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Privacy policy

This is a convenience translation. The German Datenschutzerklärung is the authoritative version.

This website is built to process as little data as possible. This page says exactly which data is still processed, why, and on what legal basis (Art. 13 GDPR).

1. Controller

Abdurrahman Bilir
c/o POSTFLEX PFX-676-636
Emsdettener Straße 10
48268 Greven
Germany
Email: hello@mitlernen.com

I have not appointed a data protection officer because I am not legally required to.

2. At a glance

Note under § 25 TDDDG (German Telecommunications Digital Services Data Protection Act): I do not store information on your device or access information stored there, except where this is strictly necessary to provide the website (§ 25(2) no. 2 TDDDG). The only such case is your browser keeping this website’s files (such as stylesheets and fonts) in its cache; you can clear the cache in your browser at any time. Whether the site is shown in light or dark mode is decided by your browser based on your device setting — this information is not sent to me.

3. Hosting on Cloudflare

This website is served via Cloudflare Pages, provided by Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA (“Cloudflare”). Cloudflare delivers the pages through its global network and protects them against attacks.

What data: on every request Cloudflare processes technically necessary connection data: your IP address, date and time, the requested address, the HTTP status code, the amount of data transferred, the previous page (referrer, if your browser sends it) and information about your browser and operating system (user agent). This data appears in server and security logs.

Purpose and legal basis: delivering the website, stability and security (for example, defending against overload and abuse). The legal basis is Art. 6(1)(f) GDPR; my legitimate interest is a secure, reliable and fast website. I do not analyse this data myself, do not combine it with other data and do not build usage profiles.

Whether it is required: processing this connection data is technically necessary to deliver the website; without it the website cannot be shown.

Storage period: I do not retrieve, evaluate or store access logs myself. According to Cloudflare, it keeps such logs only as long as needed for delivery and security; details are in Cloudflare’s privacy policy.

Data processing agreement: Cloudflare processes the data on my behalf under a data processing agreement pursuant to Art. 28 GDPR (Cloudflare Data Processing Addendum).

Transfers to the USA: Cloudflare may process data in the USA and in other countries outside the EU. Cloudflare, Inc. is certified under the EU-U.S. Data Privacy Framework, so an adequacy decision of the European Commission applies (Art. 45 GDPR). In addition, Cloudflare has agreed to the European Commission’s Standard Contractual Clauses (Art. 46(2)(c) GDPR). More: Data Privacy Framework list and Cloudflare’s privacy policy.

4. Waitlist

You can join the waitlist so that I can let you know when MitLernen is released. To do so, you tick the box next to this text in the form:

“Email me when MitLernen launches. I can unsubscribe any time. Privacy policy”

On the German home page the text reads: „Ich möchte per E-Mail erfahren, wenn MitLernen erscheint. Ich kann mich jederzeit abmelden. Datenschutzerklärung“. The version of this text (dated 8 October 2026) is stored.

What I store:

The entry is filed under a checksum (SHA-256 hash) of your email address so that signing up twice does not create a second entry. For the waitlist I store no IP address and no browser information. The form contains a field that is invisible to people and helps against spam; whatever is entered there is not stored. Independently of this, Cloudflare processes the connection data described in section 3 when you submit the form.

Purpose: to write to you when MitLernen is released. I use your address for nothing else and do not pass it on.

Legal basis: your consent (Art. 6(1)(a) GDPR). Providing your email address is voluntary; without it and your consent you cannot join the waitlist.

Withdrawal: you can withdraw your consent at any time without giving reasons — the easiest way is an email to hello@mitlernen.com. I will then delete your entry. Withdrawal applies to the future; processing up to that point remains lawful (Art. 7(3) GDPR).

Where it is stored: entries are kept in Cloudflare Workers KV, a data store run by Cloudflare. The information on data processing and transfers in section 3 applies.

Confirmation (double opt-in): before I send you a message about the release, I will ask you to confirm by email. You only receive the launch message after confirming. Entries that are not confirmed are deleted. I will use an email delivery service to send these emails and will add the details to this policy before I do.

Deletion: I delete your entry once the release message has been sent, immediately after a withdrawal, and also if I discontinue the project.

5. Contacting me by email

When you write to hello@mitlernen.com, Cloudflare receives the message and forwards it via Cloudflare Email Routing to my mailbox at Gmail. According to Cloudflare, it does not store the content of the message. Section 3 applies to Cloudflare.

Mailbox at Google (Gmail): for users in the European Economic Area the mailbox provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Data may also be processed by Google LLC in the USA. Google LLC is certified under the EU-U.S. Data Privacy Framework (adequacy decision, Art. 45 GDPR); standard contractual clauses (Art. 46(2)(c) GDPR) also apply. More in Google’s privacy policy. I use a free Gmail account, for which there is no data processing agreement; Google therefore processes the emails as a controller in its own right under its privacy policy. The legal basis for using the mailbox is Art. 6(1)(f) GDPR (legitimate interest in reliable email handling).

What data: your email address, your name if you give it, the content of your message and the technical email headers.

Purpose and legal basis: answering your enquiry. Where it concerns a contract or steps before a contract, the legal basis is Art. 6(1)(b) GDPR; otherwise Art. 6(1)(f) GDPR (my legitimate interest in answering enquiries).

Deletion: I delete the message once the enquiry is settled, unless statutory retention obligations (for example under commercial or tax law) apply.

6. Contact form

You can send me a message through the contact form.

What data: your name (optional), your email address and your message, plus the language of the page and the time it was received. The form stores no IP address and no browser information. A field that is invisible to people and the time between loading the page and sending the form are only checked to keep out spam; they are not stored. Independently of this, Cloudflare processes the connection data described in section 3 when you send the form.

Purpose and legal basis: answering your enquiry. Where it concerns a contract or steps before a contract, the legal basis is Art. 6(1)(b) GDPR; otherwise Art. 6(1)(f) GDPR (my legitimate interest in answering enquiries).

Whether it is required: I need your email address to reply; without it the form cannot be sent. Your name is optional.

Storage: the message is stored in Cloudflare Workers KV (the information on data processing and transfers in section 3 applies) and deleted automatically after 90 days at the latest. If your enquiry is settled earlier, I delete it earlier, unless statutory retention obligations apply.

Email notification: a copy of the message is sent via Cloudflare Email Routing to my mailbox at Gmail so that I can read and answer it. The information on Google in section 5 applies to the mailbox: Google processes the email as a controller in its own right, and the legal basis for using the mailbox is Art. 6(1)(f) GDPR. I delete the message there once the enquiry is settled.

7. The MitLernen app

The iOS and Android apps have not been released yet. This website does not process any data from the app. The app is designed so that

A planned, optional tutor (not built yet) would send your saved words off your device only if you explicitly switch it on; this policy and the app’s privacy policy will be updated before that.

I will publish a separate privacy policy for the app at release.

8. Your rights

Regarding your personal data, you have the right to:

An email to hello@mitlernen.com is enough.

Right to object (Art. 21 GDPR)

Where I process data on the basis of Art. 6(1)(f) GDPR, you may object at any time on grounds relating to your particular situation. I will then stop processing the data unless I can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

Right to lodge a complaint (Art. 77 GDPR)

You can complain to a data protection supervisory authority, in particular in the EU member state of your habitual residence, place of work or place of the alleged infringement.

9. No automated decision-making

I do not make decisions based solely on automated processing within the meaning of Art. 22 GDPR, and I do no profiling.

10. Encryption

This website is only served encrypted over HTTPS (TLS).

11. Changes

If the processing changes — for example when I start using an email delivery service for the waitlist — I will update this policy beforehand.

Last updated: October 2026