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LEGAL

Privacy Policy – App & Studio

For use of the Learn Battle app and Learn Battle Studio. Our general privacy policy applies to this website.

This privacy policy informs you, pursuant to Art. 13, 14 GDPR, about the processing of personal data in connection with the use of our digital products:

  • Learn Battle app – for learners (e.g. pupils, students)
  • Learn Battle Studio – for teachers, administrators and content managers

The processing of personal data differs depending on the context of use. The respective processing activities are presented separately below.

Table of contents
  1. 1. Controller
  2. 2. Data protection officer
  3. 3. Competent supervisory authority
  4. 4. Types of data processed
  5. 5. Payment processing via Stripe
  6. 6. Invoice data & retention
  7. 7. AI services (KISSKI and OpenAI)
  8. 8. Hosting
  9. 9. Data transfer to teachers
  10. 10. Push notifications
  11. 11. Storage period
  12. 12. Data subject rights
  13. 13. Security
  14. 14. Minor users
  15. 15. Changes
  16. 16. Contact

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Learn Battle
Dennis Koob, Annika Latz
Karl-Arnold-Str. 31
52525 Heinsberg
Germany
Email: datenschutz@learn-battle.de

The controller decides, alone or jointly with others, on the purposes and means of processing personal data.

2. Data protection officer

A data protection officer has not been appointed under current statutory requirements, as the legal conditions pursuant to Art. 37 GDPR are not met.

For data protection matters, please contact us at: datenschutz@learn-battle.de

3. Competent supervisory authority

State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia (LDI NRW)
Kavalleriestraße 2–4
40213 Düsseldorf, Germany
Phone: +49 211 38424-0
Email: poststelle@ldi.nrw.de
Website: ldi.nrw.de

You have the right, pursuant to Art. 77 GDPR, to lodge a complaint with a supervisory authority.

4. Types of data processed

4.1 Technical data and log files

When accessing our services, technical information is automatically processed:

  • IP address
  • device and operating system information
  • browser type
  • time of access
  • duration of use
  • referrer URL

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in system security, stability, and abuse/fraud prevention)

Where possible, this data is stored in anonymized or pseudonymized form.

4.2 Registration and profile data

  • name (or pseudonym, where applicable)
  • email address
  • password (stored encrypted)
  • role information (e.g. student, teacher)
  • assigned modules / courses

Legal basis: Art. 6(1)(b) GDPR (performance of a contract)

4.3 Usage and learning data

In the course of use, the following is processed:

  • learning times
  • learning progress
  • learning status
  • learning forecasts
  • answered questions
  • created questions
  • interactions with modules
  • aggregated analytics data

This processing serves to provide personalized learning features and to optimize didactics.

Legal basis: Art. 6(1)(b) GDPR (performance of a contract), Art. 6(1)(f) GDPR (improving our services)

No automated decision-making within the meaning of Art. 22 GDPR takes place.

4.4 Payment and billing data

For paid offerings, we process the following data:

  • name
  • billing address
  • email address
  • VAT identification number (for institutional purchases)
  • product and subscription information
  • payment status
  • transaction ID
  • Stripe Customer ID

Legal basis: Art. 6(1)(b) GDPR (performance of a contract), Art. 6(1)(c) GDPR (statutory retention obligations)

5. Payment processing via Stripe

Payment processing is handled via:

Stripe Payments Europe Ltd.
1 Grand Canal Street Lower
Dublin, Ireland

Stripe processes payment data under its own data protection responsibility. Learn Battle does not store complete payment data (e.g. credit card numbers).

We receive only the transaction and subscription information necessary for contract performance, in order to:

  • associate payments with user accounts
  • manage subscriptions
  • fulfill tax obligations

Further information: stripe.com/privacy

6. Invoice data & retention

Invoice-relevant data is stored for up to 10 years in accordance with German commercial and tax law retention obligations (in particular §§ 238, 257 HGB; § 147 AO).

7. AI services (KISSKI and OpenAI)

Our digital products include optional AI features to assist with creating and optimizing learning content. Use of these features is voluntary.

7.1 Use of KISSKI

Provider
KISSKI is an AI service provided by: Gesellschaft für wissenschaftliche Datenverarbeitung mbH Göttingen (GWDG), Burckhardtweg 4, 37077 Göttingen, Germany.

Privacy policy: kisski.gwdg.de/datenschutzerklaerung

Type of data processed
When using the AI feature, the following data is processed:

  • text entered by the user (prompts)
  • generated responses
  • technical metadata (e.g. time of the request)
  • IP address, where applicable (technically required to provide the service)

We do not transmit any specifically collected personal data. Users are expressly advised not to enter personal or sensitive data (Art. 9 GDPR) into AI prompts.

Purpose of processing: generating learning content, assisting with question creation, didactic optimization of teaching and learning processes.

Legal basis: Art. 6(1)(a) GDPR (consent), where use is optional, additionally Art. 6(1)(b) GDPR, where the AI feature is part of the contractually owed service. Consent can be revoked at any time.

Responsibility: Learn Battle is the controller for the transfer of data to KISSKI. GWDG processes data in the course of providing the AI infrastructure in accordance with its own data protection provisions.

Third-country transfer: As things currently stand, processing takes place within the European Union. To our knowledge, no transfer to a third country outside the EU takes place.

Storage period: We store AI inputs only insofar as necessary for documentation purposes, quality assurance, or technical functionality. The storage period at KISSKI is governed by their own data protection provisions.

Note on data minimization: We expressly recommend not entering personal, sensitive, or confidential data into AI prompts.

7.2 Use of OpenAI

Provider
OpenAI, L.L.C., 3180 18th Street, San Francisco, CA 94110, USA.

Privacy policy: openai.com/privacy

Type of data processed
When using the AI features, the following is processed:

  • text entered by the user (prompts)
  • generated responses
  • technical metadata (e.g. time of the request)
  • IP address, where applicable (technically required to provide the service)

The same applies here: users should not enter personal or sensitive data into input fields.

Purpose of processing: generating learning content, assisting with question creation, content optimization of Learn Battle Studio.

Legal basis: Art. 6(1)(a) GDPR (consent), where use is optional, Art. 6(1)(b) GDPR (performance of a contract), where the AI feature is part of the booked scope of services.

Responsibility: Learn Battle is the controller for the transfer of data to OpenAI. OpenAI processes data under its own data protection responsibility in accordance with its privacy policy.

Third-country transfer: OpenAI processes data in the USA. The transfer is based on appropriate safeguards pursuant to Art. 46 GDPR (e.g. EU Standard Contractual Clauses). It cannot be ruled out that US authorities may gain access to data. An adequate level of data protection within the meaning of the GDPR therefore cannot be guaranteed in every case.

Storage period: Learn Battle stores AI inputs only insofar as necessary for functional purposes, documentation, or quality assurance. The storage period at OpenAI is governed by its own data protection provisions.

Note on data minimization: We strongly recommend not entering personal, sensitive, or confidential information into AI prompts.

8. Hosting

netcup GmbH
Daimlerstraße 25
76185 Karlsruhe
Germany

Server location: European Union. A data processing agreement pursuant to Art. 28 GDPR is in place.

Legal basis: Art. 6(1)(f) GDPR

9. Data transfer to teachers

Learning and learning-status data is transferred to authorized teachers only with the user's active consent. Consent can be revoked at any time.

Legal basis: Art. 6(1)(a) GDPR

10. Push notifications

Delivered via: Google Ireland Limited (Google Firebase Cloud Messaging)

Legal basis: Art. 6(1)(a) GDPR

Push notifications can be disabled at any time.

11. Storage period

Personal data is deleted as soon as:

  • the purpose no longer applies
  • statutory retention periods expire
  • a deletion request is made

User accounts are deactivated after a deletion request and permanently deleted once statutory obligations have expired.

12. Data subject rights

You have the following rights:

  • information (Art. 15 GDPR)
  • rectification (Art. 16 GDPR)
  • erasure (Art. 17 GDPR)
  • restriction of processing (Art. 18 GDPR)
  • data portability (Art. 20 GDPR)
  • objection (Art. 21 GDPR)

13. Security

We use appropriate technical and organizational measures (TOMs), in particular:

  • TLS/SSL encryption
  • access restrictions
  • role-based permission systems
  • regular security updates

14. Minor users

Insofar as our services are used by minors, the processing of personal data takes place only within the scope of statutory requirements. Where applicable, the consent of a parent or legal guardian is required.

15. Changes

We reserve the right to amend this privacy policy to reflect legal changes or adjustments to our services.

16. Contact

datenschutz@learn-battle.de

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