Responsible unit

Mina Le Beauty Academy Berlin UG
Möllendorffstr. 45
10367 Berlin
Germany

Phone: +49 3075657128
Email:info@minale-beautyacademy.de

Director legally represented

Thanh Nguyen

Security Policy & Technical and Organizational Measures (TOM)

In accordance with the General Data Protection Regulation (DSGVO/GDPR), we have appointed a data protection officer who will be the point of contact for all questions related to data protection within our business.

Our data protection officer is:
CUBE - das Würfelprinzip® - Miriam Haberer

Strausberger Str. 15a1 - 5345 Altalndbserg

If you have questions or issues related to data protection, you can contact our data protection officer directly.

We are committed to complying with the General Data Protection Regulation (DSGVO/GDPR).
All staff are fully informed of the requirements and obligations under DSGVO and have been trained to comply with these regulations.

All companies and individuals involved in the provision of services are DSGVO compliant and have signed appropriate agreements to ensure compliance with data protection regulations.

Data transfer

We will not pass your data on to third parties unless this is permitted by law.

Transfer of your data can only take place if:

• necessary to perform the contract and permitted under Article 6, clause 1, point b DSGVO;
• allowed on the basis of our legitimate interests to organize effective service provision according to Article 6, paragraph 1, point f DSGVO;
• covered by the consent you have granted;
• or becomes necessary where, pursuant to Article 6 paragraph 1 point c DSGVO, a public authority or competent authority legally requests us to provide your data.

If your data is transferred to third parties, this will be done as listed below.

Encryption

All of our sites use SSL encryption, which is a secure data transfer protocol (HTTPS), to ensure that data is transmitted encrypted. This prevents third parties from capturing and reading the data. The padlock icon on your browser and the “s” in “https” are signs that a secure connection has been established and your data is being transmitted securely.

Your Consent & Rights | Delete, edit, restrict

The basis for the storage of personal data is our legitimate interest in communicating with interested users according to Article 6 paragraph 1 point f DSGVO, and for contractual requirements the storage of contractual data according to Article 6 paragraph 1 point b DSGVO.

You can request that we provide data stored about you in machine-readable form at any time.

As for any consent, you have the right to withdraw at any time the consent given to us for the processing of your personal data. This can be done by means of an informal notice, for example via our contact form or by email to the email address set out in the legal information section. Your withdrawal does not affect the lawfulness of the data processing carried out up to that point.

You can ask us to correct (including supplement) inaccurate data at any time. You can also ask us for information about the personal data we hold about you, free of charge. To prevent abuse, it is necessary to verify your identity.

If the purpose of processing no longer exists, if the necessary consent has been withdrawn and there is no other legal basis, or if our data processing is unlawful, your personal data will be rectified, blocked or erased without delay in accordance with the law if you request.

Complaints

If you believe that your rights have been violated as a result of our data processing, you may file a complaint with the competent supervisory authority.

Initial contact via electronic inquiry

If it is in connection with the initiation or performance of a contract and you contact us outside this system electronically (e.g. email, fax, telephone, messenger, etc.), we will store and process the data you have provided to us. The legal basis is our legitimate interest in effective communication with customers according to Article 6, paragraph 1 point a DSGVO and Article 6 paragraph 1 point b DSGVO.

We only pass these data on to third parties if it is necessary for the performance of the contract (pursuant to Article 6 paragraph 1 point b DSGVO), in accordance with the overriding interests of efficient provision of services (pursuant to Article 6 paragraph 1 point f DSGVO), or based on your consent (pursuant to Article 6 paragraph 1 point a DSGVO), or otherwise authorized or legally obliged.

Input data

We collect data through the following possible forms:

• Contact form
• Callback request form
• Registration page
• Sign up to receive the newsletter
• Register for the course
• Register for an appointment

General information

We inform you according to our legal obligations about the collection and use of your personal data. Any data you enter on our website is voluntary; Failure to provide data will not disadvantage you.

When ordering services that we are required to provide or when entering into a contract with us, certain mandatory information is necessary as a basis for performing the services. These information are marked as required fields.

User personal data is only collected within the scope of applicable data protection laws, in particular the General Data Protection Regulation (DSGVO). The technical terms used in this document are explained in more detail in Article 4 of the DSGVO.

According to DSGVO, data processing is specifically permitted in three cases:

• according to Article 6, clause 1, point a and Article 7 DSGVO, if you have given us your consent to process the data;
• as set out in this privacy policy and in the consent under Article 4 No. 11 DSGVO, how your data is processed, for what purposes and under what circumstances;
• according to Article 6, paragraph 1, point b DSGVO, if the processing of your personal data is necessary for the creation, conclusion or performance of contractual relations;
• according to Article 6, paragraph 1, point f DSGVO, if after considering the interests, processing is necessary to protect our legitimate interests; This mainly includes our interests in analyzing, optimizing and securing services on the website – including in particular analyzing user behavior, creating profiles for advertising purposes, storing access data and using third party providers.

Basic data

We collect basic data insofar as necessary to establish, internalize or change the contractual relationship (including non-remunerative) between us and you as a user.

This data may include:

Customer data (natural personal)

• Address
• Name
• Last name
• Date of birth (in some cases)

Participant data (natural individuals)

Participants can be adults, themselves customers or registered with customers, or children.

• Gender
• Name
• Last name
• Date of birth (in some cases)

Contact information

• Email
• Phone
• Street
• House number
• Postal code
• City
• Country

Service data

• Location and date of scheduled service

Contract data for monthly contracts | installment contract | member

• Fees for booked services
• Payment history
• Basic history of the exchange since registration

When establishing a usage relationship, we will ask you to provide these data and inform you by marking mandatory fields, the extent to which the provision of information is required to establish the usage relationship.

Basic data storage time

Basic data necessary for the fulfillment of the contractual relationship (even without remuneration) will be stored until the contract is fully fulfilled or terminated. Longer storage may in particular be considered if this is still necessary to protect legal rights or due to legitimate interests, in particular in respect of data that we are legally obliged to retain; According to the tax retention period, data is often retained for 6 or even 10 years.

Usage data

All the following provisions apply within the framework of our legitimate interest in a correctly technical online service and its economically efficient organization and optimization in accordance with Article 6 paragraph 1 point f DSGVO.

We collect usage data of all site visitors and customers during the registration process, to enable you as a user to use the services on our website. Those affected by the storage of usage data are all site visitors, customers logged into the system during the ordering process and customers who register themselves on the site, subscribe to the newsletter or enroll in the information system. This takes place depending on the device or software you use to access our website. Personal data that you actively enter manually into the respective fields will not be automatically collected.

For example:

• your email address,
• name,
• and other information.

Data may include:

Usage information

• websites or page areas visited
• access duration
• level of concern for service

Content data

• date information of basic data entered by you

Optional information

• your profile photo (profile photo is not a required field)

Metadata

• your device identity
• location
• IP address of website visit in visitor tracking, anonymized (last two digits of IP address are not saved)

We only combine usage data with underlying data when and to the extent that it is necessary for billing purposes. Additionally, if there is no contact with the underlying data, we only process usage data in anonymized form.

You can object at any time by sending it to the address given in the legal information section or to the responsible person stated in this privacy policy.

The legal basis for this data processing is our legitimate interests according to Article 6 paragraph 1 point f DSGVO in analyzing the website and its use, and, if appropriate, also the legal permission to store data within the framework of creating a contractual relationship according to Article 6 paragraph 1 point b DSGVO.

Usage data storage time

Usage data collected during your use of the website will only be stored for as long as necessary for the proper functioning of the website and for as long as our legitimate interests exist, plus a statute of limitations (normally 2 or 3 years), with a reasonable extension in case the statute of limitations is interrupted. Statistical data will mainly be saved in pseudonymous form only.

Hosting provider

Kutego

Course bookings are provided online by a service provider (provider or hoster) for retrieval on the internet.

We use the service:

Hoster - Kutego GmbH, Pariser Platz 6a, 10117 Berlin, Germany

(hereinafter referred to as “Kutego”)

We have signed an authorized data processing contract with Kutego. Accordingly, Kutego is obliged to process your data only on our instructions and on our behalf. More detailed information about data processing at our providers can be found in their privacy policies. The legal basis for this data processing is our legitimate interests according to Article 6 paragraph 1 point f DSGVO in providing and operating the website on the internet as well as, if applicable, the statutory permission to store data during the creation of contractual relations according to Article 6 paragraph 1 point b DSGVO.

Each time this website is used, Kutego processes information called server log files, which are automatically transmitted by your browser when accessing the website on the internet.

This information includes:

• your IP address
• browser type and version
• hostname
• access time
• website from which you access our website
• the website name is called
• exact time of request
• amount of data transmitted

These data are used for statistical purposes only and do not enable us to identify you as a user.

Cookies

Necessary cookies

Our website uses cookies and possibly similar technologies such as pixels, web beacons or tags, within the framework of our legitimate interests to ensure that an online service operates correctly and is organized and economically optimized in accordance with Article 6, paragraph 1, point f DSGVO.

Cookies are text files that are saved on your computer and store certain data about your usage behavior. Cookies can be "session cookies", which are automatically deleted at the end of a website visit, or persistent cookies, which are stored on your computer for a certain period of time if you do not delete them. We may then recognize your browser on your next visit and provide you with functions appropriate to your previous use.

Our website only uses cookies that are necessary for website use and specifically does not use tracking or advertising cookies from outside.

Your browser allows you to prevent the use of cookies altogether or on a case-by-case basis. Please see your browser's instructions for use.

You can also delete cookies. Some instructions:

• Chrome
• Safari
• Firefox
• Edge
• Internet Explorer

Blocking cookies may limit the functionality of our website and other websites you visit.

More information about how to manage, limit or completely disable third-party cookies and similar technologies can be found at:

• aboutads.info/choices
• youronlinechoices.eu
• networkadvertising.org/choices
• 
  

Send email

Mailgun

Email sending is done partly through “Mailgun”, a US provider's email sending platformMailgun Technologies, Inc., 535 Mission St., San Francisco, CA 94105.

This provider is DSGVO certified to meet data protection laws and regulations in force in the EU. Further information about the provider's data processing can be found in Mailgun's DSGVO information and privacy policy.

Email delivery is only carried out through data centers located within the EU.

Advertisements & newsletters

For the submission of advertising, where necessary we will ask for your explicit consent in accordance with Article 4 No. 11 DSGVO, except in the case of advertising similar products that you have previously purchased. If you subscribe to the newsletter offered on our website, your data will not be transferred to third parties and will only be used to send the newsletter. We only send you newsletters if you have given your prior consent. To do this, you will receive an email from us containing a link, detailed instructions and a request to confirm consent. When you click on that link, you agree to receive newsletters and advertising from us.

Because we are required by law to obtain your consent through a process called “Double Opt-In”, your subscription to the newsletter, the sending of a consent email, and your consent by clicking on a link will be recorded and stored according to your location, time and IP address. The legal basis for storage is your consent according to Article 6, paragraph 1, point a DSGVO.

Emails used for newsletters contain a “web beacon” through which your opening of the newsletter and/or clicking on links within it will be sent to us. Through this, we receive information about your browser, location and IP address. This information is used to optimize how we communicate with you. Your data is retained as long as it remains on our email list, or as long as retention is necessary for the protection of legal rights, other legitimate interests, or retention obligations under law. Especially in the case of recording consent for sending the newsletter.

You may withdraw your consent at any time in accordance with the “Consent” section set out below. Data collected for the purpose of contractual relations will not be removed from that list.

Social network

Social network links

General note

We place links to our social media pages. Unlike social plugins, regular links do not make the social media platform aware of your visit as soon as you open our website. However, like any other link, at the latest when you click on the link, your data will be processed by the social media platform. Usually the platform will save cookies on your device or even save usage behavior tied to your account, especially if you are logged in. Social media platforms can analyze usage behavior and use that data for interest-tailored advertising. This may result in you seeing ads both on and off social media platforms. You should consider whether you accept this or not and should only use social media platforms if you are fully informed about the data processing there and agree to this.

Instagram

Our site uses links to our Instagram profile on the social network Instagram of Instagram LLC, now Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland.

This is just a regular link; when you visit our website, Instagram won't know about it. However, if you click on the link, you will be redirected to Instagram, and so Instagram or Facebook will also know that you have visited our website before.

Your data will be transferred by Facebook Ireland to Facebook in the United States based on standard contractual terms.

We do not know and have no influence on the collection and use of your data by Instagram/Facebook after you click on the link. More detailed information can be found in Instagram's privacy policy.

WhatsApp Business

To simplify communication with interested parties, users and customers, we use WhatsApp Business in individual chats based on our legitimate interest in fast, technical and always-available communication in accordance with Article 6 paragraph 1 sentence 1 point f DSGVO.

In order to communicate with you through this service, your active consent is required.

Requests related to our services are processed on the basis of the contract database according to Article 6, paragraph 1, point b and according to Article 6, paragraph 1, point a of DSGVO.

All communication via WhatsApp is encrypted end-to-end (peer to peer). Third parties cannot view the exchange content.

Your messages will be stored as long as the processing of the communication is required, in particular if storage is necessary for the performance/processing of a contract, the protection of our legal rights, our other legitimate interests or we are under a legal obligation to store your data.

The following consent applies to the data:

• Company name
• Name
• Last name
• Phone number
• Email address

for communications regarding:

• product and service consulting
• schedule an appointment
• New and updated information about products and services

through the instant messaging service WhatsApp.

I am aware that WhatsApp Ireland Limited receives personal data, in particular communication metadata, and that this data may also be processed on servers in non-EU countries such as the United States. WhatsApp also shares collected data with other companies within and outside the Meta group. I am also aware that these non-EU countries may not ensure an adequate level of data protection. WhatsApp uses standard contractual clauses approved by the European Commission to secure such data transfers.

I acknowledge that I may withdraw this consent at any time in the future, without giving a reason, by sending a notice of withdrawal of consent to communication via WhatsApp Business.

Map service

Google Maps

We use the Google Maps API, a mapping service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”), within the framework of our legitimate interest in ensuring a technically correct and economically optimized online service in accordance with Article 6 paragraph 1 point f DSGVO, to display interactive maps.

Use of Google Maps is based on a joint liability agreement under Article 26 DSGVO that we have entered into with Google Maps.

To protect your data, we have installed a “two-click” solution. Therefore, Google will not know about your visit to our website immediately upon opening the page, but only when you actually use the Google map service.

The use of Google Maps, in particular through active JavaScript, may result in information about your use of this website, including your IP address, being transmitted to Google LLC servers in the United States based on standard contractual clauses and stored there.

If you do not want your data to be transferred, you can disable JavaScript in your browser or install a JavaScript execution blocker. However, this may affect your use of our website and other websites.

Link to Google Maps

As part of our legitimate interests, we link to our business section on Google Maps so you can find us.

This link does not let Google know about your visit as soon as you open the website. However, as with all links, when you click on them your data is processed by Google. Google will then also know that you visited our website and searched for our location. Google can analyze your usage behavior and use it for advertising that matches your interests.

We have no knowledge or influence on Google's collection and use of your data after you click on the link.

Analytical tools

Matomo

We use Matomo, an open source web analytics tool, within the framework of our legitimate interests according to Article 6 paragraph 1 point f DSGVO.

Do not use cookies

We host Matomo ourselves internally, so no data is passed on to third parties. In addition, we use Matomo without cookies, so we only collect data as described in the "Usage Data" section.

Video conferences, webinars and online meetings

Zoom

We use an external communication service providerZOOM Video Communications Inc., San Jose Office, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USAfor video conferences, audio conferences, webinars or other online meetings and communications. This happens:

• within the framework of contractual or pre-contractual relations according to Article 6, clause 1, point b DSGVO;
• within the framework of your consent, if we have obtained such consent in advance, for example for video recording, pursuant to Article 6 paragraph 1 point a DSGVO;
• or within the framework of our legitimate interests according to Article 6, paragraph 1, point f DSGVO.

Each time you use an external communication provider, all data that you declare, enter or display during the communication process will be transferred to that provider and saved there. Specifically, this includes basic data such as name and email, usage data such as browser used, websites visited, length of stay, referrer URL and IP address, as well as content data such as audio and video communications and/or recordings, chat history, shared screen content. We ourselves try to use data protection-friendly settings; You can also take measures such as using aliases, disposable emails, or partially turning off the audio/video.

Your data is therefore transferred to the United States. We have signed with the communications service provider a contract based on standard contractual clauses, in which the provider commits to protecting your data in accordance with DSGVO standards. We have also entered into an authorized data processing contract with this provider under which they process your data only on our instructions.

Your data is retained as long as necessary for the purposes of consent, for the performance/processing of a contract, to protect our legal rights, for other legitimate interests, or because of a legal obligation to retain it.

Your data will not be passed on to third parties by us and our external communication providers. The exception may be the provider's analysis of usage data for service, security or marketing purposes. For further use of your data by external communication providers, please see their terms and privacy policies.

If an external communications provider stores cookies or other trackers on your device, we refer to the general statement on cookies in this privacy policy.

Changes to privacy policy

If the privacy policy needs to be changed for legal or practical reasons, we will update this page accordingly. This will not affect consents already granted by the user.

Last updated: January 17, 2026