Privacy Policy (Datenschutzerklärung)

1. Data Controller Information

The data controller responsible for the processing of your personal data on this website is:

LearnWell GmbH
[Street Name and Number]
[Postal Code] Berlin
Germany

Email: hello@learnwell.ai
Phone: [Phone Number]

Data Protection Officer

For all data protection inquiries, you may contact our Data Protection Officer:

2. Overview of Data Processing

LearnWell is an AI-powered exam preparation platform. We process personal data to provide our services, improve your learning experience, and comply with legal obligations. This Privacy Policy explains how we collect, use, and protect your data in compliance with the EU General Data Protection Regulation (GDPR), German data protection laws (BDSG), and applicable international privacy regulations.

3. Categories of Personal Data We Collect

3.1 Account and Profile Data

Name and email address
Account credentials (password stored in hashed form)
Profile information and preferences
Communication preferences

3.2 Learning and Progress Data

Exam enrollments and study progress
Practice attempt results and performance metrics
Bookmarked questions and notes
Study calendar and scheduling data

3.3 Payment and Transaction Data

Subscription plan and billing history
Payment method details (processed securely by Stripe)
Invoice and receipt information

3.4 Technical and Usage Data

IP address (hashed for consent records)
Browser type and version
Device information and operating system
Usage patterns and session data
Cookies and similar technologies (see Section 10)

3.5 AI Coach Interaction Data

Chat conversation history
Coach memory and personalization data
Learning context and preferences

4. Purposes and Legal Bases for Processing

We process your personal data for the following purposes, based on the corresponding legal bases under GDPR Article 6:

4.1 Contract Performance (Art. 6(1)(b) GDPR)

Creating and managing your user account
Providing access to exam preparation content
Processing practice attempts and tracking progress
Managing subscriptions and processing payments
Providing customer support

4.2 Consent (Art. 6(1)(a) GDPR)

Setting non-essential cookies (analytics, marketing)
AI Coach memory and personalization features
Marketing communications and newsletters
Personalized learning recommendations

You may withdraw consent at any time through your account settings or by using the Cookie Settings link in the footer.

4.3 Legitimate Interests (Art. 6(1)(f) GDPR)

Improving and optimizing our platform
Ensuring security and preventing fraud
Analyzing aggregated usage patterns
Communicating service updates and changes

4.4 Legal Obligations (Art. 6(1)(c) GDPR)

Retaining financial records for tax purposes
Responding to lawful requests from authorities
Maintaining consent records for compliance

5. Recipients and Third-Party Processors

We share your personal data only with trusted third parties who assist us in operating our platform. All processors are contractually bound to protect your data (Art. 28 GDPR):

5.1 Infrastructure and Hosting

Vercel Inc. (USA) – Website hosting and deployment
Supabase Inc. (USA) – Database hosting and authentication

5.2 Payment Processing

Stripe Inc. (USA) – Secure payment processing

5.3 AI Services

Anthropic PBC (USA) – AI Coach functionality

5.4 Analytics (with consent)

Vercel Analytics – Privacy-focused usage analytics

We do not sell your personal data to third parties.

6. International Data Transfers

Some of our service providers are located in the United States. When transferring personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place:

Standard Contractual Clauses (SCCs) – We use EU Commission-approved SCCs with all US-based processors
EU-US Data Privacy Framework – Where applicable, we work with processors certified under the DPF
Supplementary Measures – Additional technical and organizational measures to protect data in transit and at rest

You may request a copy of the applicable safeguards by contacting our Data Protection Officer.

7. Data Retention

We retain your personal data only as long as necessary for the purposes described in this policy:

Account data: Until account deletion, plus 30 days for backup recovery
Learning progress: Until account deletion or upon your request
Payment records: 10 years (German tax law requirements)
Consent records: 3 years from the date of consent
AI Coach conversations: Until you delete them or disable Coach memory
Server logs: 90 days for security purposes

8. Your Rights Under GDPR

As a data subject, you have the following rights under GDPR. You can exercise these rights through your Privacy Center in account settings or by contacting us:

8.1 Right of Access (Art. 15 GDPR)

You have the right to obtain confirmation of whether we process your personal data and to receive a copy of that data. Use the "Download My Data" feature in your Privacy Center.

8.2 Right to Rectification (Art. 16 GDPR)

You have the right to correct inaccurate personal data. Update your profile information directly in your account settings.

8.3 Right to Erasure (Art. 17 GDPR)

You have the right to request deletion of your personal data ("right to be forgotten"). Use the "Delete Account" feature in your Privacy Center. Note that some data may be retained for legal obligations.

8.4 Right to Restriction (Art. 18 GDPR)

You have the right to request restriction of processing in certain circumstances. Contact our Data Protection Officer to exercise this right.

8.5 Right to Data Portability (Art. 20 GDPR)

You have the right to receive your data in a structured, machine-readable format (JSON). Use the "Download My Data" feature in your Privacy Center.

8.6 Right to Object (Art. 21 GDPR)

You have the right to object to processing based on legitimate interests. Contact our Data Protection Officer to exercise this right.

8.7 Right to Withdraw Consent (Art. 7(3) GDPR)

Where processing is based on consent, you may withdraw consent at any time. This does not affect the lawfulness of processing before withdrawal. Manage your consent preferences in your Privacy Center or through Cookie Settings.

8.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. For Germany, the relevant authority depends on your location. The federal authority is:

Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
Graurheindorfer Str. 153
53117 Bonn
Germany
Website: www.bfdi.bund.de

9. How to Exercise Your Rights

You can exercise most of your rights directly through your account:

Privacy Center: Access via Dashboard → Settings → Privacy & Data
Cookie Settings: Click "Cookie Settings" in the website footer
Email: Contact privacy@learnwell.ai

We will respond to your request within 30 days. In complex cases, we may extend this period by up to 60 additional days, with prior notification.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to operate our platform and, with your consent, to analyze usage and personalize your experience.

10.1 Essential Cookies

These cookies are necessary for the website to function and cannot be disabled:

Authentication and session management
Security features and fraud prevention
Cookie consent preferences

10.2 Analytics Cookies (Consent Required)

With your consent, we use analytics cookies to understand how visitors interact with our website:

Page views and navigation patterns
Performance metrics
Error tracking

10.3 Personalization Cookies (Consent Required)

With your consent, we use personalization features to enhance your learning experience:

AI Coach memory and context
Learning recommendations
Interface preferences

10.4 Managing Cookie Preferences

You can manage your cookie preferences at any time by clicking "Cookie Settings" in the website footer. You can also control cookies through your browser settings, though this may affect website functionality.

11. AI Coach and Automated Processing

Our AI Coach feature uses artificial intelligence to provide personalized learning assistance. Here's how we handle AI-related data:

11.1 How the AI Coach Works

The AI Coach analyzes your questions and learning context to provide helpful explanations and guidance. Conversations are processed by our AI service provider (Anthropic) to generate responses.

11.2 Coach Memory

With your consent (Personalization category), the AI Coach can remember context from previous conversations to provide more relevant assistance. You can:

View a summary of stored Coach memory
Delete all Coach memory at any time
Disable Coach memory entirely (conversations won't be stored)

11.3 Chat History

Your chat conversations with the AI Coach are stored to allow you to review previous discussions. You can delete individual conversations or all chat history through your Privacy Center.

11.4 AI Limitations

The AI Coach can make mistakes. Always verify important information from official sources. Do not share sensitive personal data, passwords, or confidential information in chat conversations.

11.5 No Automated Decision-Making

We do not use AI for automated decision-making that produces legal effects or similarly significantly affects you (Art. 22 GDPR). The AI Coach provides educational assistance only.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

Encryption of data in transit (TLS/HTTPS) and at rest
Secure authentication with hashed passwords
Regular security assessments and updates
Access controls and employee training
Incident response procedures

While we strive to protect your data, no method of transmission over the internet is 100% secure. We encourage you to use strong passwords and protect your account credentials.

13. Children's Privacy

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If you believe we have collected information from a child, please contact us immediately at privacy@learnwell.ai.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will:

Update the "Last Updated" date at the top of this page
Notify you of material changes via email or in-app notification
Request renewed consent where required by law

We encourage you to review this policy periodically.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights:

General Inquiries:
Email: hello@learnwell.ai

Data Protection Officer:
Email: privacy@learnwell.ai

Postal Address:
LearnWell GmbH
[Street Name and Number]
[Postal Code] Berlin
Germany