Privacy Policy

Last updated: May 26, 2026

This Privacy Policy explains how Verluma Academy, operated by Henrich Kotlán - Lektor (“Verluma Academy,” “we,” “us,” or “our”), collects, uses, stores, and protects personal information when you visit our website, purchase our digital courses, subscribe to our email communications, book private tutoring, or otherwise interact with our services.

Our website is: https://www.verlumaacademy.com/

Contact email:

hello@verlumaacademy.com

Verluma Academy is operated from Slovakia. Because the business is operated from a private home address, the full postal address is not published on this page for privacy and safety reasons. A suitable postal or business contact address may be provided upon a legally valid request where required.

This Privacy Policy is written mainly for users in the European Union and the European Economic Area, but it also applies generally to other visitors and customers where relevant.


1. Who is responsible for your personal data?

The data controller responsible for the processing of personal data described in this Privacy Policy is:

Verluma Academy
operated by Henrich Kotlán - Lektor
Slovakia
Email: hello@verlumaacademy.com

As the data controller, we decide why and how personal data is processed in connection with our services.


2. What services does this Privacy Policy cover?

This Privacy Policy applies when you:

·         visit verlumaacademy.com;

·         create an account or access course content through Podia;

·         purchase a prerecorded German course;

·         download or use course materials, including PDFs, vocabulary lists, phrase lists, exercises, and related learning materials;

·         book or purchase private tutoring lessons;

·         purchase a lesson package;

·         schedule a lesson through Calendly;

·         attend a private lesson through Zoom;

·         subscribe to the Verluma Academy newsletter or marketing emails;

·         contact us by email or through platform forms;

·         provide information about your German level, goals, exam preparation needs, learning background, or tutoring preferences.


3. What personal data do we collect?

The personal data we collect depends on how you interact with Verluma Academy.

3.1 Account and course data

When you purchase or access a course, we may process:

·         your name;

·         your email address;

·         your account login details or username, where applicable;

·         your purchased course or product;

·         your course access status;

·         your progress, activity, or account-related information available through Podia;

·         messages or support requests you send to us.

3.2 Payment and billing data

When you purchase a course, private lesson, or lesson package, payment may be processed through Stripe, PayPal, Podia, Calendly, or connected payment systems.

We may receive or process:

·         your name;

·         your email address;

·         billing details required for payment or receipts;

·         transaction information;

·         purchase history;

·         payment status;

·         refund or dispute information where relevant.

We do not intentionally store full credit card numbers or full payment card security codes ourselves. Payment information is handled by the relevant payment providers.

3.3 Private tutoring and booking data

When you book or request private tutoring, we may process:

·         your name;

·         your email address;

·         your selected lesson time;

·         your time zone;

·         your German level;

·         your learning goals;

·         your exam preparation needs, if any;

·         your learning background;

·         your preferred lesson focus;

·         information you write in booking forms or messages;

·         lesson package information;

·         attendance, rescheduling, or cancellation information.

3.4 Lesson notes

For private tutoring, we may keep limited lesson notes to provide better teaching support. These notes may include:

·         your approximate German level;

·         topics covered in lessons;

·         grammar or vocabulary areas to review;

·         learning goals;

·         progress notes;

·         planned next steps.

We do not use these notes for public profiling or advertising. They are used to support the tutoring relationship.

3.5 Zoom lesson data

Private tutoring may take place through Zoom. We may process information needed to conduct the lesson, such as your name, email address, Zoom display name, meeting details, and communication during the lesson.

We do not record private Zoom lessons by default. If a lesson were ever to be recorded, this would only happen with prior notice and appropriate consent where required.

3.6 Newsletter and marketing data

If you subscribe to our newsletter or agree to receive marketing emails, we may process:

·         your name, if provided;

·         your email address;

·         your subscription status;

·         email preferences;

·         information about whether emails were delivered, opened, clicked, or unsubscribed from, where this is available through the email platform.

You can unsubscribe from marketing emails at any time.

3.7 Communication data

If you contact us by email, forms, or platform messaging, we may process:

·         your name;

·         your email address;

·         the content of your message;

·         information needed to respond to your request;

·         any attachments or information you choose to send.

3.8 Technical and website data

When you visit the website, the platforms we use may automatically process technical information such as:

·         IP address;

·         browser type;

·         device type;

·         operating system;

·         pages visited;

·         date and time of access;

·         cookies or similar identifiers necessary for site functionality, security, preferences, checkout, account login, or platform operation.

At the time of this Privacy Policy, Verluma Academy does not intentionally use Google Analytics, Meta Pixel, TikTok Pixel, Google Ads tracking, or retargeting pixels.


4. Do we collect sensitive personal data?

We do not intentionally request or process special categories of personal data, such as information about racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, or sexual orientation.

However, students may sometimes choose to share personal information in messages or lessons. Please avoid sending sensitive personal data unless it is necessary for your request.

If you provide information about learning needs, exam goals, scheduling restrictions, or other circumstances, we will use it only as needed to provide the requested service.


5. Why do we process your personal data?

We process personal data for the following purposes:

5.1 To provide digital courses

We process personal data to create and manage your account, provide course access, deliver course materials, manage purchases, and offer support.

5.2 To provide private tutoring

We process personal data to schedule lessons, prepare lessons, provide personalized teaching, manage lesson packages, communicate with you, and track relevant learning progress.

5.3 To process payments

We process payment and transaction information to complete purchases, issue confirmations, manage refunds where applicable, prevent fraud, and meet accounting or tax obligations.

5.4 To communicate with you

We process contact and message data to answer questions, send course-related information, provide customer support, and manage administrative communication.

5.5 To send newsletters and marketing emails

If you subscribe or otherwise give appropriate permission, we may send you emails about German learning, course updates, offers, free materials, or Verluma Academy news.

You can unsubscribe at any time.

5.6 To improve our services

We may use limited information about customer questions, course usage, feedback, or lesson needs to improve our courses, website, customer experience, and teaching services.

5.7 To protect our business and users

We may process data to prevent fraud, maintain website security, resolve disputes, enforce our terms, or protect legal rights.

5.8 To comply with legal obligations

We may process and retain personal data where required by tax, accounting, consumer protection, legal, or regulatory obligations.


6. What legal bases do we rely on?

Where the GDPR or similar data protection laws apply, we rely on the following legal bases:

6.1 Contract

We process personal data when it is necessary to provide a service you requested or purchased, such as course access, private tutoring, lesson scheduling, payment administration, or customer support.

6.2 Consent

We rely on consent for certain optional activities, such as newsletter subscriptions, marketing emails where required, and any lesson recording if this were ever requested.

You may withdraw consent at any time. Withdrawal does not affect processing that took place before consent was withdrawn.

6.3 Legal obligation

We process and retain some data when required by law, for example for accounting, taxation, legal compliance, or responding to valid legal requests.

6.4 Legitimate interests

We may process personal data where necessary for our legitimate interests, provided those interests do not override your rights and freedoms. Examples include:

·         improving our courses and services;

·         responding to non-marketing inquiries;

·         keeping limited lesson notes for tutoring continuity;

·         maintaining security;

·         preventing misuse or fraud;

·         managing business records;

·         defending legal claims.


7. Which third-party services do we use?

We use third-party platforms to operate Verluma Academy. These providers may process personal data on our behalf or as independent controllers, depending on the service and context.

The main services we currently use are:

7.1 Podia

Podia is used for website hosting, course hosting, product pages, customer accounts, checkout, course access, digital downloads, and email/newsletter features.

7.2 Calendly

Calendly is used for scheduling private tutoring lessons and lesson packages. Calendly may process booking information such as name, email address, selected time, time zone, and answers to booking questions.

7.3 Zoom

Zoom is used to provide live private tutoring lessons online.

7.4 Stripe

Stripe is used to process card payments and related payment information.

7.5 PayPal

PayPal may be used to process payments and related payment information.

7.6 Google / Gmail

Gmail or Google services may be used for business email communication and administration.

These providers may process data in countries outside your country of residence. We rely on the safeguards, contractual terms, and privacy practices provided by these platforms where applicable.


8. International transfers

Some of the platforms we use may process or store personal data outside Slovakia, the European Union, or the European Economic Area.

Where personal data is transferred internationally, we rely on appropriate safeguards where required, such as contractual protections, data processing agreements, standard contractual clauses, adequacy decisions, or other mechanisms provided by the relevant service providers.


9. Cookies and similar technologies

Our website and the platforms connected to it may use cookies and similar technologies.

Cookies may be used to:

·         make the website work properly;

·         keep users logged in;

·         support checkout and account access;

·         remember preferences;

·         protect the website and services;

·         understand basic site performance or usage where provided by the platform.

At the time of this Privacy Policy, Verluma Academy has not independently added Google Analytics, Meta Pixel, TikTok Pixel, Google Ads tracking, retargeting pixels, or similar advertising tools to the website. However, because our website and courses are hosted through Podia, Podia may use cookies, analytics, and similar technologies as part of operating, securing, improving, and measuring its platform. For more information, please review Podia’s own privacy and cookie information.If we add non-essential analytics or advertising cookies in the future, we will update this Privacy Policy and, where required, provide a cookie notice or consent banner.

You can usually control or delete cookies through your browser settings. Blocking some cookies may affect website functionality, login, checkout, or course access.

For more information about Podia’s data and cookie practices, you may also review Podia’s own privacy information.


10. Email marketing

If you subscribe to our email list or agree to receive marketing communication, we may send emails about:

·         German learning tips;

·         course updates;

·         free materials;

·         offers;

·         private tutoring information;

·         Verluma Academy news.

You can unsubscribe from marketing emails at any time by using the unsubscribe link in the email, where available, or by contacting us at hello@verlumaacademy.com.

Even if you unsubscribe from marketing emails, we may still send necessary non-marketing emails, such as purchase confirmations, course access information, private lesson details, customer support replies, or legal/administrative notices.


11. Private tutoring and lesson records

Private tutoring is available for adults and students aged 16 or older. Students under 18 should use private tutoring only with the consent and involvement of a parent or legal guardian.

To provide effective tutoring, we may process information about your German level, goals, exam preparation needs, previous learning background, lesson preferences, and progress.

We may keep limited lesson notes to help prepare future lessons and support your learning. These notes are not sold, used for advertising profiling, or made public.

Private Zoom lessons are not recorded by default.


12. Minors

Our private tutoring services are intended for adults and students aged 16 or older. If a student is under 18, a parent or legal guardian should be involved in the purchase, booking, and use of the service.

Digital courses may be purchased through the website checkout system. If a minor accesses or uses a course, they should do so with the consent and supervision of a parent or legal guardian.

We do not knowingly market directly to children under 16. If we become aware that we have collected personal data from a child without appropriate consent, we will take reasonable steps to delete or restrict that data where required.


13. How long do we keep your data?

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

As general rules:

·         Customer account and course access data: kept while your account remains active or while needed to provide access to purchased products.

·         Payment, billing, tax, and accounting records: kept for the period required by applicable tax, accounting, or legal obligations.

·         Private lesson booking data: normally kept for up to 3 years after the last lesson or last relevant interaction, unless a longer period is required for legal, accounting, dispute, or business reasons.

·         Lesson notes: normally kept for up to 3 years after the last lesson, unless you request deletion and we do not have a legal or legitimate reason to keep them.

·         Email and support messages: normally kept for up to 3 years after the last contact, unless needed longer for legal, accounting, dispute, or service reasons.

·         Newsletter data: kept until you unsubscribe, withdraw consent, or request deletion, unless we need to keep limited suppression records to make sure you are not contacted again.

·         Technical/security records: kept for a limited period as needed for security, troubleshooting, platform operation, and legal protection.

When data is no longer needed, we will delete it, anonymize it, or securely restrict it where deletion is not immediately possible.


14. How do we protect your data?

We use reasonable technical and organizational measures to protect personal data. These may include password-protected accounts, secure third-party platforms, limited access to student information, secure payment providers, and careful handling of lesson notes and communications.

However, no internet-based service is completely secure. We cannot guarantee that unauthorized access, cyberattacks, or technical failures will never occur. You should use strong passwords, keep your login details private, and contact us if you suspect unauthorized access to your account.


15. Do we sell personal data?

We do not sell your personal data.

We also do not currently use advertising pixels or retargeting tools for personalized advertising. If this changes in the future, we will update this Privacy Policy and provide any required choices or consent mechanisms.


16. Your privacy rights

Depending on your location and applicable law, you may have rights regarding your personal data. These may include the right to:

·         request access to your personal data;

·         request correction of inaccurate or incomplete data;

·         request deletion of your personal data;

·         request restriction of processing;

·         object to certain processing;

·         request data portability;

·         withdraw consent where processing is based on consent;

·         lodge a complaint with a data protection authority.

These rights are not absolute and may be limited by legal, accounting, tax, contractual, or legitimate business requirements.

To exercise your rights, contact us at:

hello@verlumaacademy.com

We may need to verify your identity before responding to your request.

If you are in the European Union or European Economic Area, you also have the right to lodge a complaint with your local data protection authority.


17. Links to other websites and platforms

Our website or services may contain links to third-party platforms, such as Podia checkout pages, Calendly booking pages, Zoom, PayPal, Stripe, or social media platforms.

We are not responsible for the privacy practices of third-party websites or services. You should review their privacy policies when using those services.


18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example if our services, platforms, legal obligations, or data practices change.

The updated version will be posted on this page with a new “Last updated” date. If changes are significant, we may provide additional notice where appropriate.


19. Contact

For privacy questions, requests, or concerns, contact:

Verluma Academy
operated by Henrich Kotlán - Lektor
Slovakia
Email: hello@verlumaacademy.com

Because the business is operated from a private home address, the full postal address is not published here. A suitable postal or business contact address may be provided upon a legally valid request where required.


20. Important note

This Privacy Policy is intended to describe Verluma Academy’s current data practices in a clear and transparent way. It should be reviewed and updated if you add new tools, advertising pixels, analytics, lesson recording, a separate email provider, a cookie banner, or a public business address.