Privacy policy
Last updated: 5 October 2026
1. Data controller
Independence Blueprint di Nadine Tatiana Elena Proietto
Via Ruggero I il Normanno 6
95011 Calatabiano (CT), Italy
Phone: +39 377 277 4269
Email: deutsch.intensivkurs.online@gmail.com
Partita IVA: 06179920878
2. Website access and technical log data
When you visit this website, technically necessary connection data is processed so that the site can be delivered, protected against abuse and operated reliably. This may include your IP address, date and time of access, page URL, referrer, browser and device details, and technical security or log data.
The legal basis is Article 6(1)(f) GDPR. Our legitimate interest lies in secure, reliable and technically stable website operation and protection against misuse.
3. Hosting, CDN and security via Cloudflare
This website uses services provided by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare distributes the site through its network and provides security and protection services. It may therefore process the technical data described in section 2.
Cloudflare processes personal data according to its contractual privacy provisions. For self-service customers, Cloudflare's Data Processing Addendum (DPA) forms part of the contract. Cloudflare uses, among other measures, European Commission Standard Contractual Clauses (SCCs) for international transfers and participates in the EU–US Data Privacy Framework.
Further details: Cloudflare Data Processing Addendum · Cloudflare GDPR information.
Technical security and connection data is processed only for as long as required for the relevant technical or security purpose, or under the retention and deletion periods of the relevant Cloudflare service. This website does not create additional user profiles from its own server logs.
4. Cookies and related technologies
Microsoft Clarity is integrated as an optional analytics tool to understand website use and identify usability problems. Analytics cookies are used only with express consent; advertising tracking has not been enabled on this website.
Cloudflare may use technically necessary cookies or similar mechanisms as part of its active networking and security services. These are necessary to deliver and protect the site and are not used for advertising or profiling.
Consent is requested before Microsoft Clarity analytics cookies are used. The legal basis is consent under Article 6(1)(a) GDPR, which you can withdraw at any time with future effect. To reset your choice, see our cookie information.
5. Microsoft Clarity
We use Microsoft Clarity, a web analytics service from Microsoft, to analyse interaction with this website. It may process page views, clicks, scrolling, mouse movements, device and browser information, heatmap data and session reconstructions. Reconstructions are technical representations based on observed page interactions, not ordinary video recordings.
With consent, Clarity may set cookies to recognise users or sessions. Without consent, Clarity operates in Microsoft's restricted no-consent mode without cross-session Clarity cookies. For further information see the Microsoft Clarity documentation and Microsoft privacy statement.
6. Contact by email and enquiry forms
The enquiry forms on this website currently do not save submitted data on a separate web server. When users submit a course enquiry, callback request or free mock-exam request, WhatsApp or WhatsApp Web opens with a pre-filled message. Data is sent only when that message is actually sent in WhatsApp. The provider's privacy terms also apply.
Only details that you voluntarily submit are processed, such as your name, email, phone, company, German level, desired lesson format, preferred course period and message.
For course or contractual enquiries, the legal basis is Article 6(1)(b) GDPR (pre-contractual steps). For general questions, the basis is Article 6(1)(f) GDPR and our legitimate interest in responding to your enquiry.
Information is deleted when the enquiry has been fully processed, unless statutory retention obligations or other legitimate grounds require longer retention. If a contract is concluded, data relevant to the contract or invoicing may be retained under statutory rules.
Scheduling with Calendly and Google Meet
We offer free consultation booking through Calendly (Calendly LLC). When you submit the consultation form and proceed to choose a time, we pass the information you have entered (name, email and required or optional contact, course and learning-goal details) to Calendly to schedule and prepare the appointment. Availability is checked against connected Google Calendars; the contents of private calendar events are not disclosed to invitees. Meetings take place through Google Meet, and necessary scheduling data is also processed by Google. The legal basis for processing your pre-contractual enquiry and arranging the consultation is Article 6(1)(b) GDPR. The Calendly booking widget is loaded only after you have submitted the form and acknowledged the privacy notice; Calendly may use cookies or similar technologies. For details, see Calendly's privacy policy and Google's privacy policy.
7. Email service: Gmail
We use a Google Gmail mailbox for business email communications. Emails sent to the address on this website, including their contents and technical communication data, are therefore also processed via Google's systems.
Microsoft states that personal data may also be processed internationally, using safeguards including Standard Contractual Clauses and the EU–US Data Privacy Framework. Further information: Microsoft privacy statement.
8. Telephone and WhatsApp
If you provide a telephone number and expressly request contact by phone or WhatsApp, we can communicate through your selected channel. WhatsApp is provided by WhatsApp Ireland Limited. It processes account, connection and metadata needed for the service. WhatsApp states that personal messages and calls are end-to-end encrypted.
The legal basis is Article 6(1)(b) GDPR for pre-contractual enquiries, or Article 6(1)(f) GDPR for general enquiries. Further details: WhatsApp privacy policy for the European region.
9. Course and contractual data
When an enquiry leads to a booking or contract, we process the information necessary for delivering, organising, communicating about and invoicing the course. The legal basis is Article 6(1)(b) GDPR. Where accounting, taxation or recordkeeping obligations apply, Article 6(1)(c) GDPR also applies.
Recipients are limited to service providers or organisations needed for the transaction, such as communication, hosting or payment providers and, where appropriate, accountants or tax advisers. Data-processing agreements are used where required.
10. Payment processing
Live courses are currently not paid for via an external checkout on this website. After written booking confirmation, participants receive payment information. Payment is by bank transfer or PayPal, and an invoice is issued by Deutsch Intensivkurs / Independence Blueprint after payment is received.
For bank transfers, the involved banks process the details required for payment. PayPal processing is provided by PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg. For further information, consult the PayPal privacy policy. An external checkout may be introduced in future for separate digital products. This policy will be updated before such a service is activated.
11. Appointments via Calendly, Google Calendar and Google Meet
We may use Calendly to arrange free consultations. Availability may be checked against connected Google calendars and video meetings may take place through Google Meet. Data processed can include your name, email address, appointment date and any details you provide about your enquiry or learning goals. The legal basis for processing a pre-contractual enquiry is Article 6(1)(b) GDPR. Loading Calendly may involve cookies or similar technology in accordance with the service's terms and applicable preferences.
Calendly privacy policy · Google privacy policy
12. Placement tests and exam simulations
Depending on the features used, creating an account and taking a placement test or exam simulation can involve processing your first and last name, email address, a cryptographic password hash (not the password in plain text), test identifier, answers, scores, written responses, progress, results and the date and time when the privacy policy was acknowledged. If provided, exam goals, the level or courses of interest may also be processed. Completed attempts may be saved in a personal archive. When enabled, the application may also record which simulation was opened and the date and frequency of access.
According to the documented application setup, test data is stored in a Cloudflare D1 database configured for Western Europe (EU). Where international data transfers occur, applicable safeguards, including European Commission standard contractual clauses, apply. IP addresses associated with failed login attempts may be processed temporarily for account security; a 15-minute lockout is planned after repeated failed attempts.
The legal basis for an account, a requested test and stored results is Article 6(1)(b) GDPR; access security relies on Article 6(1)(f) GDPR. Acknowledging a privacy policy is not consent. Permission to be contacted about test results must be optional, separate and withdrawable (Article 6(1)(a) GDPR), and does not authorise promotional messages.
Test data is intended to be deleted 24 months after the last login once the automated deletion procedure has been activated and verified. Until that procedure is technically confirmed, deletion is handled on request and through administrative checks. Statutory retention obligations are unaffected.
13. Recipients, international transfers and retention
Depending on the services used, data may be shared with providers of infrastructure, security, communications, appointment booking, teaching tools and payment services, accountants or competent authorities where required by law. Transfers outside the European Economic Area are subject to the safeguards under Articles 44 et seq. GDPR.
Messages and enquiries are retained for as long as necessary to respond and undertake legitimate checks; invoices, accounting and contract records follow the legally required retention periods. The test-data rules above apply to test results, while security data and cookie choices are retained for their respective purposes according to the technical configuration.
14. No automated individual decision-making
This website currently does not carry out decision-making based solely on automated processing, including profiling, within the meaning of Article 22 GDPR.
15. Providing information
Providing personal data on the website is generally voluntary. However, to handle a course or company enquiry, we require contact details that enable us to respond. Without them, we may not be able to process the request.
16. Your rights
Subject to the legal requirements, you have rights including access (Article 15 GDPR), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20) and objection (Article 21). If we rely on consent in future, you may withdraw it at any time with future effect under Article 7(3) GDPR.
17. Right to complain
You may complain to a data protection supervisory authority. The relevant Italian authority for the business location is Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, Italy. Email: protocollo@gpdp.it, website www.garanteprivacy.it.
18. Changes to this privacy policy
This policy will be updated when the services used or the processing of personal data change, particularly before adding analytics, marketing, booking or payment services.
Current position: Cloudflare is integrated; Microsoft Clarity analytics uses consent management; advertising tracking is not enabled; live courses are paid for by bank transfer or PayPal following personal booking confirmation, with invoices issued after payment has been received.