course (contract) and journal and chat (consent), as our processor
  • Paddle.com Market Ltd. (Judd House, 18-29 Mora Street, London EC1V 8BT, United Kingdom): payment processing as merchant of record in its own responsibility (privacy policy: paddle.com/legal/privacy). Transfers to the United Kingdom rely on the adequacy decision of the EU Commission.
  • Dodo Payments LLC (USA): payment processing as merchant of record in its own responsibility for selected countries (for example GCash and cards in the Philippines; privacy policy: dodopayments.com/privacy). Dodo Payments receives the data needed for your purchase (e-mail, name, billing country, payment method, amount). The transfer to the USA is necessary to conclude and perform your purchase contract with Dodo Payments (Art. 49(1)(b) GDPR). Which provider handles your purchase depends on the country of your billing address and is shown in the payment window and on your receipt.
  • Meta Platforms Ireland Ltd.: ad measurement (only with consent, see above)
  • Microsoft Ireland Operations Ltd.: usage analysis with Clarity (only with consent, see above)
  • Google Ireland Limited: web analytics with Google Analytics and ad measurement with Google Ads (only with consent, see above)
  • The platform's hosting provider