Privacy Policy

1. Introduction

Protecting your personal data matters to us. In this privacy notice we explain which data is collected, processed and used in the “Besser Sprechen” app and when you visit this website, and how we protect your data. Sections 3 to 7 concern the app; what applies in addition when you visit this website is set out in section 7b. Besser Sprechen is intended for people aged 16 and over.

2. Controller

The controller responsible for data processing is:

3. What data is collected?

When you use the app, the following data may be processed:

• Usage data: interactions with the app (e.g. exercises opened, progress).
• Account data: email address and name; if you sign in with Apple or Google, the details you share there.
• Profile details: what you voluntarily enter in your profile, such as date of birth, your goals or a profile picture.
• Device data: information about your device (e.g. operating system, app version, IP address) as well as crash and error reports, for some sessions and in the event of errors with a screen recording of the app session.
• Install origin: whether you downloaded the app via an ad, with campaign and ad.
• Support requests: your message, attached photos and technical details about your device and app version.
• Health data (speech therapy): your answers in the medical history (anamnesis) of the practice area, such as complaints, their cause, previous treatment and your goals.
• Purchase data: information about subscriptions and in-app purchases you have made (e.g. Besser Sprechen Pro or Stimmcheck).
• Audio recordings (Stimmcheck): voice samples you submit as part of the “Stimmcheck” (voice check) service, and the coaches’ assessments.
• Recorder recordings (exercises): recordings you make during exercises to listen back to yourself. They are stored on our servers and remain there until you actively delete them.
• Data for practice access: if you apply for practice access for commercial use, additional data such as business contact details may be collected.

4. What is the data used for?

Your data is processed exclusively for the following purposes:

• Personalising exercise recommendations and content.
• Providing the app and improving its ease of use.
• Processing in-app purchases (e.g. via the App Store).
• Analysing usage behaviour to optimise the app.
• Detecting and fixing crashes and errors.
• Emails about your account and, if you allow it, news by email and notifications on your device.
• Providing the “Stimmcheck” service, including storing the voice sample and passing it on to the selected coach for assessment.
• Automatic analysis of your recordings: pronunciation analysis, transcription, feedback on exercises and exercise recommendations after a Stimmcheck.
• Checking and improving the accuracy of our pronunciation analysis using stored recordings and analysis results.
• Measuring which of our ads lead to installs and purchases.
• Answering your support requests.
• Speech therapy: exercise recommendations based on your anamnesis and, only with your separate consent, research in the field of speech therapy (section 7).

5. Legal basis for processing

The data is processed on the basis of:

• Art. 6(1)(b) GDPR: for the performance of a contract (e.g. providing the app’s features, processing purchases, carrying out the Stimmcheck).
• Art. 6(1)(f) GDPR: the provider’s legitimate interest (e.g. app analytics and optimisation, fixing errors, checking the accuracy of our pronunciation analysis, measuring the success of our advertising).
• Art. 6(1)(a) GDPR: your consent (e.g. for using the “Stimmcheck” voice assessment feature, storing recorder recordings, news by email or notifications on your device).
• Art. 9(2)(a) GDPR: your explicit consent for health data. The anamnesis answers are voluntary; you give them by filling in and saving the anamnesis, and you can delete them at any time in your profile under “Your data”.

For an account we need your email address; without it we cannot create an account. All other details are voluntary.

6. Storage and deletion of data

7. Disclosure of data

Your data is only disclosed to third parties if:

• you have given your express consent (e.g. passing the voice sample on to the selected coach as part of the Stimmcheck);
• it is necessary for the performance of a contract (e.g. payment providers such as the Apple App Store or Google Play Store for in-app purchases);
• it is required to comply with legal obligations (e.g. information provided to authorities).

Recorder recordings and Stimmcheck data are received only by the coach as part of the Stimmcheck (only with your consent), the speech recognition of Apple or Android, and our service providers for pronunciation analysis and AI analysis (section 11).

Device speech recognition

When you speak in the app, for example in exercises, during the microphone sound check or during onboarding, the app transcribes your words live, for instance to measure your speaking rate. On iPhone and iPad it uses the iOS speech recognition for this. Depending on the app version and on whether the language pack for the language is installed on your device, either your device recognises the speech itself or iOS sends the audio to Apple for recognition. For users in the European Economic Area, the United Kingdom and Switzerland, the recipient is Apple Distribution International Ltd., Hollyhill Industrial Estate, Cork, Ireland. Apple processes the audio as an independent controller in accordance with the Apple Privacy Policy. Apple may transfer the data to Apple Inc. in the USA and, according to Apple, relies on EU standard contractual clauses for this. The legal basis for the transfer is Art. 6(1)(b) GDPR, because the transcription is part of the feature. You can revoke the app’s access to speech recognition in the iOS settings under Privacy & Security > Speech Recognition.

On Android, from version 6.22 the app uses the Android speech recognition. If no language pack for the language is installed on your device, Android sends the audio to the speech recognition service selected in your Android settings. Here too, the legal basis is Art. 6(1)(b) GDPR.

Automatic analysis of your recordings

So that the app can assess your pronunciation and give you feedback, service providers for pronunciation analysis and AI analysis analyse your recordings or their transcripts on our behalf. What they receive is set out in section 11.

Research with Hochschule Bochum

Only if you give separate consent in the practice area does Hochschule Bochum (Bochum University of Applied Sciences) analyse your exercise data and anamnesis answers in pseudonymised form for research in the field of speech therapy. The legal basis is your consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR). You can withdraw it at any time with effect for the future in the settings of the practice area.

Install origin

To measure which of our ads work, the app on iPhone and iPad asks Apple whether you downloaded it via an ad in Apple Ads. The Android app before version 6.22 reads the install’s campaign details from Google Play and, from the Facebook or Instagram app, whether the install came from an ad on Meta. We store the campaign and ad details with your account and with our service providers for analytics and subscriptions (section 11). The legal basis is our legitimate interest in measuring the success of our advertising (Art. 6(1)(f) GDPR).

Sign in with Apple or Google

If you sign in with Apple or Google, the provider sends us your email address and your name, to the extent you share them there. Apple and Google process the sign-in itself under their own privacy policies. The legal basis is Art. 6(1)(b) GDPR.

Payment for Stimmcheck and coaching

If you pay for a Stimmcheck or a coaching session in the app or on this website, Stripe Payments Europe, Limited (Ireland) processes the payment; you enter your payment details directly with Stripe, and we do not receive them. Stripe transfers data to Stripe, LLC in the USA, which is certified under the EU-US Data Privacy Framework. For fraud prevention, Stripe is an independent controller. The legal basis is Art. 6(1)(b) GDPR.

7a. Waiting list for offers not yet launched

For offers that are still in preparation (currently group coaching), you can voluntarily put yourself on a waiting list. For this we store your email address, the chosen topic, the time of sign-up and of confirmation, and your IP address with our service provider for database and server functions (see section 11).

The sign-up only takes effect once you click the confirmation link in our email (double opt-in). Without this confirmation you will not receive any further messages. The legal basis is your consent (Art. 6(1)(a) GDPR); we additionally process the IP address on the basis of our legitimate interest in preventing abusive sign-ups (Art. 6(1)(f) GDPR).

We use your address exclusively to inform you about the launch of the respective offer, not for any other advertising. You can withdraw your consent at any time with effect for the future, informally by email to coaching@bessersprechen.app.

We delete your entry no later than twelve months after the offer launches, after you withdraw your consent, or if you have not confirmed the sign-up within 72 hours. The emails are sent via our email service provider (see section 11).

7b. Use of this website

Sections 3 to 7 describe processing in the app. The following applies in addition when you visit this website.

Audience measurement

To understand which pages are read and which references to our app lead to the goal, we use the analytics service PostHog (PostHog, Inc., USA). It records the pages viewed, the time of the visit, how far an article is read, and clicks on our links to the App Store and to Google Play. Technically, your browser also transmits your IP address and your browser identifier to PostHog. Your session is not recorded, and your clicks are not captured across the board, only at the points mentioned.

On your first visit, a notice at the bottom of the page asks whether we may store data in your browser by which we can recognise it. How we measure depends on your answer.

Because we neither store information on your device nor access information stored there for this count, no consent under Section 25 TDDDG (German Telecommunications Digital Services Data Protection Act) is required. The legal basis is our legitimate interest in data-minimising audience measurement (Art. 6(1)(f) GDPR). You can object to this processing under Art. 21 GDPR (see section 9); you can also prevent it technically by blocking requests to bessersprechen.app/klang, through which your browser sends the measurement data to PostHog.

With your consent (“Accept”), PostHog and our website store data in your browser, of these kinds: randomly generated identifiers with the associated measurement settings, by which we recognise your browser, in cookies and in local storage; information about your consent for PostHog in local storage; session data in session storage, such as a session identifier and, if you arrive via a campaign link, its origin (utm parameters). Your browser deletes the session data when you close the tab. Cookies expire after twelve months at the latest; what is in local storage remains until you withdraw consent or clear your browser data. When the notice refers to cookies, we mean all of these entries, including those in local storage and session storage. This lets us recognise returning visits over several days and see whether someone comes back after a few days and downloads the app. The legal basis is your consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR). You can withdraw it at any time with effect for the future (Art. 7(3) GDPR): via “Privacy settings” in the footer of every page and then “Decline”. PostHog and our website then remove these entries from your browser, only your choice remains (see next paragraph), and we count without storage again.

We store your answer to the notice in your browser’s local storage (entry “bessersprechen-consent-v1”) so that it does not reappear on every page. This storage is strictly necessary for the notice (Section 25(2) no. 2 TDDDG) and contains only your choice (“granted” for accepted, “denied” for declined).

On the pages you reach via a QR code or as a pure redirect to the app stores (/open, /landing, /download), we show no notice and always count without storage as described above.

On the pages you open from a confirmation or booking email, no audience measurement takes place. The analytics service is not loaded there.

Transfer to the USA

PostHog, Inc. is based in the USA, where the data is processed. The company is certified under the EU-US Data Privacy Framework; an adequacy decision of the European Commission therefore exists for the transfer (Art. 45 GDPR). In addition, we have concluded a data processing agreement with PostHog including EU standard contractual clauses (Art. 28, Art. 46 GDPR).

Hosting of the website

This website is run by a hosting provider in the USA. When a page is requested, the server processes technically necessary connection data such as IP address, time, requested address and browser identifier. The legal basis is our legitimate interest in the secure and trouble-free operation of the website (Art. 6(1)(f) GDPR). A data processing agreement is in place with it; the transfer is based on the EU-US Data Privacy Framework and standard contractual clauses.

8. Data security

We use technical and organisational measures to protect your data against unauthorised access, loss or misuse. These include transmitting your data in encrypted form.

9. Your rights

You have the following rights regarding your personal data:

• Right of access (Art. 15 GDPR): you can request information about the data processed.
• Right to rectification (Art. 16 GDPR): you can request the correction of inaccurate data.
• Right to erasure (Art. 17 GDPR): you can request the deletion of your data (e.g. voice samples or recorder recordings).
• Right to restriction of processing (Art. 18 GDPR): you can request that processing be restricted.
• Right to object (Art. 21 GDPR): you can object to the processing on legitimate grounds.
• Right to data portability (Art. 20 GDPR): you can request your data in a structured format.
• Right to lodge a complaint with a supervisory authority (Art. 77 GDPR): you can complain to a data protection supervisory authority about the processing of your data.

Your right to object: where we process your data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), you can object at any time on grounds relating to your particular situation. You can object to the use of your data for direct marketing at any time without giving reasons; we will then no longer use it for that purpose (Art. 21(2) and (3) GDPR).

To exercise these rights, please contact us at: hello@speakzmedia.de.

Without prejudice to any other remedy, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes the General Data Protection Regulation (Art. 77 GDPR). You can contact the supervisory authority of your place of residence, your place of work or the place of the alleged infringement. The authority responsible for us is:

10. Changes to this privacy notice

We reserve the right to change this privacy notice to adapt it to legal or technical developments. The current version can always be viewed in the app.

We send you news about the app by email if you allow it in the app (Art. 6(1)(a) GDPR). If you have bought something from us, we also inform you by email about our own similar offers (Section 7(3) UWG, German Act against Unfair Competition; Art. 6(1)(f) GDPR). You can object to both at any time, via the link in each of these emails or by email to hello@speakzmedia.de, without incurring any costs other than transmission costs at basic rates.

11. Data processing on our behalf

To provide our services, we use service providers as processors under Art. 28 GDPR. They process your data only on our behalf and for the stated purpose:

• Hosting, database and server functions: storage of your account, your data and recordings and operation of our server functions, as well as coaching bookings and the waiting list (section 7a). From app version 6.22 the servers are located in Frankfurt am Main, Germany; in earlier app versions, recordings and server functions are located in the USA.
• Pronunciation analysis and AI analysis: voice recordings from exercises with pronunciation analysis and the words of the exercise text; for feedback and exercise recommendations, transcripts, i.e. the text of your recordings and of your coach’s reply, your text in the exercise library and the analysis measurements. In app versions before 6.22 also the transcription of voice recordings for the Stimmcheck and the speech output of personal announcements in the Stimmcheck Light with your first name.
• Analytics: app usage, including the IP address, the approximate location derived from it and the install origin.
• Crash and error reports: reports from the app, for some sessions and in the event of errors with a screen recording of the app session.
• Subscriptions and in-app purchases: purchase and usage data and the install origin.
• Notifications and app updates: from app version 6.22, the device token for notifications and the text of the notification, which are passed on to Apple or Google for delivery, as well as delivery of app updates.
• Email delivery: emails from the app, the waiting list (section 7a) and coaching bookings.
• Video sessions: holding coaching sessions by video, with your name, your email address and the recording of the session.

Some of these service providers process data in third countries, above all in the USA. The basis is then the European Commission’s adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR) or EU standard contractual clauses (Art. 46(2)(c) GDPR); you can obtain a copy of the standard contractual clauses on request at hello@speakzmedia.de. For one provider of our pronunciation analysis in the USA there is no adequacy decision, and we cannot currently demonstrate a safeguard under Art. 46 GDPR.