This Privacy Policy explains how fluente collects and uses personal data when you visit the German Sprint website, take a placement test, book a course, use a self-study membership or contact us. It also explains your choices and data-protection rights.
1 Who is responsible
Katarina Bertusek, trading as fluente, is responsible for the personal data described here. fluente is a Swiss sole proprietorship (Einzelfirma), UID CHE-368.665.243, at Brackenweg 14, 5200 Brugg, Switzerland. Contact: info@fluente.ch or WhatsApp +41 76 262 47 48. You may also write to the postal address above.
This policy concerns the fluente German Sprint website, its placement test, course bookings, self-study membership and associated communications. fluente owns fluente.ch and profluente.com. This policy applies to the services described here when offered through those domains. If another service has a separate privacy notice, that notice explains the processing specific to that service.
2 The essentials
- Before starting the written test, you provide your first name and email and confirm the enquiry notice. Your contact details are linked to your saved answers, result and course choices.
- fluente uses your details to recommend a suitable group, arrange your course, provide materials and support, and handle payments, cancellations and cashback.
- General newsletter signup is optional and separate from the enquiry permission requested before the test. Leaving the optional newsletter box unchecked does not affect your booking.
- Stripe processes payments. The fluente website does not collect or store your full card details.
- You can contact info@fluente.ch about access, correction, deletion or other data-protection requests.
3 Visiting the website
The current public website runs on Cloudflare hosting and a Cloudflare D1 database. Delivering and protecting the site involves technical information such as IP address, request time, requested page, browser and device information, and error or security records. The hosting services process this information to deliver pages, operate their infrastructure and prevent abuse.
The website also uses Google Fonts loaded from Google's servers. Loading a page can therefore send Google your IP address and technical request information. fluente does not use Google Analytics, a Meta advertising pixel or an embedded Facebook feed on this website. Links to external services are described below.
4 Cookies and campaign information
The fluente_session cookie identifies your test session. It is necessary to save answers and connect your result to your booking. Its lifetime is seven days from creation. Blocking or deleting it can prevent you from resuming the test or accessing its result. The cookie contains a random identifier and secret, rather than your name or score.
The fluente_campaign cookie stores the source and campaign labels from a promotional link for up to 30 days. It helps connect a later signup or registration with that promotion. It is set when those link parameters are present, without a separate consent prompt. It is separate from newsletter consent. Browser cookie controls can remove it; that does not remove information already saved with a registration.
Cookie expiry is not deletion of the corresponding database records. The current website has no automatic purge of test answers when the session expires. See section 11 for retention and deletion.
5 Your written test and group recommendation
fluente stores the answers you save, test status, creation and completion times, calculated score and recommended book group. For new tests, these records are linked to the first name and email supplied before the test. Older tests started without contact details remain linked to a browser session until a contact is provided. Answers are saved when you move between question pages, save progress or submit the test.
The recommendation is calculated automatically: a correct answer earns one point, an incorrect answer subtracts one point, and an unanswered question earns zero. Scores of 1-12 recommend Book 1; 13-24 Book 2; 25-36 Book 3; 37-48 Book 4; and 49-60 Book 5. A score of zero or below also allows Book 1.
This result determines which book group's classes you can book through the website. It is an internal placement recommendation, not an official language qualification. If it does not seem appropriate, contact fluente for a human review before booking. fluente can discuss a different placement or a speaking assessment with you. A test result alone does not enrol you or require payment.
6 Registration, teaching and learner support
To register, you provide your first and last name, email address and selected class. Phone number, location, how you found fluente and learning goals are optional. The website records your test reference, assigned book, selected lesson slot, registration time, required acknowledgements and optional newsletter choice. Campaign labels may also be saved as described in section 4. Without the required contact and class information, fluente cannot complete a registration.
If the classes for your book are full and you request a one-to-one call, fluente stores your name, email, test result, book and any optional phone number or availability you provide. These details are used to respond to your request. A call request does not itself subscribe you to marketing.
During a course, fluente uses the contact and learning information needed to organise lessons, give feedback, assess progress and manage attendance, the final assessment, any cashback request and your certificate of participation. Teachers receive the details needed to teach and support their group. In live group lessons, other participants can see your chosen display name and hear or see what you share through audio, video or chat.
The lesson platform is identified in your joining information, together with the information needed to access the lesson. Ordinary participation is not permission to use your image, voice or comments in promotional material. Any intended recording or testimonial use requires separate information and the appropriate permission.
Please include only information relevant to your learning or request. Avoid entering health information, identity documents or other sensitive details in open text fields unless fluente has specifically explained why they are needed and how to provide them securely.
7 Payment and access to self-study
Payment takes place on Stripe's checkout. For the Sprint, the website passes your registration email and a booking reference to Stripe to prefill checkout and match the payment to your chosen class. Your test answers and score are not included in that link. The self-study checkout also takes place on Stripe. If you have supplied details for a test in this browser, the website passes your email and a test reference to prefill checkout and associate your purchase with your recommended book.
Stripe processes the contact, billing and payment information you enter, as well as transaction and fraud-prevention information. fluente receives or can view the merchant information needed to manage the purchase, subscription, refund, dispute or accounting record. Full card information is not stored by the fluente website. Stripe also processes certain information for its own purposes, explained in its privacy notice: https://stripe.com/privacy.
fluente records payment confirmations received from Stripe, including a checkout reference, name, email, programme, amount, currency and payment time. These are matched to a registration or test where possible; unclear matches require manual review. fluente sends joining or self-study access instructions manually. Your checkout email is used to send the books, MP3 access and private Facebook-group details. Necessary purchase and access messages are service communications, separate from optional marketing.
fluente prepares a daily internal email for the owner with registration counts and the names, email addresses, programme, book and payment references needed to assign learning-system access manually. The report distinguishes confirmed payments, uncertain matches and enquiries that have not progressed. This report is processed through the owner's connected Gmail account using a scheduled Codex task. It is not sent to other learners.
8 Email, WhatsApp and the Facebook group
When you contact fluente, your contact details, message and relevant attachments are used to answer you and manage the matter raised. Email and WhatsApp are alternative contact channels; you can also use post. WhatsApp processes communications and account or technical data under its own privacy terms. Do not send payment-card details through messages.
The private Facebook group supports the self-study membership. If you choose to join, fluente uses the details needed to check membership and manage admission. Your Facebook profile information, posts, comments and questions are visible according to the group's settings, including to other members and administrators. A private group does not make its contents confidential from Meta or prevent another member from copying them. Avoid sharing private information about yourself or others in a group question.
Facebook and WhatsApp are Meta services with their own processing rules. Their current notices are available at https://www.facebook.com/privacy/policy/ and https://www.whatsapp.com/legal/privacy-policy. fluente remains responsible for its own use of your information, including group administration and responses to questions.
9 Optional newsletters and course news
The website's newsletter form and unchecked course-news option collect marketing consent separately. A signup records your email, any name supplied, consent wording and time, subscription status, and relevant source, campaign or book group. These details support relevant course news and follow-up messages. fluente does not treat a test or course purchase alone as newsletter consent.
Website newsletter signups are stored in the website database, including the consent and subscription records described above. Email delivery from this website's mailing system is currently inactive. This general newsletter system is separate from the German Sprint enquiry integration described below.
For German Sprint enquiries, fluente records your name, email, the permission wording and time, your recommended book, and whether you completed the test, selected a class, registered or proceeded to self-study checkout. Contact details and corresponding group memberships are sent to MailerLite to organise enquiries and relevant follow-up. Confirmed purchase groups are recorded separately; a click or reservation is not treated as payment. If the connection is temporarily unavailable, the website retains the record and retries. Existing MailerLite subscriptions retain their opt-out status. A purchase alone is not general newsletter consent. MailerLite explains its handling of personal data at https://www.mailerlite.com/legal/privacy-policy.
You can withdraw marketing consent at any time using the unsubscribe option in a marketing email or by contacting info@fluente.ch. This does not cancel your course or prevent necessary service messages. fluente keeps a limited opt-out record to avoid accidentally adding you again. Consent withdrawal does not affect processing that was lawful before withdrawal.
10 Purposes and legal grounds
The Swiss Federal Act on Data Protection applies to fluente's handling of personal data. Where the EU General Data Protection Regulation also applies, the relevant grounds depend on the activity:
- Article 6(1)(b): requested placement and booking steps, teaching, material access, payment matching, support and contract administration.
- Article 6(1)(a): optional marketing based on consent, and other activities for which separate consent is obtained.
- Article 6(1)(c): applicable accounting, tax and other legal duties.
- Article 6(1)(f): necessary site security, abuse prevention, service administration and protection of legal claims, after considering your rights.
These grounds do not replace any separate consent required for cookies or similar technologies. Reading or accepting this Privacy Policy does not itself constitute consent to optional processing.
11 Retention and deletion
Retention is assessed according to the purpose of each record, any ongoing service or enquiry, and applicable legal obligations. Test answers support placement and any resulting booking or placement check. Contact requests support the enquiry and related follow-up. Course records support delivery, the participation certificate, assessment, refunds and cashback. An outstanding obligation, dispute or applicable record-keeping requirement may require information to be kept after a course or enquiry ends.
Test, booking and call-interest records are not deleted automatically when a browser session expires. The seven-day session lifetime is therefore not the retention period for those records. Deletion requests are handled manually through info@fluente.ch, taking account of the purposes and obligations described in this section.
Necessary transaction and accounting records are kept for the applicable statutory retention period; this does not justify retaining every test answer for the same period. Marketing information is kept while there is a valid subscription and relevant purpose. After opting out, limited suppression and consent evidence may be retained to honour the opt-out and address a complaint. Records under a justified legal hold may be kept until the issue is resolved.
Website signup abuse prevention uses a hashed IP value in an hourly counter. Counters expire after an hour and are cleared on a subsequent signup request. Hosting and external-service logs and backups are subject to the relevant provider's retention arrangements. You can contact fluente for information about the records associated with your use of the service.
12 Recipients and international processing
Information is shared with the people and services needed for the purposes described above: fluente administration and teachers; hosting and database providers; the email and lesson services; Stripe; and, when you use them, Facebook, WhatsApp and the relevant mailing service. Professional advisers or authorities receive information when necessary for a legal obligation, a dispute or the protection of rights. The information shared depends on each recipient's role and the service you use.
Cloudflare provides website hosting: https://www.cloudflare.com/privacypolicy/. OpenAI processes the scheduled internal reporting task: https://openai.com/policies/privacy-policy/. Gmail processes the owner's internal report email under Google's privacy policy: https://policies.google.com/privacy. Google processes font requests under its applicable privacy information at https://policies.google.com/privacy. These provider notices explain their own processing; they do not replace fluente's responsibilities.
These providers operate internationally. Your information may be processed outside Switzerland, including in the United States and other locations used by the relevant provider. The provider notices linked above describe their international processing. The destination and applicable protection depend on the service and recipient involved; information is not stored exclusively in Switzerland. Contact info@fluente.ch for information about the recipients, destinations and transfer safeguards relevant to your personal data.
13 Your choices and rights
Contact info@fluente.ch to request information about your data, a copy, a correction or deletion. Where the applicable law provides, you may also request restriction or portability, object to processing based on legitimate interests, withdraw consent, or challenge an automated decision. You may object to direct marketing at any time. Statutory exceptions, such as necessary legal record keeping, may limit a request; fluente will explain any applicable limitation.
Use the email associated with your booking if possible and describe the request. For an unnamed test, contact fluente while you can still access the result so the record can be identified safely. Do not send your session cookie or secret. fluente may request proportionate information to verify identity and protect another person's records.
You may complain to the Swiss Federal Data Protection and Information Commissioner at https://www.edoeb.admin.ch or, where GDPR applies, to a competent authority in the EU, including where you live or work. You do not have to contact fluente first to exercise that right.
14 Changes and contact
fluente updates this policy when its services or data practices change. The date at the top identifies the current version. Material changes will be communicated as required by applicable law. An update does not replace any new consent that may be needed. For privacy questions, write to info@fluente.ch or Katarina Bertusek, Brackenweg 14, 5200 Brugg, Switzerland.