Personal Data Protection Policy
This Personal Data Protection Policy explains how we collect, use and protect your
personal data when you use our services, participate in our programs or visit the
website https://ivanvotipka.com (“Website”).
We collect, store and process personal data in order to deliver high-quality
services, manage our business activities, and continuously improve the quality and
security of our services.
This Website is primarily used to present information, allow visitors to contact
us, and allow prospective clients to apply for or schedule a qualification call.
Paid programs are governed separately by specific written agreements.
Applicable Legal Framework
Personal data is processed in accordance with this Policy and applicable data
protection laws, in particular Regulation (EU) 2016/679 (General Data Protection
Regulation – “GDPR”), where applicable, in particular for users located in the
European Union, and applicable data protection and privacy laws of the United Arab
Emirates.
This Policy fulfils our information obligations under Article 13 GDPR, where applicable.
Controller
Lightspeed German Learning FZE LLC, represented by Ivan Votipka
Registered office: Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
Privacy requests may be submitted through the contact form available on this Website.
Personal Data
“Personal data” means any information relating to an identified or identifiable natural person.
How Do We Obtain Your Personal Data?
Directly from you – when you contact us through the Website or another linked communication channel.
Directly from you – when you apply for, schedule, or attend a qualification call.
Directly from you – when you later enter into a separate written agreement for paid services.
Automatically – through technical data collected when you visit and use the Website.
If you do not provide personal data required for contractual or legal purposes, we may not be able to provide the requested services.
What Personal Data Do We Process?
Identification data (name)
Contact details (email address, telephone number)
Payment and transaction data
Technical and usage data
Qualification-call and communication data
Profile and course participation data
Marketing preferences
Purposes and Legal Basis for Processing
Article 6(1)(b) GDPR – performance of a contract
Article 6(1)(b) GDPR – taking steps at your request before entering into a contract, including qualification calls and enrollment assessment
Article 6(1)(c) GDPR – compliance with legal obligations
Article 6(1)(f) GDPR – legitimate business interests
Article 6(1)(a) GDPR – consent, where required (e.g. marketing communication)
This includes handling qualification call requests, responding to inquiries,
delivering purchased services, processing payments, improving the Website,
protecting platform security, and sending marketing communications where lawful.
Direct Marketing
You may object to marketing communication at any time. Upon objection, your data will no longer be processed for marketing purposes.
Data Retention
Qualification call and inquiry data is retained for as long as reasonably necessary to evaluate the request, follow up, and protect legitimate business interests.
Client and transaction data is retained for the duration of the contractual relationship and as required by applicable legal, accounting, and tax obligations.
Marketing data is retained until consent is withdrawn or a valid objection is exercised.
Technical and analytics data is retained according to the applicable provider settings and legitimate retention needs.
Data Processors
We use carefully selected service providers (data processors) who process personal
data on our behalf, including website hosting and infrastructure providers, email
and communication service providers, scheduling and qualification-call tools,
payment service providers, video and embedded-media providers, heatmap and session
analytics providers (e.g. Hotjar), and analytics providers (e.g. Google Analytics).
All data processors act only on our instructions and are contractually bound to
comply with applicable data protection laws.
Technical Data and Cookies
The Website uses essential technical cookies and may use analytics and behavioral tools such as Google Analytics and Hotjar.
These tools may collect technical, device, browsing, session, and interaction data, including page visits, clicks, scrolling behavior, approximate location derived from IP address, and similar usage data.
Such tools may be used for website analytics, performance monitoring, usability analysis, and service improvement. You may manage cookies through your browser settings and any consent tools made available on the Website.
International Data Transfers
Personal data may be processed outside the EU/EEA, including in the United Arab Emirates and the United States.
Where required by law, we rely on appropriate safeguards such as contractual protections, provider commitments, or other legally recognised transfer mechanisms.
Data Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse.
These measures may include access controls, provider-level security protections, secure infrastructure, restricted internal access, and reasonable monitoring of our systems and service providers.
Personal data is accessed only where necessary for operational, contractual, legal, or support purposes, and only by authorised persons or processors acting on our instructions.
While we take reasonable steps to protect personal data, no website, platform, storage system, or transmission method can be guaranteed to be completely secure. For that reason, users should also protect their own devices, accounts, and communication channels when interacting with the Website or our services.
Your Rights
Right of access
Right to rectification
Right to erasure
Right to restriction
Right to data portability
Right to object
Right to withdraw consent
To exercise your rights, please use the contact form available on this Website or the contact details provided on the Website. Identity verification may be required.
Automated Decision-Making
We do not use fully automated decision-making or profiling that produces legal
effects or similarly significant effects on individuals through this Website.
Sensitive Data
Please do not submit sensitive personal data, special-category personal data, or
confidential third-party information through the Website or qualification-call
process unless specifically requested and legally appropriate.
Complaints
If you believe your personal data has been processed unlawfully, you may lodge a complaint with a competent data protection authority in your country of residence.
Updates
This Privacy Policy may be updated from time to time. The current version will always be available on this Website.
Registered Office
Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
