1. General information
This data protection statement is between Wilhelm Digital GmbH (“Company”, “we” or “us”) and the user of our services (“you”, “your” or “customer”). By accessing or using our services, you agree to this statement. If you disagree, please stop using our services immediately.
We attach great importance to protecting and securing your personal data. This statement explains how we collect, use, store and protect your personal information when you interact with our platforms, including learning management systems, test simulations and related services.
By accessing or using our services, you consent to the collection and use of your data as described here.
2. Definitions
Platform: This includes, but is not limited to, providing a multilingual, communicative and interactive learning environment for teachers and learners: Tuees.de, Testgerman.de or similar platforms.
Customers: Organisations or businesses that enter into agreements with the Company to access and use our platform.
Learners: Individuals using the platform to access lessons, take quizzes and receive feedback, including to improve skills, prepare for certifications or achieve specific educational goals.
Teachers: Individuals or organisations using the platform to create, provide or manage lessons and educational content, including professionals, educators and organisations responsible for learning materials and monitoring progress.
Content: Any material, including text, images, videos and other data uploaded by customers, learners or teachers. By uploading content, you grant us a non-exclusive, worldwide licence to display and distribute it solely to provide and improve the services. This content may be shown to potential customers for demonstration and marketing purposes.
API: The API used for AI-assisted requests to large language models (LLMs) and for providing feedback.
Text-to-Speech API: Converts text to speech to promote accessibility and engagement.
Translation API: Translates input from learners or teachers into multiple languages to improve usability.
Performance Dashboard: A platform feature providing analytics and insights into learning progress and engagement.
Other tools: Customisable tools enabling users to use all platform functions securely.
Services: Providing AI-based, multilingual and interactive learning and learning management platforms or software for various purposes.
3. Information we collect
We collect the following types of personal data when you use our services:
Personal identification data: Name, email address, telephone number and other contact details.
Account information: Username, password, preferences and user settings.
Usage data: How you access and use the platform, including time spent, features used and pages visited.
Learning data: Enrolled courses, progress, quiz results and feedback.
Payment information: Where applicable, payment details for subscriptions or course fees.
4. How we use your data
We use personal data to provide, maintain and improve our platforms and services; personalise your learning experience and provide relevant content; communicate account notifications, updates and marketing materials (the latter only with your consent); process subscription or course payments where applicable; monitor and analyse usage and trends to improve platform functionality; and ensure compliance with our policies and legal obligations.
5. Sharing your data
We may share personal data with third parties in the following circumstances:
Service providers: Providers supporting platform operation, payment processing, email communications and data analysis.
Legal requirements: To meet legal obligations, such as subpoenas or requests from authorities.
Business transfers: Personal data may be transferred in a merger, acquisition or sale of assets.
6. Data retention
We retain personal data only for as long as necessary for the purposes in this statement or as required by law:
Account information: For the lifetime of your account.
Payment information: For 7 years under tax regulations.
Learning data: For the duration of your subscription plus 1 year for performance analysis, unless otherwise requested.
7. Your rights
Access: Request a copy of the personal data we hold about you.
Rectification: Request correction of inaccurate or incomplete personal data.
Erasure: Request deletion, subject to certain exceptions such as ongoing contractual obligations.
Objections and complaints: Object to processing for marketing or other legitimate interests. If you believe we have breached data protection law, you may complain to the German Federal Commissioner for Data Protection and Freedom of Information (BfDI) or your local supervisory authority.
Portability: Request a copy of your data in a structured, commonly used, machine-readable format.
User control: If you do not wish to use AI-based platform functions, you can terminate your contract under the agreed terms. AI functionality cannot be individually restricted or disabled for each user.
To exercise these rights, contact info@wilhelmdigital.de.
8. Cookies and tracking technologies
We use cookies and similar tracking technologies to improve your experience on our platforms. They help analyse usage, customise content and improve performance. You can control cookie settings through your browser. Disabling cookies may affect your experience.
9. Data security
We implement appropriate safeguards against unauthorised access, disclosure, alteration or destruction of personal data. However, no internet transmission method is completely secure, and we cannot guarantee absolute security.
10. AI, LLMs, text-to-speech, text-to-image and third-party APIs
Our services integrate artificial intelligence (AI), large language models (LLMs), text-to-speech (TTS), text-to-image (T2I) and third-party APIs to improve learning, optimise content delivery and provide personalised learning paths.
AI and LLM processing: We use these technologies to generate content, provide immediate exercise feedback and personalised recommendations. Models may analyse and process text you enter, including written answers or platform interactions, to support language learning.
Anonymised data: Anonymised or aggregated data may improve our models, develop the platform and support research. It cannot be traced back to individual users.
Data use: Submitted text may be temporarily processed to improve feedback or recommendation accuracy. Personal data is used for training only where explicitly stated and with your consent.
Retention: AI interaction inputs may be stored temporarily for performance improvement and quality checks. Where possible, data is anonymised and securely stored.
Automated decisions: Some functions may involve automated decisions, such as personalised learning paths or task assessment. Users may request human review, express their views or challenge decisions by contacting info@wilhelmdigital.de.
Text-to-speech: Entered text or displayed content may be processed to generate speech supporting pronunciation and listening comprehension. Audio may be temporarily stored for the session to facilitate interaction, but not beyond the necessary session duration unless explicitly stated.
Text-to-image: Entered text may be processed to create images or visual feedback for educational purposes. Data is used only for the specific request or task, not stored for other purposes. Generated images may be stored temporarily within the platform, but not permanently unless necessary for service functions, such as saving tasks or images.
Third-party APIs: We integrate translation, analytics, payment and other essential services. Interactions may transfer data to the relevant provider. We ensure APIs comply with applicable data protection rules and limit shared data to what is necessary for the API’s purpose. Providers must comply with strict privacy and security protocols and may use personal data only to deliver the requested services.
Data shared with APIs is subject to the providers’ privacy policies, which we recommend reviewing. All third-party providers are bound by strict contractual obligations, including GDPR-compliant data processing agreements (DPAs), to ensure data is used only for agreed purposes.
Security and privacy: We strive for high privacy standards across all integrations and take all reasonable measures to protect personal data. These technologies may involve processing by external providers. Absolute security cannot be guaranteed given the inherent risks of cloud technologies and APIs. Where possible, data used by AI and third-party APIs is anonymised to minimise identification risks.
11. Data breach notification
In the event of a data breach, you will be notified within 72 hours.
12. Data protection officer
Mustafa Aksoy – Chief Learning Officer has been appointed as the legal contact for data protection measures.
Email: maksoy@wilhelmdigital.de
13. International data transfers
Personal data may be transferred to and stored on servers outside your country of residence (AWS Cloud). By using our services, you consent to transfers to these locations, which may have different data protection laws.
For transfers outside the European Economic Area (EEA), we rely on standard contractual clauses (SCCs) or other legally recognised safeguards to provide an equivalent level of protection.
14. Children’s privacy
Our platforms are not intended for children under 16. We do not knowingly collect or solicit their personal data. If we discover such collection, we take steps to delete the data.
In certain circumstances, we require parental or guardian consent to collect or process data of users under 16. Parents or guardians may contact us to review, update or delete their child’s data.
15. Changes to this statement
We may update this statement to reflect changes in our practices or for operational, legal or regulatory reasons. Updates will be published on this page with a revised effective date. We recommend reviewing the statement regularly.
16. Agreement
By using our platforms and services, you confirm that you have read and understood this statement and agree to the collection, use and sharing described. If you disagree with its terms, please do not use our services.
17. Contact information
For questions or concerns about this statement or our data practices, contact:
Wilhelm Digital GmbH info@wilhelmdigital.de +49 15560 486455 HRB 9741
18. Legal bases under the EU GDPR
We process personal data in accordance with the EU General Data Protection Regulation on these bases:
Contract (Article 6(1)(b)): Meeting contractual obligations, including providing platforms and services, access, content or courses.
Consent (Article 6(1)(a)): Explicit consent where required, for example for marketing communications, optional AI features or certain sensitive data.
Legal obligation (Article 6(1)(c)): Compliance with applicable laws, including tax rules, record retention and lawful authority requests.
Legitimate interests (Article 6(1)(f)): Pursuing legitimate interests while respecting your fundamental rights and freedoms, including improving functionality and usability, analysing trends, securing platforms and detecting fraud or abuse.
Vital interests (Article 6(1)(d)): In rare cases, protecting your or another person’s vital interests, such as in health or safety emergencies.
Public interest or official authority (Article 6(1)(e)): Where applicable, performing a task in the public interest or exercising official authority; this is generally not relevant to our activities.