Privacy Policy

The data controller responsible for personal data processing on the Germany/Europe website (/de/de, /de/en, /de/ar) pursuant to the GDPR is:

REQUIRED_BEFORE_PRODUCTION

Trading as: Success Path Mentors Europe / Success Path Mentors Germany

Registered Address: REQUIRED_BEFORE_PRODUCTION

Commercial Registration Number: REQUIRED_BEFORE_PRODUCTION

VAT Identification Number: REQUIRED_BEFORE_PRODUCTION_OR_NA

Email: europe@successpathmentors.net | WhatsApp: +49 1512 3974353

For any privacy inquiries or to exercise your GDPR rights, please contact our European coordination team directly at europe@successpathmentors.net.

This Privacy Policy applies specifically to the Germany and Europe section of Success Path Mentors, including pages under /de/de, /de/en, and /de/ar, free trial requests, registration and authentication, SPM Portal/LMS access, and associated tutoring coordination.

It does not govern the separate North American Success Path Mentors market pages, which operate under distinct legal terms.

We collect and process personal data directly provided by parents, legal guardians, students, and adult learners, including:

• Parent/Guardian Details: Full name, email address, telephone and WhatsApp number, relationship to the learner.
• Student Information: Name, educational level/grade, current academic status, requested subject, curriculum, preferred teaching language, and goals.
• Scheduling and Coordination Preferences: Country of residence, time zone, preferred lesson days, and preferred times.
• Account & Authentication Data: Verification status, account credentials, and authentication records received via Email OTP, WhatsApp OTP, or integrated providers (Google, Facebook) where enabled.
• Technical Information: IP address, browser type, device information, operating system, timestamp, server logs, and security events necessary for service integrity and protection.

We process your personal data in strict adherence to the GDPR under the following legal bases:

• Article 6(1)(b) GDPR (Contractual Necessity & Pre-contractual Steps): To respond to trial lesson inquiries, evaluate learner requirements, coordinate and match qualified tutors, manage user accounts, and provide agreed tutoring services.
• Article 6(1)(c) GDPR (Legal Obligations): To comply with statutory legal, commercial, tax, and accounting retention obligations.
• Article 6(1)(f) GDPR (Legitimate Interests): To safeguard IT security, prevent fraud, verify contact authenticity, and maintain smooth, high-quality tutoring coordination.
• Article 6(1)(a) GDPR (Consent): Where you have provided voluntary consent (e.g., for optional marketing or non-essential cookies). You may withdraw consent at any time with future effect.

Many of our tutoring services involve learners who are minors. Registration, lesson booking, and account creation for minors must be performed by a parent or legal guardian.

We process minor learner information strictly for educational, lesson planning, and tutoring purposes. We do not use children’s information for behavioral advertising or profiling, nor do we disclose it to unauthorized third parties.

To ensure account security, we support secure authentication workflows:

When verifying via Email or WhatsApp OTP (One-Time Password), a short-lived verification code is transmitted to confirm ownership of the provided contact channel.

Where Google or Facebook social login is selected, the external identity provider processes data under its own privacy policy. Success Path Mentors receives only the data necessary to authenticate, create, or link your account. Third-party logins are enabled conditionally based on configuration.

Tutoring coordination, lesson schedules, educational records, and study materials are managed via the Success Path Mentors Portal and associated administrative systems.

Access to learner records is strictly limited to authorized coordinators and the designated tutor assigned to the learner, all of whom are bound by confidentiality obligations.

We utilize trusted service providers for web hosting, cloud infrastructure, authentication, customer communication, and security (such as Vercel, Google, Meta/Facebook, and WhatsApp where enabled).

All processors are bound by Data Processing Agreements pursuant to Article 28 GDPR, ensuring data is processed only under our explicit instructions and with adequate security safeguards.

Certain technical service providers may process personal data in countries outside Germany and the European Economic Area (EEA).

Where international transfers take place, we ensure appropriate safeguards are established, such as European Commission Adequacy Decisions (including the EU-U.S. Data Privacy Framework) or Standard Contractual Clauses (SCCs).

We use strictly necessary technologies and session cookies essential for core website operations, language selection, navigation, authentication, and security. Under § 25(2) TDDDG, these do not require prior consent.

Non-essential tracking, analytics, or marketing technologies are not activated without your prior express consent. Users may withdraw or modify optional consent settings at any time with future effect.

We retain personal data only for as long as necessary to achieve the intended purpose:

Contractual, invoicing, and billing records are stored in compliance with statutory commercial and tax retention mandates (typically up to 6 or 10 years).

Temporary verification transactions and OTP records are deleted automatically after short validity periods.

When data is no longer required and statutory retention requirements have lapsed, records are securely deleted or irreversibly anonymized.

Under the GDPR, individuals located in the EU/EEA enjoy specific enforceable rights:

• Right of Access (Article 15 GDPR) regarding your personal data processed by us.
• Right to Rectification (Article 16 GDPR) of inaccurate or incomplete data.
• Right to Erasure / Right to be Forgotten (Article 17 GDPR), subject to statutory exceptions.
• Right to Restriction of Processing (Article 18 GDPR).
• Right to Data Portability (Article 20 GDPR) in a structured, machine-readable format.
• Right to Object (Article 21 GDPR) against processing grounded on legitimate interests under Art. 6(1)(f) GDPR.
• Right to Withdraw Consent (Article 7(3) GDPR) at any time without affecting prior lawful processing.
• Right to Lodge a Complaint (Article 77 GDPR) with a competent data protection supervisory authority.

Success Path Mentors does not utilize solely automated decision-making or profiling mechanisms under Article 22 GDPR that produce legal or similarly significant effects. Tutor selection and lesson coordination always involve human evaluation by our coordination team.

We maintain robust technical and organizational security measures (TOMs) to safeguard personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Security measures are continuously evaluated and updated.

We may update this Privacy Policy periodically to reflect technological advancements, service updates, or evolving legal frameworks. The current version and effective date will always remain accessible on this page.