Privacy Policy

Privacy Policy

This Privacy Policy explains how Valentin Zach e.K. collects, uses, stores, shares, transfers, and protects personal data in connection with the Palabruno website, app, and related services.

Last updated: March 2026

This Privacy Policy explains how Valentin Zach e.K. ("Company", "we", "us", or "our") collects, uses, stores, shares, transfers, and protects personal data in connection with the website https://palabruno.com and https://palabruno.app, the mobile application Palabruno, and all related services, content, subscriptions, support, classroom-sharing features, exports, links, and AI-generated materials (collectively, the "Service").

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.

Controller

Valentin Zach e.K.

Äußere Passauer Straße 125

94315 Straubing

Germany

Email: vzach@vzach.com

Registered in the Commercial Register A of the Local Court of Straubing

Registration number: HRA 7221

Categories of personal data we collect

Depending on how you use the Service, we may collect the following categories of personal data.

Information you provide

  • name
  • email address
  • account information
  • login credentials
  • subscription information
  • support requests and communications
  • prompts, texts, notes, vocabulary lists, exercises, translations, uploads, screenshots, shared links, and other content submitted through the Service
  • teacher or classroom contact data, including recipient names, preferred contact method, group names, and records of previously shared materials

Automatically collected information

  • IP address
  • approximate geographic location derived from IP address
  • browser type and version
  • device type and operating system
  • app version
  • language settings
  • crash reports
  • diagnostics
  • usage data
  • cookies and similar technologies
  • log files

Payment information

Payments are processed by third-party providers such as Apple App Store, Google Play, Stripe, or similar payment providers. We do not store full payment card information. We may receive limited payment-related information such as subscription status, transaction identifiers, country, and billing confirmation.

How we use personal data

We may use personal data to provide, operate, and maintain the Service, create and manage accounts, generate AI-based content, enable sharing, exports, and classroom-related features, process subscriptions and payments, provide support, improve the Service, monitor usage and security, prevent fraud, abuse, infringement, and unauthorized use, comply with legal obligations, enforce our Terms of Service, communicate with you, and send marketing communications where you have consented.

Teacher and classroom features may involve the processing of limited student-related information solely for contact management, sharing, and classroom history purposes, including names, contact details, preferred contact method, group names, and records of materials previously shared with a particular student or group.

Such information is used only for contact management, sharing, and classroom history functionality and is not used to personalize, generate, train, or otherwise influence AI-generated content.

  • provide teacher and classroom functionality
  • create and deliver shared materials
  • send invitations, notifications, or communications designated by teachers
  • enable shared links, exports, and access management
  • maintain records of shared classroom content
  • prevent misuse, fraud, or unauthorized access

AI providers and user content

The Service may use third-party artificial intelligence providers to process prompts, text, translations, vocabulary, exercises, and other content submitted through the Service.

We may use third-party artificial intelligence providers located inside or outside the European Economic Area.

By using the Service and submitting content, you expressly consent to the transfer, processing, storage, and temporary retention of such content by those providers as reasonably necessary to operate the Service.

We seek, where commercially and technically feasible, to configure AI providers so that user content is not used to train public AI models. However, we cannot guarantee that all providers will permanently refrain from logging, retention, abuse monitoring, security review, or other internal processing.

If you use the Service as a teacher, tutor, school, or educational institution, you are solely responsible for ensuring that all student-related information submitted through the Service is processed lawfully and that all necessary permissions, notices, consents, and legal basis have been obtained.

Teachers and educational users should avoid uploading student-identifying information wherever possible and should instead use pseudonyms, initials, anonymized information, or internal identifiers.

You should not include student names, contact details, or other student-related information in prompts or content sent to third-party AI providers. Teacher contact and history data are intended solely for internal contact management and sharing features and should not be incorporated into generated content, prompts, or AI requests.

You must not submit through the Service any of the following unless strictly necessary and legally permitted.

  • sensitive personal data
  • health information
  • financial information
  • passport numbers
  • government-issued identifiers
  • passwords
  • information about minors
  • confidential third-party information
  • legally protected information

If you nevertheless submit such information, you do so entirely at your own risk.

Shared links, exported classroom materials, and similar functionality may allow access to content by any person who receives the relevant link or file. Users are responsible for controlling access to such materials.

We are not responsible for unauthorized disclosure, misuse, or onward sharing of classroom materials, exported content, student-related information, or shared links after such content has been created or shared by a user.

We are not responsible for the consequences of users voluntarily submitting sensitive, confidential, or legally protected information through the Service.

Sharing of personal data

We may share personal data with the following categories of recipients.

  • hosting and cloud providers
  • AI providers
  • analytics providers
  • payment processors
  • customer support providers
  • legal, accounting, and professional advisors
  • courts, regulators, law enforcement, and public authorities where legally required

We may share student-related information and recipient contact details with hosting providers, cloud providers, AI providers, email delivery providers, communication providers, analytics providers, and similar service providers where reasonably necessary to operate teacher, classroom, export, sharing, and communication features.

We do not sell personal data.

We do not share personal data with third parties for their own independent advertising purposes.

International data transfers

Because the Service is available worldwide, personal data may be transferred to and processed in countries outside the European Economic Area, including the United States.

Where required, we rely on safeguards such as adequacy decisions, Standard Contractual Clauses, and contractual, organizational, and technical measures.

By using the Service, you acknowledge that data protection laws in other countries may differ from those in your own country.

Retention of data

We retain personal data only for as long as reasonably necessary. Unless a longer retention period is required or permitted by law, the following retention windows may apply.

  • account information may be retained while your account remains active
  • support communications may be retained for up to 3 years
  • billing and accounting records may be retained for up to 10 years
  • logs, diagnostics, and security information may be retained for up to 12 months
  • prompts, generated content, exports, shared links, and related content may be retained for up to 24 months for support, abuse prevention, debugging, and improvement purposes

Student-related information, recipient names, preferred contact methods, group names, share history, shared classroom materials, shared links, and related communication records may be retained only for as long as reasonably necessary to provide the relevant teacher functionality, maintain account history, investigate misuse, respond to complaints, enforce our rights, or comply with legal obligations.

Such information may be deleted earlier when removed by the user, when no longer needed for the relevant teacher functionality, or after a prolonged period of account inactivity.

We may retain information longer where necessary to comply with law, enforce our rights, resolve disputes, defend against claims, or investigate fraud, abuse, or infringement.

Monitoring, removal, and disclosure

We reserve the right, but not the obligation, to review, monitor, filter, block, remove, preserve, investigate, or disclose content and information where reasonably necessary to comply with law, enforce our Terms of Service, protect our rights, users, or third parties, or investigate abuse, fraud, infringement, or security issues.

Cookies and similar technologies

The website and app may use cookies and similar technologies. Strictly necessary cookies may be used where they are required for the Service to function.

Optional analytics, personalization, advertising, and similar cookies would be used only if you provide consent.

The public website does not currently use analytics or advertising cookies. If optional cookies are introduced later, consent controls will be shown before they are used and a way to withdraw consent will be provided.

Marketing communications

We will send marketing communications only where you have consented or where otherwise permitted by law. You may unsubscribe at any time.

Security

We take commercially reasonable technical and organizational measures to protect personal data. However, no method of transmission, storage, or processing is completely secure.

Although we take commercially reasonable security measures, we cannot guarantee that shared links, exported materials, teacher-created content, or student-related information will never be accessed, forwarded, copied, or disclosed by unintended recipients after such content has been shared by a user.

To the maximum extent legally permitted, we disclaim liability for unauthorized access, data loss, theft, disclosure, or misuse unless directly caused by our intentional misconduct or gross negligence.

Children

The Service is not directed to children under the age of 16 without parental or guardian consent. If we become aware that personal data has been collected from a child without required consent, we may delete such information.

Your rights

Depending on applicable law, you may have the following rights.

  • access your personal data
  • request correction
  • request deletion
  • request restriction of processing
  • object to processing
  • withdraw consent
  • request portability
  • lodge a complaint with a supervisory authority

If you are located in the European Union, you may lodge a complaint with the competent data protection authority.

Changes to this Privacy Policy

We may modify this Privacy Policy at any time. The updated version becomes effective when published. Continued use of the Service after changes constitutes acceptance of the updated Privacy Policy.

Contact

Valentin Zach e.K.

Äußere Passauer Straße 125

94315 Straubing

Germany

Email: vzach@vzach.com

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