Babbel

Babbel is a German subscription-based language learning app and e-learning platform.

5.9/10

How we calculate ratings →

Handling

Does the policy allow personally-targeted or behavioral marketing? Yes, but you may opt-out

4/10

Does the service allow you to permanently delete your personal data? Yes, using an automated mechanism

5/5

Does the service allow third-party access to private personal data? Yes, all parties specified (including non-critical service providers such as advertisers)

3/10

This may come in the form of outright data sharing or by using local third-party analytics software (such as Google Analytics, which collects a plethora of user information).

Note that whether the policy allows sharing aggregated user data does not affect this question.

If the personal data is encrypted when it passes through the third-party, it does not count as third-party access (as the data is inaccessible to that party).

If personal data has been made public by, for example, posting it to a blog, it does not count as private personal information (and is therefore not considered by this question).

Score

Yes

The policy allows sharing personal data with third parties (not just critical service providers), and does not explicitly list the third parties.

Yes, all parties specified (including non-critical service providers such as advertisers)

30%

Yes, not all parties specified (but only to critical service providers)

70%

Yes, all parties specified (only to critical service providers)

80%

100%

Citation

With reference to Clause 1.7, you will find a list here of further external suppliers:

New Relic (Optimization of the website [...])
Visual Website Optimizer (Optimization of the website, A/B tests [...])
Google AdWords (Marketing, campaign measurements [...])
Google Tag Manager (Marketing [...])
ShareThis (Social Media Plugin [...])

When does the policy allow law enforcement access to personal data? When reasonably requested

3/5

Score

Always

This includes cases in which law enforcement either runs the service or has a known backdoor into (or relationship with) the service.

Not specified

When reasonably requested

60%

Only when required by a court order or subpoena

80%

N/A (no personal data to share)

The service would have no personal data to share with law enforcement.

100%

Never (special legal jurisdiction)

The service operates in a jurisdiction in which sharing data with law enforcement is never required.

100%

Citation

Lesson Nine does not forward the personal data of its users to third parties unless the user has given his/her explicit consent or there is a legal requirement to forward the data.

Notes

This is vague enough to be at their discretion.

Transparency

Does the policy outline the service's general security practices? Somewhat

1/3

Score

Somewhat

The policy provides only a very vague overview of its security practices.

30%

Yes

60%

Yes, including audits

"Reviews," "monitoring," etc. also count as audits.

80%

Yes, including independent audits

Independent "reviews," "monitoring," etc. also count as independent audits.

100%

N/A

The service doesn't collect any personal information.

100%

Citation

Lesson Nine employs safety precautions to guarantee that your data are protected against loss, modification or misuse. To this end, Lesson Nine works with constantly updated firewalls meeting the industry standard as well as other security systems. At the same time, the user should be aware of the fact that one hundred per cent protection against attacks cannot be guaranteed because of the continual appearance of new viruses and other means of attacking the protected data systems of Internet services. Lesson Nine will instigate civil and criminal proceedings against any attack by hackers and the like and will inform the users of any cases in which their data have been compromised.

Is the policy's history made available? No

0/5

Does the policy require users to be notified in case of a data breach? Yes, eventually

5/7

Will affected users be notified when the policy is meaningfully changed? No

0/5

Collection

Does the service collect personal data from third parties? No

10/10

Is it clear why the service collects the personal data that it does? Yes

10/10

Does the service allow the user to control whether personal data is collected or used for non-critical purposes? On an opt-out basis, but only for some non-critical data/uses

3/10

Some services allow users to opt-out or opt-in to of non-critical collection or use of personal data, such as collecting data for personalized advertisements.

Score

On an opt-out basis, but only for some non-critical data/uses

30%

On an opt-out basis, for all non-critical data/uses

60%

On an opt-in basis

60%

N/A (no data used for non-critical purposes)

100%

Citation

[...] you can prevent the data captured by the cookie and relating to your use of the website (incl. your IP address) from being captured and processed by Google by downloading and installing the browser plugin available at the following link : https://tools.google.com/dlpage/gaoptout?hl=en.

[...]

You will find further information on the purpose and scope of the data capture and the further processing and use of the data by Facebook as well as optional settings for protecting your privacy in the Facebook data protection guidelines at: https://www.facebook.com/about/privacy/.

[...]

With reference to Clause 1.7, you will find a list here of further external suppliers:

New Relic (Optimization of the website, https://newrelic.com/privacy)
Visual Website Optimizer (Optimization of the website, A/B tests,https://vwo.com/opt-out/)
Google AdWords (Marketing, campaign measurements, https://www.google.de/intl/de/policies/technologies/ads/)
Google Tag Manager (Marketing, https://www.google.com/policies/privacy/)
ShareThis (Social Media Plugin, https://www.sharethis.com/legal/privacy)

Does the policy list the personal data it collects? Yes, exhaustively

10/10

Score

The policy does not claim to not collect personal data, but it also doesn't provide any meaningful insight into the types of personal data it collects.

Only summarily

The policy uses overly vague language to provide a summary of the types of collected personal data.

30%

Yes, generally

All general categories of collected personal data are listed, though not all types of personal data are explicitly mentioned (for example, the list might use a phrase like 'such as' when listing types of personal data).

70%

Yes, exhaustively

All types of collected personal data are listed specifically

100%

N/A (no personal data is collected)

100%

Notes

Due to girth of the article, an anchor link is provided:

https://about.babbel.com/privacy#1-which-data-are-stored

Last Updated

May 26, 2021

Sources

Source #1 ↗

Contributors

doamatto