Babbel
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Source provenance
Verified official sourceSnapshot hash bb96536e73a0436f7afa1e0267f189cebd7c4aa764ce6442baa8fca5ed3e66a6
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Plain-English summary
Babbel's Privacy Policy indicates several areas of potential concern for users. The policy itself may be updated without direct notification, requiring users to proactively check the website for changes. A significant concern is Babbel's right to process personal data based on its own or a third party's legitimate interests, which could potentially override users' own interests or fundamental rights (risk_flags-2). Furthermore, user behavior data and identifiers from the app are collected and transmitted to third-party providers for marketing and advertising activities (risk_flags-3). User-contributed feedback and information from studies might be published on Babbel's website and other marketing channels for promotional purposes (risk_flags-4). More critically, Babbel tracks website behavior and shares detailed event data (including IP addresses and user IDs) with advertising partners and social media platforms as joint controllers for targeted advertising. While jointly responsible for data collection, Babbel explicitly states it has "no influence on further data processing activities by the advertisement partner" once the data is transferred (risk_flags-5, risk_flags-6), which could lead to broader data use than users anticipate. Regarding data processing, voice recordings may be transcribed and processed with AI for learning measurement, pronunciation review, and personalizing the learning experience, with some shared with AI providers for transcription (data_use-1). While some recordings are deleted, the transcriptions can be stored. Finally, if users access Babbel through their employer, the platform may provide usage reports to the employer detailing app usage, content access, and live class participation (gotchas-1). For questions regarding this, users are directed to their employer, potentially complicating privacy inquiries (gotchas-2).
90% confidence
Clauses that indicate potential for significant user harm, financial loss, or privacy erosion.
Babbel states that they may update their Privacy Policy periodically by publishing a new version on their website.
Why it matters: Users need to actively check the website for updates to the Privacy Policy as Babbel may change it from time to time.
We may update this Policy from time to time by publishing a new version on our website.
Babbel states they process "Personal Data" if the processing is necessary for the protection of their legitimate interests or the legitimate interests of a third party, unless user interests or fundamental rights and freedoms override these.
Why it matters: Babbel's legitimate interests or those of a third party may allow them to process a user's personal data, potentially overriding the user's interests or fundamental rights if those rights are not deemed to override the legitimate interest.
(iv) if the processing is necessary for the protection of our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms requiring the protection of your Personal Data override these, or
Babbel collects pseudonymized user behavior on the app, including server log files, IP addresses, and user IDs, some of which are assigned by or provided to third-party providers, for marketing and advertising activities on Babbel and third-party services.
Why it matters: This means that data about users' behavior on the app, such as IP addresses and user IDs, can be shared with and used by third-party providers for targeted advertising, potentially leading to increased exposure to ads based on their app usage.
Engaging in marketing and advertising activities on Babbel and on third-party services (therefore, persistent identifiers may be collected by, and/or transmitted by Babbel to, such third-party providers through our services via pixels, cookies and other tracking mechanisms);
Babbel processes feedback and information from user studies, research projects, surveys, or (video) interviews, and this information may be published on their website and other marketing channels for promotional purposes.
Why it matters: If users participate in studies or provide feedback, their information might be used publicly by Babbel for promotional purposes, which could expose their opinions or participation to a wider audience, even if anonymity is maintained for some data in other contexts.
Publication on our website and other marketing channels for promotional purposes;
Babbel processes information about how users behave on their websites, including IP address, user IDs, device information, internet connection, non-precise geolocation, and interaction data (event data). This event data, collected via pixel tracking, is transmitted to and analyzed by third-party platforms, particularly social media platforms, for targeting advertisements, improving ad delivery, personalizing content, and enhancing product advertisements.
Why it matters: User behavior on Babbel's websites, including event data like page views and click behavior, is collected and shared with advertising partners and social media platforms. These third parties then use this data to target advertisements and personalize content, meaning users will see ads tailored to their browsing habits across different platforms, often without full control over this joint processing.
This includes the event data collected via pixel tracking as part of conversion tracking which is used for targeting our advertisements, improving ad delivery on third-party platforms (particularly social media platforms), personalizing features and content, and enhancing the advertisements of our products on third-party platforms. For this purpose, the event data collected on our website via the pixel is transmitted to and analyzed by the providers of these platforms (particularly social media platforms). The collection and transmission of event data are carried out jointly by us and the platform providers as joint controllers.
Babbel transfers personal data collected from user visits to their websites to advertising partners. These partners then determine whether and which advertisements are displayed on the user's device. Babbel is jointly responsible for the collection of this personal data but states that they do not influence further data processing activities performed by the advertising partner.
Why it matters: Once Babbel transfers user personal data to advertising partners, they lose control over how their data is further processed or used by these partners for advertising purposes. This means that advertising partners can use the data in ways Babbel does not control, potentially leading to broader use of personal data than anticipated.
Joint controllership is also relevant for data processing activities regarding advertising campaigns. In those cases, we transfer your personal data collected on our websites to our advertising partners, which then decide whether to display an advertisement and, if yes, which ad should be displayed on your device. We are jointly responsible with our advertisement partner regarding the collection of your personal data. However, we have no influence on further data processing activities by the advertisement partner.
Clauses that describe how the company collects, uses, and shares user data, especially personal data.
Babbel processes information about learning behavior, personal vocabulary, and learning progress, which includes content and (transcriptions of) voice recordings. Voice recordings may be transcribed and processed with AI for measuring learning, reviewing pronunciation, and personalizing the learning experience, including conversational language learning features. For conversational features, voice recordings will only be shared with AI providers for transcribing purposes and deleted after transcription, though the transcription itself can be stored.
Why it matters: User voice recordings can be processed using AI for various purposes, including being transcribed and used to measure learning, review pronunciation, and personalize the learning experience. While some recordings are deleted after transcription, the transcriptions themselves can be stored, potentially raising concerns about the retention and use of spoken data. Additionally, voice recordings may be shared with AI providers for transcription.
Provision of conversational language learning features. When you use a learning feature that enables AI-powered real-time conversations, transcriptions of voice recordings will be processed. Voice recordings will only be shared with AI providers for transcribing purposes and will be deleted after transcription. The transcription itself can be stored and used for later conversations
Babbel uses anonymized voice recordings for speech analysis and the further development of internal machine learning or other learning features.
Why it matters: While voice recordings are anonymized, they are still used to improve Babbel's AI and learning features. This use is generally low risk given the anonymization, but it represents ongoing processing of user data.
Anonymization of voice recordings for speech analysis and further development of internal machine learning or other learning features;
Babbel processes pseudonymized information about how users behave on their app, which includes server log files, IP addresses, and user IDs. Some of these identifiers are assigned by or provided to third-party providers.
Why it matters: Even though this information is pseudonymized, its connection to third-party providers for app behavior tracking could mean that some user behavior, network data, and identifiers are shared, which could potentially be linked back to users if combined with other data, though this is mitigated by pseudonymization.
We process pseudonymized information about how you behave on our app. This includes server log files, IP addresses, and user IDs, some of which are assigned by or provided to third-party providers.
Clauses that describe how subscriptions or services can be cancelled or renewed, including any associated fees or conditions.
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If a user accesses Babbel through their employer, Babbel may process information about the user's service usage, such as app frequency, content access, and live class participation, and make this available to the employer in usage reports.
Why it matters: If you use Babbel through your job, your employer could monitor your app usage, including how often you use it, what content you access, and which live classes you attend. This could affect your privacy while using the service, as your learning activities may not be entirely private from your employer.
In case you use Babbel through your employer, we might process information about how you use our services in order to make this available to your employer in the form of usage reports. This includes, in particular, information about how often you use our app, what content you access via the app, and which live classes you have participated in.
Babbel states that transfers of usage reports to an employer will only occur if the employer confirms authorization to receive such reports and ensures a legal basis for the transfer (e.g., a learning agreement or user consent). Users are advised to contact their employer for any questions about this.
Why it matters: Your employer must confirm their authorization and a legal basis to receive usage reports of your Babbel activity. If you have questions about this data sharing, Babbel directs you to your employer, which means users may need to address a potentially sensitive privacy issue directly with their workplace.
Transfers to your employer will only take place if the employer confirms to us that they are authorized to receive such reports and ensures that there is a legal basis for the transfer (e.g. a learning agreement or your consent). If you have any questions about this, please contact your employer.
Clauses that offer explicit user benefits, control, or disclose protective actions by the company.
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