Privacy Policy
Last updated: May 2026 — Compliant with LGPD (Brazil) and GDPR (EU)
Summary: We only collect the data necessary to provide our services (name, email, WhatsApp). We do not sell your data. You can request deletion at any time.
1. Data controller
Berlinguas
Controller: Marco Ryan
Email: info@berlinguas.com
WhatsApp: +49 1573 209 0894
2. Data we collect
| Data | Purpose | Legal basis |
|---|
| Name | Identification and communication | Contract performance |
| Email | Communication, sending course information | Contract performance |
| WhatsApp (optional) | Scheduling and quick communication | Consent |
| German level | Tailoring the course to the student | Contract performance |
| Availability (days/times) | Scheduling individual lessons | Contract performance |
| Placement test result | Recommending a suitable course | Consent |
| Payment data | Payment processing via Stripe | Contract performance |
3. How we use your data
- Service delivery: organising classes, scheduling lessons, communicating timetables and materials.
- Communication: answering questions, sending information about the contracted course.
- Service improvement: aggregated (non-identifiable) analysis of site usage via Google Analytics and Microsoft Clarity.
- Advertising effectiveness measurement: we send anonymised events to Meta (Facebook/Instagram) via Meta Pixel (in browser) and Conversions API (server-side) when you take a relevant action — view page, submit form, buy. Email and phone are hashed in SHA-256 (irreversible transformation) before leaving our server; Meta never receives this data in plain text.
We do not: sell data, market to third parties (we share with Meta only to measure our own ads, not so other advertisers can reach you), or make automated decisions that affect your rights.
4. Data sharing
Your data is shared only with:
- Stripe — payment processing (PCI-DSS compliant). Stripe's Privacy Policy.
- Notion — internal student and class management (restricted team access). Notion's Privacy Policy.
- Google Analytics — site usage analysis (anonymised data, no Google Signals). Enabled only after consent. Google's Privacy Policy.
- Microsoft Clarity — anonymised session recordings and heatmaps to understand how the site is used. Email, WhatsApp and name fields are automatically masked in recordings. Enabled only after consent. Data hosted on Microsoft EU servers, retained for up to 13 months. Microsoft's Privacy Statement.
- Meta (Facebook/Instagram) — advertising effectiveness measurement via Meta Pixel (browser) and Conversions API (server). Receives events with email and phone hashed in SHA-256 (irreversible), purchase value, product, IP and user agent. The
_fbp and _fbc cookies are created by the Pixel to recognise return visits. Enabled only after consent. Meta's Privacy Policy.
- Vercel — website hosting. Vercel's Privacy Policy.
- Resend — transactional emails (lead, payment and availability confirmations). Resend's Privacy Policy.
5. Your rights (LGPD + GDPR)
You have the right to:
- Access: know what data we hold about you.
- Rectification: correct incomplete or inaccurate data.
- Erasure: request the deletion of your personal data.
- Portability: receive your data in a structured format.
- Withdrawal: withdraw your consent at any time.
- Objection: object to the processing of your data for non-essential purposes.
To exercise any of these rights, send an email to info@berlinguas.com with the subject "My Data". We will respond within 15 business days (LGPD) / 30 days (GDPR).
6. Cookies and tracking
- Prior consent required: no analytics cookies are loaded until you click "Accept" on the consent banner. If you click "Decline", no tracker is activated.
- We use Google Analytics 4 for site usage analysis (pages visited, time on site, click events). Anonymised, no Google Signals.
- We use Microsoft Clarity for anonymised session recordings and heatmaps. Fields containing personal information (email, WhatsApp, name) are automatically masked.
- We use Meta Pixel + Conversions API to measure the effectiveness of our own Instagram/Facebook campaigns. When you take a relevant action (view page, submit form, buy), we send a signal to Meta with email and phone hashed in SHA-256 (irreversible) — Meta never receives these in plain text. The
_fbp and _fbc cookies are created by the Pixel to recognise return visits and attribute conversions to ads. The server-side layer (Conversions API) mirrors the same signal to bypass ad-blockers — used to measure real attribution, not to follow you. Enabled only after consent.
- Stripe may use essential cookies for payment processing (necessary for the service to function).
- Revoke consent: clear this site's cookies in your browser or open the console and run
BerlinguasConsent.reset(). The banner will appear again on the next visit.
7. Data retention
- Active student data: retained for the duration of the service relationship.
- Leads (non-students): retained for up to 12 months after the last contact, then deleted.
- Payment data: retained in accordance with tax obligations (minimum 10 years in Germany).
- Placement test results: retained for 6 months for course recommendation purposes.
8. Security
We implement technical and organisational measures to protect your data:
- Encrypted communication (HTTPS/TLS) across the entire site.
- Payments processed directly by Stripe (card data never passes through our servers).
- Access to internal data restricted to the Berlinguas team.
9. International transfers
Your data may be processed in the USA (Stripe, Notion, Vercel, Google, Meta). All providers have Standard Contractual Clauses (SCCs) or adequate certifications for international transfers in accordance with GDPR Art. 46 and LGPD Art. 33.
10. Minors
Our services are intended for individuals aged 16 and over. For minors, consent from a legal guardian is required.
11. Changes
This policy may be updated. The date of the last update is shown at the top. Significant changes will be communicated by email to active students.
12. Contact and complaints
Email: info@berlinguas.com
If you believe that the processing of your data violates the law, you may file a complaint with: