Privacy Policy
June 19, 2020 2025-08-06 14:32Privacy Policy
Effective Date: July 29, 2025
1. Introduction
This Privacy Policy explains how Tobin Ayres and Kailey Fenech GbR (“we,” “us,” or “our”) collects, uses, processes, and protects your personal data when you visit and use our website, quick-and-easy-english.com (the “Website”). We are committed to protecting your privacy and handling your data in an open and transparent manner, in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679.
Age Restriction: This Website and its services are intended for users who are at least 18 years old. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take steps to delete such information as soon as possible.
2. Who We Are (Data Controller)
Tobin Ayres and Kailey Fenech GbR
Max-Brauer-Allee 181, 22765 Hamburg, Germany.
Company VAT ID: DE 357961825
Contact Email for Privacy Inquiries: info@quick-and-easy-english.com
If you have any questions about this Privacy Policy or our data protection practices, please contact us.
Data Protection Officer (DPO):
We do not have a designated Data Protection Officer as per GDPR Article 37. Our data protection responsibilities are managed directly by the owners, Tobin Ayres and Kailey Fenech.
3. Personal Data We Collect
We may collect and process various types of personal data about you, depending on your interaction with our Website. This may include:
- Identity Data: Username, name (if provided in forms).
- Contact Data: Email address (for account creation, contact forms, newsletter subscriptions).
- Financial Data: Payment card details (processed by secure third-party payment processors; we do not store full card details on our servers), billing address.
- Transaction Data: Details about your membership plan purchases and payment history.
- Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website. This also includes data collected by Cloudflare Turnstile and Google reCAPTCHA for security purposes.
- Usage Data: Information about how you use our Website, including lessons accessed, pages viewed, links clicked, time spent on pages, and website navigation paths.
- Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
- Form Data: Information you provide when filling out our contact, feedback, or suggestion forms, which may include your name, email address, and the content of your message.
4. How We Collect Your Personal Data
We collect data through various methods:
- Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by email. This includes personal data you provide when you:
- Create an account on our Website.
- Sign up for a monthly or yearly membership plan.
- Make a payment for a subscription.
- Submit a contact, feedback, or suggestion form.
- Subscribe to our newsletter.
- Automated Technologies or Interactions: As you interact with our Website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. This also includes data collected by security and analytics services like Cloudflare Turnstile, Google reCAPTCHA, and Google Analytics. These services are only utilized when you have provided your consent through our cookie consent management system. Please refer to our Cookie Policy for more details on cookies and how to manage your preferences.
- Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties:
- Payment Processors: Stripe and PayPal provide us with transaction details (excluding full payment card numbers) necessary to confirm your purchases.
- Security Services: Cloudflare Turnstile and Google reCAPTCHA collect technical data about your interaction with our Website to distinguish humans from bots.
- Analytics Providers: Google Analytics provides us with aggregated usage data to help us understand website traffic and user behavior.
5. Purposes for Which We Will Use Your Personal Data and Legal Basis
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
| Purpose of Processing | Type of Data Used | Lawful Basis for Processing (GDPR Article 6) |
| To register and manage your user account and provide access to lessons. | Identity, Contact, Technical | Performance of a contract with you. |
| To process and deliver your membership plan, manage payments, and handle subscriptions. | Identity, Contact, Financial, Transaction | Performance of a contract with you. Necessary for our legitimate interests (to manage our financial operations and recover debts due to us). |
| To respond to your inquiries submitted via contact, feedback, or suggestion forms. | Identity, Contact, Form Data | Necessary for our legitimate interests (to provide customer support and improve our services). |
| To send you newsletters and marketing communications (if you have opted-in). | Contact, Marketing and Communications | Your consent. |
| To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). This includes using security services like Cloudflare Turnstile and Google reCAPTCHA. | Technical, Usage | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation. |
| To use data analytics (e.g., Google Analytics) to improve our Website, lesson content, customer relationships, and experiences. | Technical, Usage | Your consent (obtained via cookie consent management). Alternatively, for legitimate interests if anonymized data is used and a legitimate interests assessment has been conducted. |
| To comply with legal obligations, such as tax and accounting requirements. | Identity, Contact, Financial, Transaction | Necessary to comply with a legal obligation. |
6. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes described in section 5:
- External Third Parties:
- Payment Processors: Stripe and PayPal, for securely processing your payments.
- Security Services: Cloudflare Turnstile and Google reCAPTCHA, for website security and spam/abuse prevention.
- Analytics Providers: Google Analytics, for website usage analysis (only with your consent).
- Hosting Providers: For hosting our Website and storing data.
- Professional Advisers: Including lawyers, accountants, and auditors, who provide professional services.
- Authorities: German tax authorities, regulators, and other authorities who require reporting of processing activities in certain circumstances.
- Business Transfers: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International Transfers
We are based in Germany, within the European Economic Area (EEA). Our Website servers are located in the USA. Therefore, the processing of your personal data will involve a transfer of data outside the EEA to the USA. Additionally, some of our external third-party service providers (e.g., Stripe, PayPal, Google reCAPTCHA, Google Analytics) may also be based outside the EEA, so their processing of your personal data may involve further transfers of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers or transfer data to our servers in the USA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (Standard Contractual Clauses).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to the owners, Tobin Ayres and Kailey Fenech, and any necessary third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, financial transaction data may be retained for longer periods due to tax laws.
In some circumstances, you can ask us to delete your data: see “Your Legal Rights” below for more information.
10. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data (commonly known as a “data subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us at info@quick-and-easy-english.com.
11. Right to Withdraw Consent
Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
12. Right to Lodge a Complaint
You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. For Germany, you can find the relevant State Data Protection Authority (Landesdatenschutzbeauftragter) for your region. For example, for Berlin, it is the Berliner Beauftragte für Datenschutz und Informationsfreiheit. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
13. Cookies and Tracking Technologies
Our Website uses cookies and similar tracking technologies to enhance your experience, analyze site usage, and for security purposes. This includes the use of Cloudflare Turnstile, Google reCAPTCHA, and Google Analytics. These services are only utilized when you have provided your consent through our cookie consent management system. For detailed information on the cookies we use, their purpose, and how you can manage your preferences, please refer to our separate Cookie Policy which will be presented to you in Cookie Consent Banner upon your first visit to our Website.
14. Automated Decision-Making and Profiling
We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on individuals.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The “Effective Date” at the top of this policy indicates when it was last revised. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Website after any changes indicates your acceptance of the updated Privacy Policy.
