Privacy Policy of Primlo UG (haftungsbeschraenkt)

1. About PRIMLO, its Service Provider and Responsible Party

1.1. PRIMLO is a service for learning the Chinese language, made available in form of a mobile app, to be downloaded onto mobile devices.

1.2. Service provider in terms of §13 TMG (Telemediengesetz) as well as responsible party in terms of §3 Abs.7 BDSG (Bundesdatenschutzgesetz) is:

PRIMLO UG (with limited liability)
Hirschbergstraße 21
50939 Cologne
Tel.: +49 221 86 94 874

2. General principles of data protection and data security

2.1. Personal data is any information concerning personal or material circumstances of an identified or identifiable natural person, i.e. data allowing for conclusions regarding a person’s identity, e.g. name, date of birth, address, telephone number and email-address.

2.2. When visiting our SITE or using the APP your personal data is collected, processed and used only to the extent necessary for accessing the services of PRIMLO as well as for making PRIMLO more user-friendly, more efficient and more secure. In this we strictly abide by the relevant data protection regulations, in particular by the Federal German Data Protection Act (Bundesdatenschutzgesetz) and the Federal German Telemedia Act (Telemediengesetz).

2.3. The collection, processing and usage of your personal data shall only be effected on the basis of a statutory provision or, in the absence of such, with your prior express consent. Both anonymous use of PRIMLO as well as through a pseudonym is possible insofar as is technically possible and reasonable.

2.4. Without your prior express consent and if no longer required for handling purposes, after usage of PRIMLO, all personal data will be blocked against further utilization. Upon expiration of retention periods according to tax and commercial law all personal data collected will be deleted.

2.5. Forwarding your personal data to third parties only occurs if required for handling or contract processing purposes or in case we have received your prior consent. For the rest disclosure and transmission will only be effected on the basis of statutory exceptions, e.g. upon request by courts or authorities.

2.6. We maintain up-to-date technical measures to ensure data security, in particular for protecting your personal data against risks arising from data transfers and unauthorized acquisition by third parties. Appropriate adaptions will be made to keep such measures always correspondent to the current state of technology.

3. Personal information directly collected whilst using the PRIMLO-Website

3.1. The SITE serves solely for general information about PRIMLO. The use of PRIMLO and its functions, features and services is currently possible through the APP only. When visiting the SITE, no personal information other than those listed below, which is automatically transferred by your browser in order to enable you to visit the SITE at all, is collected:

  • IP-address of the requesting device
  • Date and time of the request
  • Time Zone
  • Content of the request
  • HTTP-status code
  • Data volume transferred
  • The requesting website
  • Browser type and version
  • Device type designation
  • Operating System
  • IP-address of the requested server
  • Click paths
  • Hostname

The aforesaid information is collected without any conclusion on your person being possible.

4. Personal information directly collected, processed or used whilst using the APP

4.1. If you download the APP from Apple’s App-Store, information and data insofar necessary will be transferred to the App-Store. If you download the APP from Google’s Play-Store, information and data insofar necessary will be transferred to the Play-Store. We have no influence over such data-collection and therefore can not assume any responsibility for it. We only process the data provided to the extent necessary for downloading the App onto your device. No such data will be stored beyond this.

4.2. You may use PRIMLO without giving any personal information. For this you may skip the registration process when first using the App and create an anonymous user account with a randomly generated name. In that case, no personal information other than that listed below, which is automatically transferred by your device in order to enable you to use the APP at all, is collected:


  • IP-address of the requesting device
  • Date and time of the request
  • Time Zone
  • Content of the request
  • HTTP-status code
  • data volume transferred in bites
  • the requesting application
  • browser type and version
  • device’s type designation
  • OS
  • IP-address of the requested server
  • API endpoints
  • Hostname

The aforesaid information is collected without any conclusion on your person being possible.

4.3. Further personal information, including but not limited to name, username/ pseudonym, password and e-mail-address, will be collected, only if voluntarily provided by you, e.g. in line with the registration process. If you register with PRIMLO using the “Sign up” button, you consent to the storage of your inventory (e-mail-address) as well as usage data (user name, password). This provides you with access to your data and allows you to maintain and update such data without re-entering your personal information for any future use of PRIMLO. You may revoke your consent at any time with future effect by sending an e-mail to: .

4.4. After login, the learning content chosen along with information about the learning process and progress, e.g. duration and type of learning session, repetitions and user’s feedback, if any, will be stored, summarized and made available to you in form of statistics.

4.5. Further personal information will be stored, processed and used in the following events:

  • if you yourself contact us by e-mail (see clause no. 5. hereinafter)

5. Inquiry, Contact

All personal information voluntarily provided with user’s consent will be stored and used by PRIMLO only to answer your request. As far as such personal information relates to means of communication, like e-mail-addresses and/or telephone numbers you implicitly agree to us contacting you by using the respective means of communication. Here too, you may revoke your consent at any time with future effect by sending an e-mail to: .

6. Usage of cookies and analytics tools

6.1. In order to render its services more user-friendly, efficient and attractive and also to recognize you the next time you use PRIMLO, we may collect certain information using cookies, i.e. small text files stored on your device, resp. a technology with similar functions. Most of such files are deleted automatically as soon as you end your visit, others remain on your device. Neither will programs be executed nor will viruses be transferred herewith. However, you may deactivate the application of Cookies at any time changing the settings in your browser. For details please refer to the operation instructions of your browser.

6.2. Furthermore, PRIMLO uses „MIXPANEL“, an analytics service for websites and mobile applications of Mixpanel Inc., 405 Howard St, Floor 2, San Francisco, CA 94105 („Mixpanel“). MIXPANEL does its service in part using a first party cookie, i.e. small text files, placed from PRIMLO’S server on user’s device.

In addition Mixpanel uses so called “Pixel Tags” (also referred to as “Web beacons”), i.e. small image files, similar to Cookies, to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages.

The information generated by MIXPANEL allows us to learn about how the users use the APP by enabling us to collect certain information based on user’s interaction with the APP. None such information is tied to users’ personal data.

6.3. Mixpanel collects, stores, and uses the collected data to maintain and improve their services. Mixpanel may also use the data in an anonymous and aggregated form for its own business purposes. Mixpanel transfers the data to servers that store data in the U.S. and outside the U.S. It will be shared with others if Mixpanel uses third parties to perform its services or to the extent needed to comply with laws or to respond to lawful requests and legal processes, to protect the rights and property of Mixpanel, its agents, customers, and others including to enforce Mixpanel’s agreements, policies, and terms of use, in a case of emergency, including the personal safety of any person; or in connection with a sale or transfer of all or a part of Mixpanel’s business or assets (business deals may include, for example, any merger, financing, acquisition, divestiture, or bankruptcy transaction or proceeding).

6.4. By using PRIMLO you consent to the collection and use of your data by Mixpanel as described hereinabove.

7. Right to information, deletion and revocation

7.1. You are at any time entitled to free-of-charge information about your personal data stored with us, the origin, the recipient or categories of recipients to which such data is forwarded, if at all, about the purpose of the storage as well as the right to correct, block or delete such data.

7.2. You may revoke your consent to the collection, processing, use and transfer of your personal information at any time with effect for the future.

7.3. If you have any questions regarding the collection, processing or use of your personal data, and for information, correction, blocking and deletion of data as well as for revocation of your consents please refer to or the address mentioned in clause 1.2. hereinabove.

8. Changes of this Privacy Policy

8.1. PRIMLO reserves the right to change or otherwise alter its privacy policy at any time in accordance with the relevant applicable data protection regulations. This will be reflected by the date below. You are advised to check this page from time to time to inform yourself of any such changes. Continued use of PRIMLO will constitute agreement to any amendments.

Effective Date: 29th Aug, 2017