Privacy Policy

1. Controller

The controller responsible for the processing of personal data on this website is:

Sergej Gamza

Easy Guitar School

28, Route d'Echternach

L-1453 Luxembourg

Email: info@easyguitar.lu

2. General Information

The protection of your personal data is important to us. We process personal data exclusively in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR” / “RGPD”) and the data protection regulations applicable in Luxembourg. The competent data protection supervisory authority in Luxembourg is the Commission nationale pour la protection des données (CNPD).

Personal data means any information relating to an identified or identifiable natural person.

3. Processing of Personal Data When Visiting the Website

When you access our website, technically necessary information is automatically collected. This includes, in particular, the IP address, date and time of access, browser type, browser version, operating system, referrer URL, pages and files accessed, language settings, access status, and error messages.

This data is processed in order to technically provide the website, ensure the stability and security of the system, and detect misuse or disruptions. The processing is based on Article 6(1)(f) GDPR, as we have a legitimate interest in providing a secure and functional online service.

4. Contact

If you contact us by email, contact form, telephone, or by any other means, we process the data you provide, in particular your name, email address, telephone number, the content of your message, and any other information voluntarily submitted.

The processing is carried out for the purpose of handling your request and communicating with you. The legal basis is Article 6(1)(b) GDPR where your request relates to a contract or pre-contractual measures, and otherwise Article 6(1)(f) GDPR.

5. Online Shop, Digital Products, and Video Courses

Digital products such as arrangements, sheet music, PDF files, downloads, and video courses may be purchased through our website. In the context of an order, we process in particular first and last name, billing address, email address, order data, purchased products, payment status, and invoice and transaction data.

The processing is carried out for the performance of the contract, in particular for order processing, provision of digital content, activation of video courses, communication in connection with the purchase, and handling of technical support requests. The legal basis is Article 6(1)(b) GDPR. Where statutory retention obligations apply, processing is additionally based on Article 6(1)(c) GDPR.

If you use purchased video courses or digital content through a protected area, we also process the access data required for this purpose, password information in encrypted form, and technical usage data insofar as this is necessary for providing access, stability, and security. This processing is based on Article 6(1)(b) GDPR and Article 6(1)(f) GDPR.

6. Payment Processing via Stripe

We use Stripe for payment processing. In this context, the personal data required for payment is transmitted to Stripe and processed there. The specific data processed by Stripe depends on the selected payment method and the payment process. Stripe provides its own privacy documentation and a Data Processing Agreement.

The processing is carried out for the performance of the contract and is therefore based on Article 6(1)(b) GDPR. Where Stripe acts as an independent controller in certain situations, Stripe’s privacy information applies in addition. Stripe also states that international data processing may take place as part of its services; for this purpose, Stripe provides, among other things, a DPA and information on the Data Privacy Framework.

7. Hosting and Storage via Hostinger

Our website and the video courses offered by us are hosted or stored with Hostinger. Hostinger may process personal data insofar as this is necessary for hosting, technical provision, system security, backups, and maintenance. Hostinger provides a privacy policy and a Data Processing Addendum for this purpose.

The processing is based on Article 6(1)(f) GDPR. Where Hostinger processes personal data on our behalf, this is carried out as commissioned processing pursuant to Article 28 GDPR.

8. Recipients of Personal Data

Personal data is disclosed to third parties only insofar as this is necessary for the provision of the website, performance of the contract, payment processing, technical support, or due to legal obligations. Recipients may include, in particular, hosting providers, payment service providers, IT service providers, tax advisors, accounting services, authorities, or courts.

Such disclosure takes place only where there is a data protection legal basis, in particular under Article 6(1)(b), (c), or (f) GDPR.

9. Cookies and Similar Technologies

Our website may use cookies and similar technologies. Technically necessary cookies may be used insofar as they are required for the operation of the website, security functions, login areas, shopping cart functions, or the provision of services expressly requested by the user.

For non-essential cookies or trackers, in particular for analytics, statistics, marketing, or similar purposes, prior consent is generally required according to the guidelines published by the CNPD. A mere reference in the privacy policy is not sufficient for this purpose. If such technologies are used, they may only be activated after appropriate consent has been obtained via a cookie banner or consent tool.

10. Storage Period

We store personal data only for as long as this is necessary for the respective processing purposes or as long as statutory retention obligations apply. The GDPR requires information to be provided on the storage period or at least on the criteria used to determine it.

Server log data is stored only for as long as this is technically necessary and required for security purposes. Contact requests are stored until final processing and thereafter only insofar as this is necessary for evidence or legal obligations. Contract, order, invoice, and payment data are stored in accordance with statutory commercial and tax retention obligations. Access data for customer accounts or course areas is stored until the account is deleted or until the purpose no longer applies, unless statutory retention obligations prevent deletion.

11. Transfer of Data to Third Countries

Where personal data is processed outside the European Economic Area in connection with the service providers used, this is carried out only in compliance with the statutory requirements of the GDPR. Permissible bases may include, in particular, an adequacy decision by the European Commission or appropriate safeguards such as standard contractual clauses.

For Stripe, official information on international data transfers, the Data Processing Agreement, and the Data Privacy Framework is available. For Hostinger, the specific data processing must be reviewed based on the respective services used and contractual documents.

12. Rights of Data Subjects

Under the GDPR, you have in particular the right of access, rectification, erasure, restriction of processing, data portability, objection to processing, and the right to withdraw any consent given at any time with effect for the future. You also have the right to lodge a complaint with a data protection supervisory authority. The CNPD is the competent supervisory authority in Luxembourg.

To exercise your rights, you may contact us at any time at info@easyguitar.lu.

13. Data Security

We take appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, unauthorised alteration, or unauthorised disclosure. Despite all due care, complete protection during data transmission on the internet cannot be guaranteed in every case.

14. External Links

Our website may contain links to external websites. The respective operators of such external websites are solely responsible for their content and data protection practices. Please consult the relevant websites separately for information about the processing of personal data.

15. Contact

If you have any questions about this Privacy Policy or the processing of personal data, you may contact us at any time:

Easy Guitar School

28, Route d'Echternach

L-1453 Luxembourg

Email: info@easyguitar.lu