Privacy Policy
Protecting your personal data is important to us. Below we inform you about the nature, scope and purpose of the processing of personal data when you use the Teloquia platform.
1. Controller
ELOQUIA GmbH, Kaiserstraße 10, 60311 Frankfurt am Main, email info@teloquia.com. For questions about data protection you can reach us at the same address.
2. Categories of data we process
- Account and profile data: name, email address and profile details.
- Tutor verification data: information on qualifications and teaching experience and, where applicable, identity documents used to verify tutors.
- Booking and communication data: bookings, lesson times, messages between learners and tutors, reviews and lesson notes.
- Credit and transaction data: purchased packages, credit balance and the internal ledger of movements (top-ups, redemptions, refunds, guarantee decisions, code redemptions) for accounting and dispute handling.
- Payment data: payments are processed via Stripe; card data is entered directly with Stripe and we do not store complete card data.
- Attendance data: a record of when a tutor joins the video room, used to process no-show reports and prevent misuse.
- Usage and technical data: e.g. IP address, browser type, access times and cookies/local storage for the provision and security of the platform.
When you visit the website, server log files are created (for example IP address, time, page called, browser and operating system). We use them for security and debugging. Short-term access logs are usually deleted after 14 days. Longer website analytics archives may remain for up to about six months unless deleted earlier. Application logs are trimmed separately.
3. Purposes and legal bases
We process data to provide the platform, to carry out bookings, payments and the credit system and for communication (Art. 6(1)(b) GDPR: performance of a contract), to safeguard legitimate interests such as security, fraud and abuse prevention and the enforcement of our terms (Art. 6(1)(f) GDPR), to comply with legal obligations such as tax retention (Art. 6(1)(c) GDPR) and, where required, on the basis of your consent (Art. 6(1)(a) GDPR).
Without the data needed for the contract and account (in particular name and email) we cannot conclude a contract or provide the platform. Optional details (for example profile photo, longer bio) you may skip; some features may then be limited. Where we rely on legitimate interests (security, abuse prevention, enforcing the terms), our assessment is that these do not override your rights in a way that bars the processing. You may object (see clause 9).
3a. Launch notification
While lessons can't be booked on Teloquia yet, you can sign up on our website to hear when they can. For this we store your email address, your chosen language, the time you gave your consent and the times you confirmed or unsubscribed. We use this data only for this one notification. The legal basis is your consent (Art. 6(1)(a) GDPR).
So that nobody can sign up someone else's address, we first send you an email with a confirmation link (double opt-in). The link is valid for 48 hours, and you're added to the list only once you click it. We delete unconfirmed sign-ups no later than 48 hours after the link expires.
You can withdraw your consent at any time with effect for the future, using the unsubscribe link in every one of these emails or by writing to info@teloquia.com. We delete your data once we've sent you the notification or you unsubscribe.
3b. Withdrawal and consent to an early start
If you withdraw from a contract using our withdrawal form, we process your name, your email address, the booking or order number, the date of the contract, any reason you choose to give and the time we received it. We use this to handle your withdrawal and send you a confirmation of receipt. We use your IP address only briefly to prevent misuse of the form. We don't store it with your withdrawal.
If you ask us, when booking a lesson or buying an hour package, to start before the withdrawal period ends, we store the time of that request with the booking or purchase. This lets us prove it later.
The legal basis is Art. 6(1)(c) GDPR in conjunction with Sections 355 et seq. and 356a of the German Civil Code (BGB), and Art. 6(1)(b) GDPR. ELOQUIA GmbH processes the data. We send the confirmation email through our mail server provider BlackPoint GmbH (see section 4).
We keep this information until the statutory limitation period ends, which is three years from the end of the year in which the withdrawal or request was made. If a withdrawal affects an invoice or refund, we keep the related accounting records for as long as commercial and tax law requires.
4. Recipients and service providers
- Sharetribe: platform and hosting infrastructure for the marketplace.
- Stripe: payment service provider for processing payments.
- BlackPoint GmbH: mail server (eloquia2.bpaserver.net) for sending our emails, such as booking reminders and the confirmation email for the launch notification.
- The integrated video service "Jitsi as a Service" (JaaS), operated by 8x8, Inc. (USA), for delivering the video lessons (see clause 5).
- Groq, Inc. (USA) for optional lesson transcription and AI features (see clause 10).
These providers process data on our behalf as processors or, in the case of payment processing, as independent controllers. We conclude data processing agreements where required.
5. Video lessons
Lessons are delivered through an integrated video service: "Jitsi as a Service" (JaaS) provided by 8x8, Inc. (USA). When you join a lesson, audio, video and technical connection data (e.g. IP address) are processed by that service in order to establish the call. Depending on the service, data may be processed on servers outside the EU. We record only the fact and time that a tutor joined the room (attendance), not the content of the lesson. Please avoid sharing sensitive information in the video call and do not record without the consent of all participants.
6. Cookies and local storage
We use our own cookies and browser storage for login, language, security and checkout. For traffic measurement we use Plausible on our own server (analytics.teloquia.com), without third-party advertising cookies. Google Analytics is off. There is currently no separate consent banner for optional cookies.
7. International data transfers
Some providers may process data outside the European Economic Area, in particular Stripe (payments), 8x8/JaaS (video lessons) and Groq (optional AI and transcription). Where an adequacy decision or EU-US Data Privacy Framework participation applies, we rely on that; otherwise on appropriate safeguards, mainly the EU Standard Contractual Clauses. Sharetribe Oy (Finland) processes marketplace data as a processor; sub-processors may also sit outside the EU. BlackPoint GmbH runs the app and the mail server eloquia2.bpaserver.net in Frankfurt am Main.
8. Storage period
We store personal data only for as long as necessary for the stated purposes. Data relevant for accounting and tax (in particular payment and credit records) is retained for the statutory periods (generally up to 10 years). After the purpose ceases and any retention periods expire, data is deleted or anonymised.
Withdrawal information: see section 3b.
9. Your rights
You have the right to information, rectification, erasure, restriction of processing, data portability and objection. You can revoke consent you have given at any time with effect for the future. You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is the Hessian Commissioner for Data Protection and Freedom of Information.
We do not make automated decisions under Art. 22 GDPR that produce legal effects concerning you. Search sorting presents offers; it does not decide whether a contract is formed.
No data protection officer is appointed at present. Please send requests to info@teloquia.com. Competent supervisory authority: Hessian Commissioner for Data Protection and Freedom of Information, Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany, https://datenschutz.hessen.de
10. Artificial intelligence and lesson analysis
We use AI features to optionally analyse lessons, create practice and guidance, and offer placement and exam practice. AI does not replace a tutor.
Recording happens only if both the learner and the tutor consent for that lesson. Audio is sent for transcription and is not stored permanently. We store the transcript and a structured analysis (e.g. summary, key errors, vocabulary, level estimate). Both participants can view them. Consent can be withdrawn; that lesson's transcript is then deleted.
When signed in, other tools may send your inputs (e.g. practice text, chat turns, profile notes) to our AI provider to generate a response. You can turn AI tools off in settings (when available).
For transcription (Whisper) and, where configured, text models we use Groq, Inc., USA, as a processor. Processing may take place in the USA. Where no adequacy decision applies, we rely on appropriate safeguards such as the EU Standard Contractual Clauses, as for other providers named in this policy.
Lesson recording and AI analysis: consent (Art. 6 (1)(a) GDPR) of both participants. You may withdraw consent with effect for the future. Audio that has already been deleted cannot be restored.
Transcripts and analyses are deleted on a rolling basis after 90 days, or earlier on withdrawal. Other account data follows the general periods in this policy.
You have the right of access, rectification, erasure, restriction, portability and objection, the right to lodge a complaint with a supervisory authority, and the right to withdraw consent. Transcript deletion and AI opt-out will be offered in AI settings.
11. Contact
For questions about data protection you can reach us at info@teloquia.com.