Effective Date: 1 September 2026

Version: 1.0

PART 1A – GENERAL PROVISIONS

1. Introduction

Linguaclub respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how Linguaclub collects, uses, stores, shares and protects your personal data when you visit our Website, create a Student Account, purchase Services or otherwise interact with Linguaclub.

This Privacy Policy should be read together with our Terms and Conditions, Cookie Policy and any other documents expressly referred to therein.

By accessing or using the Website or our Services, you acknowledge that your personal data may be processed in accordance with this Privacy Policy, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and all applicable Dutch data protection legislation.

Nothing in this Privacy Policy limits any mandatory rights granted to you under applicable law.

2. Who We Are

Linguaclub is an online language school providing Digital Courses, Group Lessons, Private Lessons, Corporate Training and other educational Services through its Website and online learning Platform.

For the purposes of the General Data Protection Regulation (GDPR), Linguaclub is the Data Controller responsible for the processing of the personal data described in this Privacy Policy.

Contact Details of Linguaclub

Website: https://linguaclub.eu

Email: info@linguaclub.eu

Chamber of Commerce (KvK): 87513935

VAT Number: NL864315752B01

If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact us using the details above.

Unless otherwise required by applicable law, communications relating to this Privacy Policy should be sent by email.

3. Scope of this Privacy Policy

This Privacy Policy applies to all personal data processed by Linguaclub in connection with:

• the Website;
• the learning Platform;
• Student Accounts;
• Digital Courses;
• Group Lessons;
• Private Lessons;
• Corporate Training;
• online consultations;
• contact forms;
• email correspondence;
• newsletter subscriptions;
• payment procedures;
• customer support;
• and all other Services provided by Linguaclub.

This Privacy Policy applies to individuals aged 16 years or older.

It does not apply to third-party websites, applications or services that may be linked from the Website.

Such third parties operate under their own privacy policies, and Linguaclub accepts no responsibility for their privacy practices, content or security.

Where third-party services are used in connection with the Services, including payment providers, online communication platforms or learning technologies, your personal data may also be processed in accordance with the privacy policies of those providers.

We encourage you to read the privacy policies of any third-party services that you use in connection with our Services.

Nothing in this Privacy Policy shall limit or exclude any mandatory rights granted to you under applicable Dutch or European Union data protection legislation.

PART 1B – COLLECTION AND PROCESSING OF PERSONAL DATA

4. Personal Data We Collect

Depending on how you use our Services, Linguaclub may collect and process the following categories of personal data.

Identity Data

• first name;
• last name.

Contact Data

• residential address;
• email address;
• telephone number (where voluntarily provided).

Your residential address may be collected where reasonably necessary for:

• issuing invoices;
• maintaining accounting records;
• complying with legal obligations;
• debt recovery procedures;
• enforcing contractual rights;
• or other legitimate business purposes permitted by applicable law.

Account Data

• username;
• encrypted password;
• login history;
• account preferences;
• language preferences.

Educational Data

• enrolled Digital Courses;
• booked lessons;
• lesson attendance;
• learning progress;
• completed assignments;
• assessment results;
• certificates, where applicable.

Communication Data

Linguaclub may retain communications exchanged with you, including:

• emails;
• contact form submissions;
• customer support correspondence;
• consultation requests;
• communications relating to your Student Account or the Services.

Payment Data

Payments are processed securely through Mollie or, where applicable, another payment service provider selected by Linguaclub.

Linguaclub does not store complete credit card, debit card or other payment card details.

Linguaclub does not have access to your full payment card details. Payment transactions are processed directly by the payment service provider using secure encrypted connections.

We receive only the information reasonably necessary to:

• confirm successful payment;
• issue invoices;
• maintain accounting records;
• manage the purchased Services.

Payment service providers process personal data in accordance with their own privacy policies and applicable data protection legislation. Where applicable, they act as independent data controllers or data processors.

Technical Data

When you use our Website or Platform, certain technical information may be collected automatically, including:

• IP address;
• browser type;
• browser language;
• operating system;
• device type;
• date and time of access;
• pages visited;
• referring website;
• technical logs required for security;
• Platform usage information.

Lesson Recordings

Where Group Lessons are recorded, recordings may include:

• first name;
• voice;
• image;
• educational participation during the lesson.

Where reasonably practicable, Students will be informed before a Group Lesson is recorded.

Participation in a recorded Group Lesson constitutes acknowledgement that the recording is made for the educational purposes described in this Privacy Policy and the Terms and Conditions.

Lesson recordings are created solely for educational purposes.

They may be used:

• to provide access to Students who were absent from the relevant Group Lesson;
• to support revision and learning;
• for the internal professional development and training of Linguaclub Teachers.

Lesson recordings are not used for advertising, promotional or marketing purposes without the explicit consent of the individuals concerned, where such consent is required by applicable law.

Lesson recordings remain the intellectual property of Linguaclub and are processed in accordance with this Privacy Policy and the Terms and Conditions.

5. How We Collect Personal Data

Linguaclub collects personal data in several ways.

Information Provided Directly by You

We collect personal data when you:

• create a Student Account;
• purchase Services;
• book lessons;
• contact us by email or through the Website;
• request a consultation;
• subscribe to newsletters or other communications;
• participate in lessons;
• complete assignments or assessments;
• voluntarily provide information while using our Services.

Information Collected Automatically

Certain information is collected automatically when you use the Website or Platform through cookies and similar technologies.

Further information is available in our Cookie Policy.

Where applicable, you may manage your cookie preferences through the cookie banner displayed on the Website.

Please note that disabling certain cookies may affect the functionality, performance or availability of certain features of the Website or Platform.

Information Received from Third Parties

We may receive limited personal data from:

• payment service providers;
• online communication platforms;
• learning management systems;
• technical service providers;
• or other service providers involved in delivering the Services.

We receive only the information reasonably necessary to provide the Services, comply with legal obligations and administer our business.

Data Accuracy

Linguaclub makes reasonable efforts to ensure that the personal data it processes is accurate and, where necessary, kept up to date.

Students are responsible for ensuring that the personal data they provide is accurate, complete and current.

Students should notify Linguaclub without undue delay of any changes to their personal data so that our records remain accurate.

6. Legal Bases for Processing Personal Data

Linguaclub processes personal data only where there is a lawful basis under the GDPR.

Depending on the circumstances, processing is based on one or more of the following legal grounds.

Performance of a Contract

Processing is necessary to:

• create and manage your Student Account;
• provide Digital Courses;
• organise Group Lessons and Private Lessons;
• issue invoices;
• maintain accounting records;
• process payments;
• communicate regarding the Services;
• recover outstanding payments where necessary;
• provide customer support.

Compliance with Legal Obligations

Processing is necessary to comply with applicable Dutch and European legislation, including:

• tax obligations;
• accounting requirements;
• consumer protection legislation;
• court orders;
• lawful requests from public authorities.

Legitimate Interests

Linguaclub may process personal data where necessary for its legitimate interests, provided that such interests do not override your fundamental rights and freedoms.

These legitimate interests include:

• improving the Website and the Services;
• maintaining the quality and continuity of the Services;
• maintaining Platform security;
• preventing fraud;
• protecting intellectual property rights;
• improving teaching quality;
• providing professional development and training for Teachers using lesson recordings, where appropriate;
• responding to legal claims;
• recovering outstanding payments;
• ensuring the efficient administration of the business.

Consent

Where required by applicable law, Linguaclub will request your consent before processing your personal data.

You may withdraw your consent at any time where processing is based on consent.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Where consent is withdrawn, this does not affect any processing carried out on another lawful basis under the GDPR.

PART 2 – USE, SHARING AND RETENTION OF PERSONAL DATA

7. Student Accounts

Certain Services provided by Linguaclub require the creation of a personal Student Account.

Each Student Account is personal, non-transferable and may be used only by the registered Student.

Students are responsible for:

• maintaining the confidentiality of their login credentials;
• keeping their password secure;
• ensuring that the information contained in their Student Account remains accurate and up to date;
• notifying Linguaclub immediately if they become aware of any unauthorised access to or use of their Student Account.

Students are responsible for all activities carried out through their Student Account unless they have previously informed Linguaclub of unauthorised access.

Information stored within a Student Account may include:

• personal profile information;
• enrolled Digital Courses;
• booked lessons;
• learning progress;
• completed assignments;
• assessment results;
• certificates where applicable;
• account preferences;
• communication history relating to the Services.

Linguaclub processes this information solely for the purpose of providing, administering and improving the Services.

8. Payments and Invoicing

Payments for the Services are processed securely through Mollie or, where applicable, another payment service provider selected by Linguaclub.

Linguaclub does not process or store complete payment card details.

Personal data contained in invoices, accounting records and payment confirmations is processed only where necessary for:

• processing payments;
• issuing invoices;
• maintaining accounting records;
• complying with Dutch tax and accounting legislation;
• recovering outstanding payments;
• protecting Linguaclub’s legal rights.

Accounting records containing personal data are retained for the period required by applicable Dutch tax and accounting legislation.

Payment providers process payment information in accordance with their own privacy policies and applicable data protection legislation.

9. Lesson Recordings

Linguaclub may record Group Lessons for educational purposes.

Where reasonably practicable, Students will be informed before a Group Lesson is recorded.

Participation in a recorded Group Lesson constitutes acknowledgement that the recording is made for the educational purposes described in this Privacy Policy and the Terms and Conditions.

Lesson recordings are created exclusively to:

• enable Students who were absent from a Group Lesson to review the lesson;
• support revision and learning;
• improve teaching quality;
• provide professional development and internal training for Linguaclub Teachers.

Lesson recordings may contain:

• first names;
• voices;
• images;
• educational participation during the lesson.

Access to lesson recordings is limited to authorised persons who require access for educational purposes.

Students may not copy, download (unless expressly permitted), publish, distribute, upload, edit, sell, share or otherwise make lesson recordings available to any third party.

Lesson recordings remain the exclusive intellectual property of Linguaclub.

Lesson recordings are retained only for as long as reasonably necessary for educational purposes and the professional development of Teachers, unless a longer retention period is required by law.

Lesson recordings are never used for advertising, promotional or marketing purposes without the explicit consent of the individuals concerned where such consent is required by applicable law.

10. Cookies

Linguaclub uses cookies and similar technologies to ensure the proper functioning, security and performance of the Website and the Platform.

Cookies may be used for purposes including:

• maintaining user sessions;
• remembering user preferences;
• improving Website functionality;
• enhancing security;
• analysing Website performance;
• measuring Website usage;
• supporting educational functionality.

Where required by applicable law, Linguaclub will obtain your consent before placing non-essential cookies on your device.

You may manage or withdraw your cookie preferences at any time through the cookie banner available on the Website or through your browser settings.

Please note that disabling certain cookies may affect the functionality, performance or availability of certain features of the Website or Platform.

Further information regarding cookies is available in the Cookie Policy.

11. Marketing Communications

Linguaclub may send electronic communications relating to the Services.

These communications may include:

• account notifications;
• payment confirmations;
• invoices;
• lesson reminders;
• timetable updates;
• Platform notifications;
• service announcements;
• educational information relating to the Services.

Where required by applicable law, promotional or marketing communications will be sent only where an appropriate legal basis exists, including your consent where required.

You may unsubscribe from marketing communications at any time by using the unsubscribe link contained in the communication or by contacting Linguaclub directly.

Service-related communications that are necessary for the performance of the Agreement, the administration of your Student Account or compliance with legal obligations will continue to be sent even if you opt out of receiving marketing communications.

12. Data Retention

Linguaclub retains personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law.

In general:

• Student Account information is retained while the Account remains active and for a reasonable period thereafter where necessary for legal, contractual or administrative purposes;
• invoices, accounting records and payment confirmations are retained for the period required by applicable Dutch tax and accounting legislation;
• customer support correspondence is retained for as long as reasonably necessary to resolve enquiries, protect legal rights or comply with legal obligations;
• lesson recordings are retained only for as long as reasonably necessary for educational purposes and the professional development of Teachers;
• technical logs are retained only for as long as necessary to maintain Platform security, investigate incidents and ensure the proper functioning of the Services.

Where required by law, certain personal data may be retained after the termination of a Student Account.

Where personal data is no longer required, Linguaclub will securely delete, anonymise or otherwise dispose of such data in accordance with applicable law.

PART 3 – DATA SHARING, YOUR RIGHTS AND FINAL PROVISIONS

13. Sharing Personal Data

Linguaclub respects the confidentiality of your personal data and does not sell, rent or trade personal data to third parties.

Personal data may be disclosed only where necessary for the provision of the Services, compliance with legal obligations or the protection of Linguaclub’s legitimate interests.

Depending on the Services used, personal data may be shared with:

• payment service providers;
• website hosting providers;
• learning management system providers;
• online communication platform providers;
• cloud storage providers;
• email and communication service providers;
• IT support providers;
• accountants, auditors and legal advisers;
• competent public authorities or courts where disclosure is required by law.

Where third parties process personal data on behalf of Linguaclub, appropriate contractual safeguards are implemented where required by applicable law.

Linguaclub shares only the minimum amount of personal data reasonably necessary for the relevant purpose.

14. International Transfers of Personal Data

Linguaclub primarily stores and processes personal data within the European Economic Area (EEA).

Where personal data is transferred outside the EEA, Linguaclub will ensure that appropriate safeguards are implemented in accordance with the GDPR.

Such safeguards may include:

• an adequacy decision adopted by the European Commission;
• the European Commission’s Standard Contractual Clauses (SCCs);
• or another lawful transfer mechanism recognised under applicable data protection legislation.

Where third-party providers process personal data outside the European Economic Area, Linguaclub will take reasonable steps to ensure that an equivalent level of protection is provided.

Students may request additional information regarding international transfers of personal data by contacting Linguaclub.

15. Your Rights Under the GDPR

Subject to applicable law, you may exercise the following rights regarding your personal data:

• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure (“right to be forgotten”);
• the right to restrict processing;
• the right to data portability;
• the right to object to processing;
• the right not to be subject to a decision based solely on automated processing where applicable;
• the right to withdraw consent at any time where processing is based on consent.

Requests relating to your personal data should be submitted to:

Email: info@linguaclub.eu

Linguaclub will respond within the time limits required by applicable law.

Where permitted by law, Linguaclub may request proof of identity before responding to a request relating to personal data.

16. 16. Automated Decision-Making

Linguaclub does not make decisions producing legal effects or similarly significant effects concerning Students based solely on automated processing, including profiling, within the meaning of Article 22 of the GDPR.

Should this practice change in the future, Linguaclub will update this Privacy Policy accordingly and, where required by applicable law, provide the necessary information to affected individuals.

17. 17. Security of Personal Data

Linguaclub implements appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.

These measures may include:

• encrypted SSL/TLS connections;
• password protection;
• restricted access to personal data;
• secure authentication procedures;
• regular software updates;
• system monitoring;
• backup procedures;
• internal confidentiality measures;
• staff awareness regarding data protection.

Although Linguaclub applies reasonable security measures, no method of transmission over the Internet or method of electronic storage can be guaranteed to be completely secure.

Students are also responsible for maintaining the confidentiality of their Student Account credentials and for taking reasonable steps to protect their devices and passwords.

In the event of a personal data breach, Linguaclub will comply with its obligations under the GDPR, including notification of the competent supervisory authority and affected individuals where required by applicable law.

18. 18. Changes to this Privacy Policy

Linguaclub may update this Privacy Policy from time to time to reflect changes in:

• applicable legislation;
• regulatory requirements;
• business operations;
• technologies;
• Website functionality;
• or the Services provided.

The most recent version of this Privacy Policy will always be published on the Website.

Where required by applicable law, appropriate notice will be provided before material changes become effective.

The Effective Date shown at the beginning of this Privacy Policy indicates when the current version entered into force.

Continued use of the Services after the updated Privacy Policy becomes effective constitutes acknowledgement of the revised Privacy Policy.

19. 19. Complaints and Contact Information

If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact:

Linguaclub

Website: https://linguaclub.eu

Email: info@linguaclub.eu

Chamber of Commerce (KvK): 87513935

VAT Number: NL864315752B01

Linguaclub aims to respond to privacy-related enquiries without undue delay and within the time limits required by applicable law.

If you believe that your personal data has been processed in breach of applicable data protection legislation, you have the right to lodge a complaint with the competent supervisory authority.

For individuals in the Netherlands, the competent supervisory authority is:

Autoriteit Persoonsgegevens

https://autoriteitpersoonsgegevens.nl

Linguaclub encourages you to contact us first so that we have the opportunity to resolve your concerns before you submit a complaint to the supervisory authority.

20. Language

This Privacy Policy was originally drafted in the English language.

Where this Privacy Policy is translated into another language, the English version shall prevail in the event of any inconsistency or conflict, to the extent permitted by applicable law.