1. Data Controller
The data controller within the meaning of the General Data Protection Regulation (GDPR) is:
AI-Expertin
Kirsten Franck
Dorfstraße 2
23820 Pronstorf, Germany
Email: info@ai-expertin.de
Phone: +49 4506 88 90 718
Data Protection Officer
Based on the current assessment, there is no obligation to appoint a Data Protection Officer. For privacy-related inquiries, please contact the controller named above.
2. General Information on Data Processing
Whenever we collect personal data from you (e.g. via the website, a purchase, or Moodle registration), we inform you at the time of collection about, among other things:
- Purposes and legal bases
- Recipients / categories of recipients
- Any transfers to third countries, where applicable
- Storage period or the criteria used to determine it
- Your rights as a data subject
3. Recipients / Service Providers
In certain cases, we use service providers (hosting). Where these providers process personal data on our behalf, this takes place under a data processing agreement (DPA).
- Website hosting: IONOS (Germany) – provision of the website
- Learning platform hosting: Netcup (Germany) – provision of the website freigeist-sh.de
- Digistore24 – payment processing / contract processing
- Google Analytics – audience measurement
4. Area-Specific Modules
Module A: Digistore24 (Sale of Online Courses, Payment Processing, Commission)
- Purpose: Contract processing, payment processing, billing/commission processing
- Description of data flows: Payment processing (including the data required for this) is handled exclusively via Digistore24. Digistore24 receives a commission for each sale; the remaining amount is paid out to the account we have specified.
- Legal basis: Art. 6(1)(b) GDPR
- Recipient: Digistore24 (as recipient of the data required for processing)
- Storage period/criteria: in accordance with statutory retention periods
- Data subject rights: see the "Your Rights" section
Module B: Moodle Learning Platform (Account, Learning Progress, Exams, Forums/Chats, Certificates)
- Purpose(s): User account, course delivery, tracking of learning progress/exams, community features (forums/chats), certificate management
- Legal basis: Art. 6(1)(b) GDPR
- Recipient: Netcup (Germany); support/administration: Kirsten Franck
- Storage period/criteria: until the account is deleted; certificate data for 2 years
Module B.1: Automated Unlocking / Automatic Certificate Generation (Art. 22 GDPR)
We use automated logic within the learning platform to unlock exams and generate certificates. The following applies:
- The final test of a module is only unlocked once the module tests have been completed with a score of at least 85%.
- Once all module final tests have been passed with at least 85%, the certificate exam is unlocked.
- If the certificate exam is passed with at least 60%, a certificate is generated automatically.
Legal Notice (Transparency):
Automated decisions in individual cases, including profiling, are covered by Art. 22 GDPR; data subjects have, among other things, the right not to be subject to a decision based solely on automated processing which produces legal effects concerning them or similarly significantly affects them.
Where such a situation applies and an exception is met (e.g. "necessary for the performance of a contract" or "explicit consent"), appropriate measures must be in place, including the right to obtain human intervention, to express one's point of view, and to contest the decision.
Contact: If you have questions about the automated logic or would like a review, please contact us at: info@freigeist-sh.de
Module C: Individual AI Assistants (No Personal Data Entry Required)
- Purpose: Provision of AI-supported assistance functions for various use cases.
- Privacy setup: The assistants are designed so that users are not required to enter any personal data.
- Transparency under the EU AI Act (separate notice, not GDPR): In the case of direct interaction, it must be clearly communicated that users are interacting with an AI system (Art. 50 EU AI Act).
Module D: Audience Measurement (Google Analytics)
- Purpose: Audience measurement / statistics (number of visitors)
- Recipient: Google (depending on the service used)
- Legal basis: Art. 6(1)(a) GDPR
- Storage period/criteria: up to 14 months
Module E: Newsletter
We do not currently offer a newsletter. Should we introduce one, we will update this privacy policy accordingly to reflect the processes used at that time.
5. Your Rights (Data Subject Rights)
Right to Access (Art. 15 GDPR)
You have the right to obtain confirmation from us as to whether personal data concerning you is being processed; where this is the case, you have the right to access that personal data and to information such as the purposes of processing, the categories of data, recipients, storage period/criteria, further rights, the right to lodge a complaint, the origin of the data (if not collected from you), and, where applicable, information on automated decision-making including profiling. We provide a copy of the personal data undergoing processing; a reasonable fee may be charged for further copies.
Further Rights
- Right to rectification (Art. 16 GDPR)
- Right to erasure ("right to be forgotten") (Art. 17 GDPR)
- Right to restriction of processing (Art. 18 GDPR)
- Right to object to processing (Art. 21 GDPR)
- Right to withdraw consent (Art. 7(4) GDPR)
- Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)
- Right to data portability (Art. 20 GDPR) – where processing is based on consent/contract and carried out by automated means
- Right not to be subject to an automated decision (Art. 22 GDPR) – not to be subject to a decision based solely on automated processing where this has legal or similarly significant effects; profiling is explicitly mentioned
6. Contact for Exercising Your Rights
To exercise your rights, you can contact us at any time:
Kirsten Franck
Dorfstraße 2
23820 Pronstorf, Germany
Phone: +49 4506 88 90 718
Email: info@ai-expertin.de
Last updated: May 2026
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