Privacy Policy for lalabeth.com

Effective Date: 2025.01.01

1. Introduction

Purpose & Scope

This Privacy Policy describes how Lalabeth ("we," "us," "our"), the operator of the website lalabeth.com (the "Site"), collects, uses, shares, and protects your personal information when you visit or use our Site. "Personal data" or "personal information" refers to any information relating to an identified or identifiable natural person, as defined under applicable data protection laws like the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP).¹ This policy applies to all visitors and users ("you," "your") of the Site.

The Site offers free language learning resources.³ To support the provision of these free services, we display advertisements on the Site through Google AdSense.⁴ This policy explains how data is handled in relation to both the language learning resources and the advertising displayed.

Data Controller

The entity responsible for processing the personal data collected through lalabeth.com (the data controller) is:
Lalabeth.com
This identification is provided in accordance with transparency requirements under GDPR (Article 13)⁶ and FADP (Article 19).⁸

Swiss Representative (If Applicable)

The Swiss FADP requires controllers based outside Switzerland to appoint a representative in Switzerland if they process personal data of individuals in Switzerland related to offering goods or services, or monitoring their behavior, and if this processing is extensive, regular, involves high-risk profiling, or includes large-scale processing of sensitive data.⁹ Our use of Google AdSense involves cookies and tracking technologies to potentially monitor user behavior for personalized advertising¹¹, which could be considered monitoring or profiling under FADP.⁹ Whether this triggers the requirement for a representative depends on the scale and nature of processing related to Swiss users.

Based on our current assessment of the scale and nature of our data processing activities concerning individuals in Switzerland, we have determined that the appointment of a Swiss representative under the FADP is not currently required. We will reassess this position periodically.

2. Contact Information

For any questions or concerns regarding this Privacy Policy or your data protection rights, please contact us using the following details:

• Email: privacy@lalabeth.com
• Postal Address: 12 Athol Street Douglas Isle of Man IM1 1JA
• Contact Form: You may also reach us via the contact form available on our Site.³

Providing clear contact information ensures you can easily exercise your rights and make inquiries as required by GDPR and FADP.⁶

3. Information We Collect

We collect various types of information to provide and improve our language learning services, communicate with you effectively, ensure the security of our Site, and display relevant advertising to support our free offerings. The types of information we collect fall into the following categories:

3.1. Information You Provide Directly:

• Contact Form Submissions: When you use the contact form on our Site, we collect the information you provide, such as your name, email address, and the content of your message.³ This allows us to respond to your inquiries.
• Future Interactions: Should we introduce features like user accounts, newsletter subscriptions, or community forums in the future, we would collect the information you provide during registration or participation.

3.2. Information Collected Automatically:

When you access and interact with the Site, we automatically collect certain information about your device and usage patterns. This is a standard practice for most websites and online services¹⁴ and includes data that may be collected by our partners like Google.¹¹ This information includes:

• Log Data: Your Internet Protocol (IP) address, the type and version of browser you use, your operating system, the web page you visited before coming to our Site (referring URL), the pages you visit on our Site, the time and date of your visit, the time spent on those pages, and other standard server log information.¹¹
• Device Information: The type of device you use (e.g., desktop computer, mobile phone, tablet), device model, unique device identifiers (such as advertising IDs where applicable and consented to), screen resolution, language settings, and other device characteristics.¹¹
• Usage Data: Information about how you navigate and interact with our Site, including the links you click, the features you use, your language preferences, and other actions you take while using the service.¹⁴
• Approximate Location Information: We may infer your general geographic location (e.g., country, city) based on your IP address.¹⁴ This helps us understand our audience distribution, analyze usage patterns, and potentially tailor content or advertising based on broad geographic regions.¹⁶

3.3. Information Collected via Cookies and Similar Technologies:

We and our third-party partners use cookies (small text files stored on your device) and similar tracking technologies (like web beacons, pixels, scripts) to collect information automatically, enhance site functionality, analyze usage, and support advertising efforts.⁵ Detailed information about our use of these technologies is provided in Section 6 ("Cookies and Similar Technologies") below. Google AdSense, in particular, relies on these technologies to serve ads.⁵

4. How We Use Your Information (Purposes of Processing)

We process the information we collect for specific purposes, ensuring transparency as required by data protection laws like GDPR and FADP.¹ These purposes include:

• To Provide and Maintain Our Service: To operate the lalabeth.com website, deliver the free language learning resources and content, and ensure the Site functions correctly.³
• To Improve Our Service: To analyze how users interact with the Site (e.g., using analytics data), understand user needs and preferences, identify areas for improvement, optimize website design and content, and troubleshoot technical issues.¹¹
• To Communicate With You: To respond to your inquiries, feedback, or requests submitted through our contact form³ or other communication channels. We may also send important administrative messages regarding the service, if necessary.
• To Personalize User Experience: To remember your settings and preferences (such as language choice) to provide a more tailored experience during subsequent visits.¹⁴
• To Provide Advertising (Google AdSense):
  • To display advertisements on the Site, which helps us fund the provision of free language learning resources.⁴
  • To enable Google and its advertising partners to serve personalized advertisements based on your inferred interests and your visits to our Site and other websites across the internet. This relies heavily on advertising cookies, such as the DoubleClick cookie.⁵
  • To serve non-personalized (contextual) advertisements when you have not provided consent for personalized ads, or if you have withdrawn consent.¹⁹
  • To measure the effectiveness of advertisements, control the frequency with which you see ads (frequency capping), and detect and prevent advertising fraud and abuse.¹¹
• For Security Purposes: To monitor for and prevent fraudulent activities, security breaches, and technical issues, ensuring the integrity and security of our Site and user data.¹¹
• To Comply with Legal Obligations: To fulfill our legal and regulatory requirements, respond to lawful requests from public authorities (such as subpoenas or court orders), and enforce our terms and policies.¹¹

5. Legal Basis for Processing (GDPR & FADP)

We only process your personal data when we have a valid legal basis to do so under applicable data protection laws, including the GDPR and the Swiss FADP. While the FADP generally permits processing unless it unlawfully infringes personality rights, the GDPR requires identifying a specific lawful basis beforehand.⁹ Furthermore, Google's EU User Consent Policy, which applies to users in Switzerland¹⁹, mandates obtaining explicit, GDPR-standard consent for the use of cookies and the processing of personal data for personalized advertising.²⁴ Therefore, we rely on the following legal bases depending on the specific processing activity:

• Consent: We rely on your explicit consent for:
  • Placing and accessing non-essential cookies and similar tracking technologies on your device, particularly those used for analytics, functionality, and advertising (including Google AdSense cookies).¹
  • Collecting and using your personal data for the purpose of delivering personalized advertising through Google AdSense and its partners.¹¹ This may be considered high-risk profiling under FADP, requiring explicit consent.⁹
  • Processing any sensitive personal data, should we ever collect such data in the future (currently, we do not anticipate collecting sensitive data as defined by FADP² and GDPR).
  • Sending direct marketing communications like newsletters, should we offer them in the future.
  You have the right to withdraw your consent at any time, as detailed in Section 11.
• Legitimate Interests: We process certain data based on our legitimate interests, provided these interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include:
  • Operating, maintaining, and securing our website and services.²²
  • Analyzing website usage through aggregated or anonymized data to understand user behavior and improve our offerings.¹¹
  • Responding to communications you initiate with us.
  • Preventing fraud, abuse, and security incidents.¹¹
  • Serving non-personalized (contextual) advertisements to support our free service.¹⁹ Note that even for non-personalized ads, consent is still required under Google's policy and ePrivacy rules for cookies used for frequency capping, ad reporting, and fraud prevention.¹⁹
• Contractual Necessity: If you enter into a contract with us (e.g., by creating a registered user account, if this feature becomes available), we will process data necessary to fulfill that contract.
• Legal Obligation: We may process your personal data when necessary to comply with a legal obligation to which we are subject, such as responding to lawful requests from authorities or meeting regulatory requirements.¹¹

6. Cookies and Similar Technologies

6.1. What are Cookies?

Cookies are small text files that websites store on your computer or mobile device when you visit them.⁵ They are widely used to make websites work, or work more efficiently, as well as to provide information to the site owners and third parties. Similar technologies like web beacons (or pixels) and scripts perform related functions.

6.2. How We Use Cookies:

Our Site uses different categories of cookies for various purposes:

• Essential/Strictly Necessary Cookies: These are required for the basic operation of our Site, such as enabling navigation, ensuring security, and managing user sessions. The Site cannot function properly without these cookies. Consent is generally not required for these, but we inform you about their use.
• Performance/Analytics Cookies: These cookies collect information about how visitors use our Site, such as which pages are visited most often, how users navigate the site, and if they encounter errors. This data is typically aggregated and anonymized and helps us understand usage patterns and improve the Site's performance. We require your consent to use these cookies.
• Functionality Cookies: These cookies allow the Site to remember choices you make (like your preferred language) and provide enhanced, more personal features. They help tailor your experience on the Site. We require your consent to use these cookies.
• Advertising/Targeting Cookies: These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns. These cookies track your Browse habits across websites. They are usually placed by third-party advertising networks, such as Google AdSense, with our permission. We require your explicit consent to use these cookies.⁵

6.3. Third-Party Cookies - Google AdSense:

We use Google AdSense to display advertisements on our Site, which helps support our free services. Google AdSense uses third-party cookies to facilitate ad serving.⁵ This is a requirement you should be aware of as per Google's terms.⁵

Specifically, Google and its partners use advertising cookies (including the DoubleClick cookie) to serve ads based on your previous visits to our Site and/or other websites you have visited on the internet.⁵ This enables the delivery of personalized advertising tailored to your likely interests.

For more information on how Google uses data when you use our Site, please review the following Google policies:

• How Google uses information from sites or apps that use our services: https://policies.google.com/technologies/partner-sites¹⁶
• Google's Advertising Technologies: https://policies.google.com/technologies/ads¹⁶
• Google's Privacy Policy: https://policies.google.com/privacy¹⁶

6.4. Managing Cookies and Opting Out:

You have several options to control and manage cookies:

• Cookie Consent Management: We utilize a consent management platform (CMP) to help you manage your preferences for non-essential cookies. When you first visit our Site, you will be presented with a banner allowing you to accept or reject different categories of cookies, or customize your choices. You can typically change your preferences at any time through a link or icon available on our Site. Using a Google-certified CMP is a requirement for displaying AdSense ads to users in Switzerland and the EEA/UK.¹⁹
• Browser Settings: Most web browsers allow you to control cookies through their settings. You can usually find these settings in the 'Options' or 'Preferences' menu of your browser. You can typically view existing cookies, delete them, and block cookies from specific sites or all sites. Please note that if you block essential cookies, some parts of our Site may not function correctly.
• Advertising Opt-Out Tools: You can opt out of personalized advertising from Google and other participating third-party vendors through the following tools:
  • Google Ad Settings: Manage your Google ad personalization preferences directly at: https://myadcenter.google.com/.¹²
  • Network Advertising Initiative (NAI): Opt out of interest-based advertising from NAI member companies at: https://optout.networkadvertising.org/.¹²
  • Digital Advertising Alliance (DAA): Opt out of interest-based advertising from DAA participating companies at: https://www.aboutads.info/choices/.¹²
  Opting out through these tools does not mean you will no longer see advertisements; it means the ads you see may be less relevant to your interests.

6.5. Cookie Consent (GDPR, FADP, Google EU User Consent Policy):

We are committed to obtaining legally valid consent before placing any non-essential cookies or similar technologies on your device, in compliance with GDPR, relevant FADP requirements, and Google's EU User Consent Policy.¹ As noted, Google's policy specifically requires publishers serving ads in Switzerland to use a Google-certified CMP that integrates with the IAB Europe Transparency and Consent Framework (TCF).¹⁹ Our use of such a CMP facilitates this compliance.

Your consent must be:

• Freely Given: You must have a genuine choice, and access to our service cannot be conditional on consenting to non-essential cookies.¹
• Specific: Consent is requested for specific purposes (e.g., analytics, advertising).¹
• Informed: We provide clear information about the types of cookies used, their purposes, and the third parties involved (see table below).¹
• Unambiguous: Consent requires a clear affirmative action from you (e.g., clicking "Accept" or selecting preferences). Pre-ticked boxes or inactivity do not constitute valid consent.¹
• Easily Withdrawable: You must be able to withdraw your consent as easily as you gave it, typically through our CMP.¹

6.6. Cookie Details:

The following table provides more detail on the main categories of cookies and similar technologies potentially used on our Site:

*Note: The specific cookies used may vary over time. Our Consent Management Platform provides the most current and detailed information about the cookies active during your visit and allows you to manage your preferences.*

7. Data Sharing and Disclosure

We do not sell your personal data. We may share your personal information with third parties only in the circumstances described below, ensuring transparency as required by GDPR and FADP¹:

• Service Providers: We engage trusted third-party companies and individuals to perform services on our behalf, such as website hosting, data analysis (e.g., analytics providers), technical support, and potentially communication services (e.g., email delivery if newsletters are implemented). These providers are granted access to personal data only to perform these tasks based on our instructions and are obligated to protect the data and not use it for other purposes.²
• Google (AdSense & Analytics): As described previously, we share information collected automatically (including via cookies, device identifiers, IP addresses, and usage data) with Google to enable the Google AdSense advertising service on our Site.⁵ If we use Google Analytics, usage data is also shared with Google for analytical purposes.¹¹ Google acts as an independent controller for much of the data processed for AdSense but may act as our processor for certain specific features.²⁰ We encourage you to review Google's policies (linked in Section 6.3) regarding their data use.
• Other Third-Party Advertisers/Networks: If we utilize other advertising networks or partners alongside Google AdSense, we will disclose this. Google's policies require transparency about such partners.¹² In such cases, these third parties may also collect information via cookies or similar technologies. We would provide information on these partners and links to their privacy policies, advising you to review them.
• Legal Requirements and Law Enforcement: We may disclose your personal information if required to do so by law, regulation, court order, subpoena, or other valid legal process, or in response to lawful requests by public authorities.⁷
• Business Transfers: If Lalabeth is involved in a merger, acquisition, asset sale, or other business transition, your personal information may be transferred as part of that transaction. We would notify you of any such change in ownership or control of your personal data.
• Protection of Rights and Safety: We may disclose information when we believe in good faith that disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of our users or the public, including enforcing our terms and policies or investigating potential violations.¹¹

8. International Data Transfers

Your personal information may be transferred to, stored in, and processed in countries outside of Switzerland and the European Economic Area (EEA), including the United States, where our third-party service providers, particularly Google, operate.¹¹ Data protection laws in these countries may differ from those in your jurisdiction.

We ensure that appropriate safeguards are in place for such international transfers in compliance with GDPR and FADP requirements.² These safeguards include:

• Adequacy Decisions: Transferring data to countries that have been deemed by the European Commission and/or the Swiss Federal Council to provide an adequate level of data protection.²
• EU-U.S. and Swiss-U.S. Data Privacy Frameworks (DPF): Relying on the DPF certification of US-based companies, such as Google LLC, which adhere to the DPF Principles for data transferred from the EEA, UK, and Switzerland.³¹ You can learn more about the DPF and view Google's certification on the DPF website.
• Standard Contractual Clauses (SCCs): Using SCCs approved by the European Commission (and recognized/adapted for transfers from Switzerland) in our contracts with third-party service providers when adequacy decisions or the DPF do not apply.² These clauses impose data protection obligations on the data recipient.

By using our Site, you acknowledge that your information may be transferred to and processed in these other countries under these safeguards.

9. Data Security

We take the security of your personal data seriously and implement reasonable technical and organizational measures designed to protect it from unauthorized access, disclosure, alteration, loss, or destruction.²¹ These measures are chosen based on the sensitivity of the data and the risks associated with processing, aligning with GDPR (Art. 32) and FADP (Art. 8) requirements.² We strive to incorporate principles like "privacy by design" and "privacy by default" where feasible.⁹

However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

10. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.¹ The criteria used to determine our retention periods include:

• The duration required to provide our services to you.
• The time needed to respond to your inquiries or resolve issues.
• Our legitimate business needs, such as maintaining records for analysis or security.
• Compliance with legal obligations (e.g., tax or accounting requirements).
• The duration relevant for potential legal claims (statute of limitations).

When personal data is no longer necessary for these purposes, we will securely delete or anonymize it.¹¹

11. Your Data Protection Rights (GDPR & FADP)

Under the GDPR and the Swiss FADP, you have certain rights regarding your personal data. These rights are largely similar under both laws.³⁰ We are committed to facilitating the exercise of these rights:

• Right to Access: You have the right to request confirmation as to whether we process your personal data and, if so, to access that data and receive information about how it is processed.¹
• Right to Rectification: You have the right to request the correction of inaccurate personal data concerning you and to have incomplete data completed.¹
• Right to Erasure ('Right to be Forgotten'): You have the right to request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes collected, you withdraw consent, or the data has been unlawfully processed.¹
• Right to Restrict Processing: You have the right to request the restriction of processing of your personal data under certain conditions, for example, if you contest the accuracy of the data or the processing is unlawful.¹
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.¹
• Right to Object: You have the right to object, on grounds relating to your particular situation, to the processing of your personal data based on our legitimate interests. You also have the absolute right to object to processing for direct marketing purposes.¹ Under FADP, this includes the right to object to automated individual decision-making, including profiling, that has legal or similarly significant effects.¹³
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.¹ You can typically withdraw cookie consent via our CMP.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a competent data protection supervisory authority if you believe that our processing of your personal data infringes applicable data protection laws.⁷ For users in Switzerland, the relevant authority is the Federal Data Protection and Information Commissioner (FDPIC) (https://www.edoeb.admin.ch/). For users in the EEA, you can complain to the authority in your Member State.

How to Exercise Your Rights:

To exercise any of these rights, please contact us using the contact information provided in Section 2 of this policy. We may need to request specific information from you to help us confirm your identity before processing your request. We will respond to your request within the timeframes required by applicable law (typically within one month under GDPR).

12. Children's Privacy

Our Site and services are not intended for or directed at individuals under the age of 18.³⁵ This age limit is set in alignment with Google AdSense Program requirements, which stipulate that publishers must be at least 18 years old to participate.³⁶ Furthermore, Google restricts the serving of personalized ads to users identified as being under the age of consent.²⁰

We do not knowingly collect personal data from children under 18. If you are a parent or guardian and you become aware that your child has provided us with personal data without your consent, please contact us immediately using the details in Section 2. If we become aware that we have collected personal data from a child under 18 without verification of parental consent, we will take steps to remove that information from our servers.

13. Links to Other Websites

Our Site may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top.

We encourage you to review this Privacy Policy periodically for any changes.¹ Your continued use of the Site after any changes constitutes your acknowledgment of the modified Policy.

15. Contact Us

If you have any questions about this Privacy Policy, please contact us using the information provided in Section 2.