Privacy Notice

Version dated 12 October 2026

This notice explains which personal data I process when you visit the Caring Words website, submit an enquiry, take a language self-check, register your interest in a small group, provide feedback or book an appointment. The Learning Space at learning.cwcaringwords.com is a separate application with its own privacy information. This website notice does not replace the separate information provided to clients and course participants.

Reference translation: the German privacy notice remains controlling pending final legal review.

1. Who is responsible?

Chantal-Isabell Wywiol · Caring Words

Liegnitzer Str. 19

60598 Frankfurt am Main · Germany

Email: hello@cwcaringwords.com

Telephone: +49 1512 0027575

If you have questions about data protection or wish to exercise your rights, you can contact me directly. According to the business information currently documented, no separate data protection officer has been appointed.

2. Website and Google Workspace

My website is provided using Google Sites. I use Google Workspace Business Starter for business emails, documents, enquiries and appointments. The contract and billing records identify Google Cloud EMEA Limited, Ireland, as the provider.

When you access the website, data technically necessary for transmission, display and security are processed. These may include your IP address, the time of access and URL visited, technical browser and device information, connection data, errors and security-related data. Processing is necessary for the secure and functional operation of the website. For website provision initiated by me, the legal basis is Article 6(1)(f) GDPR; my legitimate interest is presenting my services reliably and securely. Access to information on your device is described separately in section 5.

Google distinguishes customer data, such as submitted form responses, from service data generated through the management and use of Google services. Google processes certain service data under its own responsibility; its Google Cloud Privacy Notice and the relevant Google terms apply. Customer data processed on my behalf are subject to the applicable contractual data-protection terms.

3. Contact, enquiries, feedback and appointments

3.1 Email and telephone

If you contact me by email or telephone, I process the contact details you provide, your message and the communication data necessary to respond. Where you are taking steps towards or performing a contract yourself, the legal basis is Article 6(1)(b) GDPR. For general business matters or contact by a company representative, Article 6(1)(f) GDPR applies; my legitimate interest is answering the enquiry properly. Article 6(1)(c) GDPR may also apply where legal documentation duties exist.

3.2 Google Forms — non-binding enquiry form

The contact page links to a Google Forms enquiry form, which opens on a separate Google page. Currently, name and contact email address are required; a telephone number is optional. The form first asks what your enquiry concerns and displays further relevant fields. Depending on the enquiry, these may cover the language and learning objective; type of support; training or teaching format; preferred dates or times; current language level; school and school year; the role of the person enquiring; company name and requested service; type and language of a text; approximate volume; intended use; and any information voluntarily included in a message. Some detailed fields are optional. The form does not contain file-upload fields.

I use the information to categorise the enquiry, respond to questions and, where appropriate, prepare an individual proposal. Where you are personally taking steps towards a contract, the legal basis is Article 6(1)(b) GDPR; otherwise Article 6(1)(f) GDPR applies to the handling of general or company-related enquiries. For enquiries concerning minors, I process only the information about parental responsibility or learning support necessary for the purpose, taking particular account of the protection of children. Without the necessary contact details and information about the request, I may not be able to respond. You can use email or telephone instead.

According to the documented form settings, responses are accessible only to the owner of Caring Words within the business Google Forms account. There is no public response summary or linked response spreadsheet. Automatic collection of the respondent’s Google-account email address is switched off; an email address entered in the contact field is still processed. The form does not create a binding contract, payment obligation or newsletter subscription. The optional acknowledgement “I have read the privacy notice” does not constitute consent to advertising.

3.3 Google Forms — feedback, requests and complaints

You can use the separate Google Forms form to send feedback, suggestions, organisational requests or complaints. The category chosen, the text of your feedback and your choice of whether to receive a personal reply are processed. No contact details are requested if you do not want a reply. If you do request a reply, a contact email address is required; your name is optional. According to the documented settings, automatic collection of your Google-account email address is switched off.

I review feedback personally, address concerns and, where appropriate, improve my services. For general feedback and quality improvement, the legal basis is Article 6(1)(f) GDPR, reflecting my legitimate interest in quality assurance and handling complaints. Where a specific contractual service is concerned, Article 6(1)(b) GDPR applies; Article 6(1)(c) GDPR may apply to legal data protection or documentation duties. Feedback is not automatically used as a public review, and submitting the form does not sign you up for marketing. Please avoid including unnecessary health information, diagnoses or confidential information about third parties. Where such information is nevertheless provided, it will be reviewed separately if required and limited to what is necessary.

According to the latest documented settings, responses are accessible only to the owner. There is no linked response spreadsheet; public response summaries, response copies and subsequent automated editing are switched off. Any transfer into a protected quality-management case is limited to the handling of the matter. Sensitive complaint details remain outside the general business overview.

3.4 Free 15-minute introductory call via Google Calendar

If you use a Google Calendar booking page for a free 15-minute introductory call, I process your first name, last name, email address, chosen appointment, including the time zone, and any additional information you provide voluntarily. The data are used exclusively to arrange the appointment, prevent double bookings, send confirmations and manage any subsequent changes. A booking is neither an order for a paid service nor a newsletter subscription.

When you use Google Calendar, the appointment is added to my business calendar. Depending on the actual settings, Google creates a Google Meet link, sends a booking confirmation and, where applicable, appointment notifications. Cancellations or rescheduling are processed in the calendar and related messages. If you use Google Meet, your participation data, audio and video data and technical connection information may also be processed. I do not plan to record the introductory call; recording would require separate consideration and information.

As a rule, the processing of data for an appointment that you request in preparation for a possible contract is based on Article 6(1)(b) GDPR. Where additional processing is necessary for secure appointment management, prevention of misuse or technical communication, Article 6(1)(f) GDPR applies. Calendar entries and information from conversations are not made publicly available to uninvolved people. Alternatively, you can request an appointment by email or through the enquiry form. Such a request does not yet reserve an appointment; processing follows sections 3.1 or 3.2.

3.5 Voluntary language checks and small-group waiting list

The short language checks for German, English and French contain multiple-choice questions in writing. They provide initial guidance only; they are neither official examinations nor confirmed CEFR placement assessments. The forms do not request names or email addresses. Answers and results are processed in Google Forms but are not assigned to a customer record. Google may also process technical access and security information. Participation is voluntary; you can ask me for a personal assessment instead. The legal basis is Article 6(1)(b) GDPR where the guidance you request helps prepare for a possible contract; otherwise, Article 6(1)(f) GDPR applies, reflecting a legitimate interest in providing suitable, non-binding guidance.

When you register your interest in a small group without obligation, I process your contact email address, preferred language, estimated language level, preferred format and possible days or time slots. Your name, learning objective or focus and any message are optional. I use these details to assess whether a suitable group can be formed and, where appropriate, to send you a specific proposal. Being placed on the waiting list is not a booking, does not guarantee a place and does not trigger payment or a newsletter subscription. The legal basis is Article 6(1)(b) GDPR for the preparatory steps you request. Without the necessary contact, language and availability details, placement in a suitable group is not possible. Alternatively, you can register your interest by email.

4. Google Forms drafts and access

Google may temporarily save entries in Google Forms as drafts for signed-in Google users if the feature is enabled for a form. Google generally states a storage period of up to 30 days. According to the verified status of 11 October 2026, automatic draft saving was disabled for the Caring Words enquiry and feedback forms. An unsent draft is distinct from a response I have received through a submitted form.

Google Forms itself may process identification, security, access or session information technically required by Google. This is independent of whether I read the submitted responses personally. The settings actually enabled and Google’s own notices govern the details.

5. Cookies and similar technologies

According to the most recently documented settings, no Google Analytics ID is connected to the Google Sites website that I manage. I do not plan to use my own marketing tracking or unnecessary YouTube, Maps or social media embeds. The actual services — Google Sites, Google Forms, where applicable Google Calendar/Meet, and the standalone Learning Space — may use cookies, session identifiers and similar storage and access technologies.

Under Section 25 of the German Telecommunications and Telemedia Data Protection Act (TDDDG), storing information on your device or accessing it generally requires prior informed consent. An exception may apply, in particular, where access is strictly necessary to provide a service expressly requested by you. Where personal data are processed, a legal basis under the GDPR is also required. Non-essential technologies must not be used before valid consent has been obtained. The Learning Space has its own session and caching technologies, which are explained separately there.

6. Recipients and potential transfers to third countries

To provide the Google Sites website, process Google Forms responses, conduct business emails and, where applicable, arrange Google Calendar/Meet appointments, I use the relevant Google services and their contractually specified affiliated companies and subprocessors. Google publishes up-to-date lists. In telephone communication, the telecommunications providers involved receive the necessary connection data.

Google services may involve transfers or access from outside the European Economic Area. Google describes data-protection instruments such as adequacy decisions and, where applicable, standard contractual clauses under Article 46 GDPR. Whether a particular transfer is covered by the EU–US Data Privacy Framework depends, among other things, on the recipient actually involved and its valid certification. Exclusive storage within the EU is not promised.

Further information is available in the Google Cloud Privacy Notice, the data protection terms for Google Workspace and the current list of subprocessors. You can contact me at hello@cwcaringwords.com regarding the relevant safeguards and how to obtain a copy.

7. How long are data stored?

I retain data only for as long as needed for the purposes described or where another legal reason justifies continued retention. For an enquiry closed without a contract, I generally review the need for deletion no later than six months after closure. This is a review date, not a blanket retention obligation. After any required transfer of Google Forms data, I generally review whether the remaining original form response can be deleted within 90 days. This is also an internal review and not automatic deletion.

For feedback and complaints, after a matter is closed I review which information remains necessary for measures, evidence or possible defence of legal claims. Appointment and meeting details are reviewed for continuing organisational needs following completion or cancellation. Under the current deletion policy, calendar contents are generally reviewed each year. Documents relevant to contracts, business correspondence or taxation may be subject to statutory retention periods — commonly six, eight or ten years depending on the type of record. A mere website visit or general enquiry does not justify such blanket retention periods.

Where applicable, deletion and restrictions also take into account Gmail, Forms, Calendar, Drive, protected records and technical copies. Deleting a form response alone does not automatically remove a separate exported copy. Providers that process service data under their own responsibility apply their own retention arrangements.

8. Caring Words Learning Space

The personal learning area is a separate application at https://learning.cwcaringwords.com. Its current privacy information is available before sign-in at https://learning.cwcaringwords.com/privacy?lang=de. It describes the learning platform’s active processing activities, particularly access, sessions, course information, appointments, homework, approved materials and personal learning functions. This separate notice also applies to data processing in the Learning Space; the website privacy notice does not replace it.

The Learning Space is used operationally for approved courses with adult learners. Your personal access code opens only the learning area for which you are authorised. The current Learning Space privacy notice describes the approved functions and the related processing of data.

9. Your rights and right to complain

Subject to the applicable legal conditions, you have the right of access and to receive a copy under Article 15 GDPR, rectification under Article 16, erasure under Article 17, restriction of processing under Article 18 and data portability under Article 20. Where processing is based on consent, you may withdraw it at any time with future effect; this does not affect the lawfulness of processing that took place before withdrawal.

Where I rely on Article 6(1)(f) GDPR, you may object to processing on grounds relating to your particular situation under Article 21 GDPR. Following a justified objection I generally cease processing, unless overriding compelling grounds apply or the processing is necessary for the establishment, exercise or defence of legal claims. Please address requests to exercise your rights to hello@cwcaringwords.com.

You may lodge a complaint with a data protection supervisory authority, in particular the Hessian Commissioner for Data Protection and Freedom of Information: https://datenschutz.hessen.de/service/beschwerde-uebermitteln. In the website and contact processing described here I do not make decisions based solely on automated processing, including profiling, which have legal or similarly significant effects.