ImagiLearn – Privacy Policy

Last Updated: May 2026

Welcome to ImagiLearn. We take the privacy, safety, and security of your family’s personal data incredibly seriously. This Privacy Policy outlines how ImagiLearn collects, uses, stores, and protects the information provided by a parent or legal guardian ("you", "your") when accessing our website, booking our online learning services, or communicating with us.

As a business legally registered in Germany and delivering premium services internationally (including to families in Singapore and the United Kingdom), we are fully committed to compliance with strict global data protection standards. This includes the European Union’s General Data Protection Regulation (GDPR / DSGVO), the German Federal Data Protection Act (BDSG), the German Telecommunications Digital Services Data Protection Act (TDDDG), the UK Data Protection Act, and the Singapore Personal Data Protection Act (PDPA).

1. Data Controller & Contact Information

The "Controller" responsible for the processing of your personal data under European data protection laws is:

ImagiLearnRepresented by: Gabi Eaton

Address: Clemensstraße, 8, Munich. 80803, Germany

Email: geaton@imagi-learn.com

Website:https://www.imagi-learn.com/

Please note: For any data protection inquiries, rights requests, or questions regarding child safety, you can reach out directly to the controller via the email address listed above.

2. Information We Collect and Our Legal Bases

We only collect the absolute minimum amount of personal data necessary to deliver high-quality, safe, and tailored cognitive mentorship to your child. Under the GDPR, we must state the legal basis for every tracking or collection process:

2.1. Information Provided Directly by You

When a parent or legal guardian schedules a session via Squarespace, registers an account, or completes a contact form, you provide us with:

  • Your Contact Details: Full name, email address, and phone number.

    • Legal Basis:Art. 6(1)(b) GDPR (Necessary for the performance or preparation of a tutoring contract).

  • Your Child’s Information: First name and age. This is required strictly to verify they are within our 6–11 age range and to safely tailor the lesson framework.

    • Legal Basis:Art. 6(1)(b) GDPR (Contract fulfillment).

  • Academic, Behavioral, or Personal Notes: Any specific learning requirements, cognitive goals, or background context you choose to share to support your child. Because these notes can occasionally touch on sensitive development metrics or learning differences, we process this information under strict confidentiality.

    • Legal Basis:Art. 9(2)(a) GDPR (Your explicit consent, which you give by choosing to submit these voluntary notes).

2.2. Automated Information (Website & Server Log Files)

When you visit our website, our server infrastructure (hosted via Squarespace) automatically collects technical data. This includes:

  • IP address (anonymized/shortened dynamically)

  • Date and time of your visit

  • Browser type, operating system, and language settings

  • Referrer URL (the site you visited right before ours)

This data is technically required to serve you our website cleanly, ensure server stability, and prevent malicious security threats. It is not merged with your personal registration files and is auto-purged within 14 days.

  • Legal Basis:Art. 6(1)(f) GDPR (Our legitimate interest in maintaining a secure, crash-free website).

2.3. Cookie Management

Our website uses cookies. Essential cookies ensure our scheduling engine and site basic features operate safely. Analytical or marketing cookies are only activated if you actively consent via our cookie banner upon landing. You can modify your preferences at any time.

  • Legal Basis:§ 25 (1) TDDDG (Informed user consent for non-essential cookies).

3. How We Use Your Information

We use the personal data provided by the parent or legal guardian strictly for operational, educational, and legal purposes, including:

  • Scheduling, managing, and delivering our 1:1 and group online learning sessions.

  • Communicating essential updates, lesson preparation notes, or schedule changes.

  • Processing secure payments and managing package balances.

  • Ensuring child safeguarding and maintaining strict visual and data privacy during our Zoom calls.

  • Complying with statutory tax, accounting, and legal obligations as a registered German business.

4. Data Sharing and Trusted Third-Party Processors

We will NEVER sell, rent, trade, or distribute your personal information or your child's data to third-party marketing companies.

To deliver our international digital service, we partner with industry-standard, secure platforms that act as our Data Processors under strict Data Processing Agreements (AVV - Auftragsverarbeitungsvertrag pursuant to Art. 28 GDPR):

  • Squarespace Ireland Ltd. / Squarespace, Inc.: For website hosting and infrastructure scheduling tools.

  • Stripe Payments Europe, Ltd. / Stripe, Inc.: For secure, PCI-DSS compliant credit card and package balance management. ImagiLearn does not see or store raw credit card details.

  • Zoom Video Communications, Inc.: For live video interaction.

5. International Data Transfers & Safeguards

Because ImagiLearn is registered in Germany and operates globally across the UK, Singapore, and beyond, personal data may cross international borders.

When your data is handled by US-based parents of our service processors (like Squarespace, Stripe, or Zoom), your data transfers are fully protected under the EU-U.S. Data Privacy Framework (DPF). All three of our core software partners are certified active participants in the DPF, guaranteeing a level of data protection equivalent to European standards. Where necessary, Standard Contractual Clauses (SCCs) are deployed additionally to safeguard your international privacy rights under both GDPR and PDPA rules.

6. Strict Classroom Visual Privacy Safeguards

In line with our strict child safeguarding standards:

  • No Recordings: No video or audio sessions are ever digitally recorded or saved by ImagiLearn without the separate, explicit, prior written consent of the parent or legal guardian.

  • Peer Privacy: Group privacy controls are actively engaged on Zoom so that children cannot view or snapshot other children's faces or full screens carelessly, creating a safe, localised zone for personal mentorship.

  • Recording Ban: The Client and students are strictly prohibited from recording, photographing, or screenshotting any part of the online sessions.

7. Data Retention and Mandatory Deletion Timelines

We do not store your data forever. We delete your information as soon as it is no longer required for its original purpose, unless legal statutory preservation orders require us to hold onto it:

  • Invoices, Payments, and Tax Data: Retained for 10 years to comply with German Tax and Commercial Law (§ 147 AO / Abgabenordnung and § 257 HGB / Handelsgesetzbuch).

  • Contracts and Business Emails: Retained for 6 years to comply with standard corporate record keeping constraints.

  • General Inquiries & Learning Notes: Deleted within 6 months if a conversation or application does not materialize into an active tutoring registration.

8. Your Comprehensive Legal Rights

Regardless of where you live in the world, we extend comprehensive data privacy rights to every parent or legal guardian who trusts us with their information. You may execute any of the following rights free of charge by emailing us:

  • Right of Access (Art. 15 GDPR): Request a copy of all data held about you or your child.

  • Right to Rectification (Art. 16 GDPR): Correct inaccurate or out-of-date records.

  • Right to Erasure (Art. 17 GDPR): Request full deletion of your records, provided it doesn't conflict with our 10-year German tax retention obligations.

  • Right to Restrict Processing (Art. 18 GDPR): Freeze data handling while disputes are verified.

  • Right to Data Portability (Art. 20 GDPR): Receive your structural account profile details in a machine-readable format.

  • Right to Object (Art. 21 GDPR): Stop any processing based on legitimate interests.

  • Right to Withdraw Consent (Art. 7(3) GDPR): Pull back permission for voluntary items (like learning notes or platform profiles) at any time.

Right to Lodge a Complaint

If you believe ImagiLearn has handled your family's data in violation of European laws, you have the legal right to file a formal complaint with a data privacy supervisory authority. Our regional authority in Bavaria is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA) > Promenade 18, 91522 Ansbach, Germany

Web: https://www.lda.bayern.de

9. Changes to This Privacy Policy

We may occasionally update this Privacy Policy to reflect operational, technical, or legal adjustments. When updates are made, we will adjust the "Last Updated" date at the top of this page. We encourage the parent or legal guardian to review this policy periodically.

10. Contact Us

If you have any questions, concerns, or unique privacy requests regarding your family's data, please do not hesitate to contact ImagiLearn directly at: contact@imagi-learn.com