Babbel

Babbel is a German subscription-based language learning app and e-learning platform, available in various languages since January 2008.

This page is not published. While you can access it via its direct link, it is not yet displayed on the website.

Transparency

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

5/7

Decided May 15, 2020 (revision history). This question accounts for 8% of the final score.

Users will be notified in case of a data breach, but within an unspecified amount of time.

Note that all companies operating in the EU are subject to Art. 33 of the GDPR, which requires companies to notify their data protection authority of a data breach within 72 hours of discovering it.

Possible Options

No0/7
Yes, eventually5/7
Yes, within 72 hours7/7
N/A (the service collects so little personal data that notification would not be possible)7/7

Citation

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.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


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

0/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Yes5/5
N/A (no personal data—or contact information—collected)5/5

Note

There is no clause mentioning the notice of policy changes.

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Is the policy's history made available? No

0/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Only the date it was last modified3/5
Yes, with revisions or a change-log5/5

Note

No date or history

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

1/3

Decided May 15, 2020 (revision history). This question accounts for 4% of the final score.

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

Possible Options

No0/3
Somewhat1/3
Yes2/3
Yes, including audits2.5/3
N/A (no personal data collected)3/3
Yes, including independent audits3/3

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.

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Collection

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

10/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

This question deals with transparency. Even if the service uses data for reasons that aren't ideal for privacy, provided they list all of those uses, the service can still receive full credit for this question. However, if they are not explicit about their uses (by employing language like "such as"), a lower score is assigned.

Possible Options

No0/10
Somewhat4/10
Mostly7/10
Yes10/10
No personal data is collected10/10

Note

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

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

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

10/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

All types of collected personal data are listed specifically

Possible Options

No0/10
Only summarily3/10
Yes, generally7/10
Yes, exhaustively10/10
N/A (no personal information is collected)10/10

Note

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

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

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the service collect personal data from third parties? No

10/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

This includes the use of data brokers and independent verification authorities (such as background check providers).

Possible Options

Yes0/10
Only for critical data7/10
No10/10

Note

No mention of using these services.

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

1.5/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

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.

Possible Options

No0/5
On an opt-out basis, but only for some non-critical data/uses1.5/5
On an opt-out basis, for all non-critical data/uses3/5
N/A (no data used for non-critical purposes)5/5
On an opt-in basis5/5

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 : http://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, http://www.google.de/intl/de/policies/technologies/ads/) Google Tag Manager (Marketing, http://www.google.com/policies/privacy/) ShareThis (Social Media Plugin, http://www.sharethis.com/legal/privacy)

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Handling

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

3.5/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

Possible Options

Yes0/10
Yes, but you can opt-out3.5/10
Yes, but you must opt-in7/10
No10/10

Citation

We use further external service providers for the purpose of optimizing our services, carrying out advertising activities or for analyzing our website for errors and in terms of its performance. Such service providers may vary. For the sake of clarity, we have listed these service providers in tabular format at the end of this data protection notice under Clause 8, and in each case we have supplied further information on the processing of data and on any opt-outs.

Note

Those services are New Relic, Visual Website Optimizer, Google AdWords, Google Tag Manager, and ShareThis. Clause 8 of the privacy policy also has the opt-out URLs for each of the services.

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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

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

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).

Possible Options

Yes, not all parties specified0/10
Yes, all parties specified (including non-critical service providers such as advertisers)3/10
Yes, not all parties specified (but only to critical service providers)7/10
Yes, all parties specified (only to critical service providers)8/10
No10/10

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 [...])

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

5/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

Even if there is a reasonable delay before the data is fully deleted (as is common), the data still counts as "permanently deleted" and satisfies the parameters for this question.

Possible Options

No0/5
Yes, by contacting someone3/5
Yes, using an automated mechanism5/5
N/A (no personal information collected)5/5

Citation

Should the user demand any alteration, correction or deletion of his/her personal data, this may take place by email or letter. To ensure correct identification of the user, the request must at least contain the following details:

User name First name and surname Email address Postal address

Please note that due to caching systems, search engines, the interposition of proxy servers and the like, deleted data may continue to remain accessible even though they are no longer present within our systems.

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

3/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

Always0/5
Not specified0/5
When reasonably requested3/5
Only when required by a court order or subpoena4/5
N/A (no personal data to share)5/5
Never (special legal jurisdiction)5/5

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.

Note

This is vague enough to be at their discretion.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.



Warnings

Babbel has no warnings published on PrivacySpy. PrivacySpy publishes warnings when it learns a service has announced a data breach or is found misusing user data. If you believe a warning should be published for Babbel, submit one here.


Highlighted Policy Snapshot ALPHA

No highlighted policy snapshot has been created for this privacy policy. To view the policy at its original location, click here.

6.1/10

How we calculate ratings →


Version Added

May 15, 2020

Ratings Updated

May 15, 2020

Warnings

0

Maintained by

doamatto

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