Privacy Policy — Onlino
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Privacy Policy

1. General Information

This Privacy Policy explains how personal data is collected, used, and protected when you visit and use this website. We process personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

2. Responsible Entity

Benjamin Witopil · Deutschenbaurstrasse 31 · 86157 Augsburg · Email: info@onlino.online

3. Data We Collect

When you visit this website, certain information is automatically collected: IP address, browser type and version, operating system, referrer URL, time of access, pages visited. We also collect data you provide when purchasing a product, contacting us, or submitting forms — including name, email address, and other information you voluntarily provide. When you submit the opt-in form on this website, your email address is stored in our database and used to send you a welcome email and a short automated email sequence (up to 2 follow-up emails over 4 days).

4. Purpose of Data Processing

We process personal data to provide and deliver our products, communicate with users, provide customer support, improve website functionality and user experience, prevent abuse or fraud, and to send you the email content you requested by signing up. Email addresses collected via the opt-in form are used exclusively to deliver the requested information and marketing communications about SpeakNow™.

5. Legal Basis for Processing

We process your data based on Art. 6(1)(b) GDPR (performance of a contract), Art. 6(1)(f) GDPR (legitimate interests), and Art. 6(1)(a) GDPR (consent, where applicable). The processing of your email address for our email sequence is based on Art. 6(1)(a) GDPR — your explicit consent given when submitting the opt-in form. You may withdraw your consent at any time by contacting info@onlino.online. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

6. Payments

Payments are processed via Gumroad (Gumroad, Inc., 548 Market St #90401, San Francisco, CA 94104, USA). We do not receive or store any payment or credit card information. Gumroad processes payment data independently and in accordance with their own privacy policy (https://gumroad.com/privacy). By clicking the purchase button on this website, you are redirected to Gumroad's checkout page. Gumroad remains solely responsible for the data processing during the payment process.

7. Meta Pixel (Facebook/Meta)

With your consent, this website uses the Meta Pixel, a web analytics tool provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. The Meta Pixel enables us to track the effectiveness of our advertising and measure conversions — including the action of initiating a checkout after clicking a button on this website. When you click the purchase button on this site, an 'InitiateCheckout' event is sent to Meta. Your consent given on this website also covers this tracking event, which occurs before you are redirected to the payment provider Gumroad. Meta may transfer data to its servers in the United States. Data is processed on the basis of Art. 6(1)(a) GDPR (consent). You may withdraw your consent at any time via the cookie settings icon at the bottom left of this page. For more information, see Meta's privacy policy: https://www.facebook.com/privacy/policy.

8. Google Ads

With your consent, this website uses Google Ads conversion tracking provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. This helps us measure the effectiveness of our ads. Data may be transferred to Google's servers in the United States. Legal basis: Art. 6(1)(a) GDPR (consent).

9. Email Delivery — Hostinger

Transactional emails (welcome email and follow-up sequence) are sent via the SMTP service of Hostinger International Ltd., 61 Lordou Vironos Street, 6023 Larnaca, Cyprus. Your email address is transmitted to Hostinger's mail servers solely for the purpose of delivering these emails. Hostinger acts as a data processor on our behalf. For more information, see Hostinger's privacy policy: https://www.hostinger.com/privacy-policy.

10. Automation — Make.com & Google Sheets

We use Make (formerly Integromat), operated by Celonis SE, Theresienstraße 6, 80333 Munich, Germany, to automate internal workflows. When you submit the opt-in form, your email address and the timestamp of your subscription are transmitted to Make.com via a webhook. Make.com forwards this data to a Google Sheets spreadsheet operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, where subscriber data is stored for internal management purposes. Both Make.com and Google act as data processors on our behalf. Data may be transferred to servers in the United States. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in managing subscriber data efficiently). For more information: https://www.make.com/en/privacy-notice and https://policies.google.com/privacy.

11. Embedded YouTube Videos

This website embeds videos from YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). When you view a page containing an embedded YouTube video, a connection is established to YouTube's servers. YouTube is informed which page you visited and may set cookies or use similar technologies. If you are logged into a Google account, YouTube can associate your visit with your account. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in providing video content). Data may be transferred to Google's servers in the United States on the basis of standard contractual clauses (Art. 46 GDPR). For more information, see Google's privacy policy: https://policies.google.com/privacy.

12. Cookies & Consent Management

This website uses a Consent Management Platform (Consentmanager) to obtain and manage your consent for cookies and tracking technologies. Only technically necessary cookies are set without consent. All other cookies (analytics, marketing) are only activated after you give explicit consent. You can withdraw or change your consent at any time by clicking the icon at the bottom left of the page.

13. Data Retention

We store personal data only as long as necessary to fulfill the purposes described in this policy or as required by law. Email addresses collected via the opt-in form are retained until you withdraw your consent or request deletion.

14. Data Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, or misuse.

15. Your Rights

If you are located in the European Union, you have the right to access, rectification, erasure, restrict processing, data portability, and to object. To exercise your rights, contact: info@onlino.online

16. Third-Party Links

This website may contain links to external websites. We are not responsible for their content or data protection practices.

17. International Data Transfers

Your data may be transferred to and processed in countries outside the European Union (e.g. United States). Such transfers are carried out in accordance with applicable legal requirements, including standard contractual clauses.

18. Changes to This Policy

We may update this Privacy Policy at any time. The current version will always be available on this page.

19. Contact

If you have any questions, contact: info@onlino.online

20. MemOnlino App Privacy

The MemOnlino app stores all data (vocabulary, learning cycles, statistics) exclusively locally on the user's device. We do not collect, store, or process any personal data through the app. No data is transmitted to external servers. The app contains no advertisements, no external analytics tools, and does not track user behaviour. Notifications are scheduled locally and used solely to remind users of learning intervals. This applies to all users, including minors.