Privacy Policy

We use the data you provide to fulfil and complete the requests you make with us or on our website. Depending on the purpose, we rely on the following legal grounds set out in Article 6 (1) GDPR:

• the performance of a contract with you, for example when you book a trip (lit. b)
• compliance with legal obligations, for example tax and travel law (lit. c)
• our legitimate interests, for example improving our service, securing our website, and corresponding with you efficiently (lit. f)
• your consent, for example for our newsletter or non-essential cookies (lit. a)

If your travel contract requires it, we forward your personal data to the relevant offices in other countries.

We process the data you share with us so that we can book, organise, and complete your trip. We only keep personal details such as your first name, surname, street, house number, postal code, city or town, date of birth, language, nationality, gender, email address, telephone number, and any allergies or dietary preferences if we genuinely need them for the service you have requested. We use your details when you book a trip with us, request an offer, contact us through our website, order a catalogue, or sign up for our newsletter.

We process your data within the EU. Where the law allows it, processing may also take place in other European or non-European locations. We need to share your personal data with relevant partners and institutions, such as airlines, language schools, host families, insurance companies, hotels, or hotel reservation teams, so that we can fulfil your contract.

When data is transferred to countries outside the European Economic Area, we make sure that an appropriate level of protection is in place. This is achieved through European Commission adequacy decisions, EU Standard Contractual Clauses, or, where applicable, the EU-US Data Privacy Framework.

If you book with us, we share your data with the service providers we work with to make your trip happen. These include airlines, language schools, host families, insurance companies, hotels, hotel reservation staff, and the SPRACHCAFFE team members responsible for your booking. We also pass on your details to delivery partners when we send you documents, catalogues, or emails. Your payment details are forwarded to the relevant payment providers, financial institutions, and our payment team to complete the transaction with the payment method you have chosen.

We use AI assistants, currently Claude (Anthropic) and Microsoft Copilot, to support our team in everyday tasks such as drafting customer emails, translating content, summarising enquiries, and preparing booking-related communication. In some cases, this means that personal data you have shared with us, for example your name, email address, or details of your booking, may be processed through these AI tools.

We only use business accounts of these services and have selected the EU data residency options offered by the providers, so that your data is processed within the European Union wherever this is technically available. Under the terms of these accounts, your data is not used to train the underlying AI models, is not shared with third parties for advertising purposes, and is processed in line with the GDPR. Access is limited to authorised SPRACHCAFFE staff. We use these AI tools as a working aid for our team, and we do not carry out any automated decision-making within the meaning of Article 22 GDPR. Final responsibility for every reply, document, or decision always rests with our team.

The legal basis for this processing is our legitimate interest in efficient customer service and internal workflows (Article 6 (1) lit. f GDPR). You have the right to object to this processing at any time on grounds relating to your particular situation.

We store your data only for as long as it is needed for the purposes set out above, or as required by law. For all business-relevant transactions, in particular bookings, contracts, invoices, and related correspondence, we are required by Maltese tax and commercial law to keep records for at least ten years from the end of the financial year in which the transaction took place. After this retention period ends, we delete or anonymise your data, unless a longer storage obligation applies in a specific case. For data we process on the basis of your consent, for example newsletter subscriptions, we keep your details until you withdraw your consent.

If you have found our website through a Google ad, an affiliate ad, or an email, Google AdWords places a cookie on your computer, provided you have given your consent. This cookie does not allow anyone to identify you personally. The information it contains helps us produce statistics and measure our conversion rates. In other words, it shows us how many users have reached our site through Google ads, affiliate ads, or email links, and how many users have become aware of one or more of the offers on our website.

If you would prefer not to take part in tracking, you can withdraw your consent at any time through our cookie settings, or block the relevant cookies in your browser:

Google Ads: adssettings.google.com
SPRACHCAFFE: sprachcaffe.com

We use cookies to provide and improve our online offers. Cookies are small text files that are stored on your computer. They allow us to recognise whether the same computer is being used to visit our website more than once.

Our website uses a cookie consent tool. When you visit us for the first time, you can decide which categories of cookies you want to allow. We only set non-essential cookies, such as those used for analytics, marketing, or social media plug-ins, after you have given your consent. Essential cookies that are needed for the basic functions of the website are set without consent, in line with the law.

You can change or withdraw your consent at any time through the cookie settings on our website. You can also adjust your browser settings so that cookies are not stored, or so that they are deleted at the end of your internet session. Please note that some functions on our website may not work properly if you do this. You can find more information about browser settings here. Further details such as your name, address, phone number, or email address are only known to us if you choose to share them with us.

You can use our live online chat service free of charge. The chat service uses cookies that allow us to analyse how this website is used. The data collected is not combined with any personal information you have shared with us. This option only applies if the chat feature is available on the page you are using.

This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"), based on your consent. Google Analytics uses cookies, which are text files stored on your computer. These cookies allow us to analyse how the website is used. The information generated about your use is usually transferred to a Google server in the USA, where it is stored. If you have activated IP anonymisation on this website, Google will shorten your IP address within the member states of the European Union or other contracting states of the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. Google will use this information on behalf of the website operator to evaluate your use of the site, to compile reports on website activity, and to provide further services related to website and internet use. The IP address transmitted by your browser as part of Google Analytics will not be combined with other Google data. Transfers to the USA are based on the EU-US Data Privacy Framework or, where applicable, EU Standard Contractual Clauses.

You can withdraw your consent at any time through our cookie settings.

We use Google Maps on certain pages to display maps and locations and to support route planning. Google Maps is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. As soon as you visit a page with Google Maps embedded, your IP address is sent to Google and a cookie is stored, provided you have given your consent.

You can find out more about how Google processes your data at https://policies.google.com/privacy?hl=en&gl=en, where you can also object to this processing.

You can prevent the transfer of your user data and website data, such as your IP address, to Google by withdrawing your consent in our cookie settings, or by installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout?hl=en

We use plug-ins from the social media site facebook.com on some of our pages, based on your consent. Facebook.com ("Facebook") is operated by Facebook Inc., 1601 California Ave, Palo Alto, CA 94304, USA. When you visit one of our pages with such a plug-in active, your browser establishes a connection with Facebook's servers, and the plug-in is displayed on the page. Facebook's server is then informed which of our pages you have visited. If you are logged in to Facebook while visiting our website, Facebook will automatically link your activity on our site to your personal Facebook account. If you use plug-in functions such as the "like" button or the comment field while logged in, this information is also linked directly to your Facebook profile. You can prevent this by logging out of Facebook before visiting our website, or by withdrawing your consent in our cookie settings. You can find more information on the purpose, scope, further use, and processing of data by Facebook, as well as your rights and privacy settings, at: www.facebook.com/policy.php.

You can subscribe to our newsletter on our website. We use a double opt-in process: after you enter your email address, we send you a confirmation email with a link. We only add you to our newsletter list once you have clicked this link to confirm your subscription. This makes sure that nobody can sign up using someone else's email address.

We use Microsoft Dynamics to send our newsletter and to manage our email marketing. Your email address and the data you provide are processed within Microsoft Dynamics for this purpose. The legal basis is your consent under Article 6 (1) lit. a GDPR.

If you provide your email address as part of a booking, we may also send you regular emails with offers and information about products similar to those you have already booked with us, unless you object. The legal basis for this is our legitimate interest in customer communication under Article 6 (1) lit. f GDPR, in line with the conditions for direct marketing to existing customers.

You can unsubscribe from our newsletter and email advertising at any time, free of charge, by clicking the unsubscribe link in any of our emails or by contacting us using the details below.

Under the GDPR, you have the following rights regarding your personal data:

• Right of access (Article 15): You can ask us whether we process personal data about you, and if so, request a copy of that data along with information about how we use it.
• Right to rectification (Article 16): You can ask us to correct inaccurate data or complete incomplete data.
• Right to erasure (Article 17): You can ask us to delete your personal data, provided no legal retention obligation prevents this.
• Right to restriction of processing (Article 18): You can ask us to limit the processing of your data in certain circumstances.
• Right to data portability (Article 20): You can ask us to provide the data you have given us in a structured, commonly used, and machine-readable format, or to transmit it to another controller.
• Right to object (Article 21): You can object at any time to processing based on our legitimate interests, including direct marketing.
• Right to withdraw consent (Article 7): Where processing is based on your consent, you can withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal.

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU member state where you live, where you work, or where the alleged infringement took place. The competent authority for SPRACHCAFFE Languages Plus in Malta is:

Office of the Information and Data Protection Commissioner
Address: Airways House, Second Floor, High Street, Sliema SLM 1549
Phone: +356 2328 7100
Fax: +356 2328 7198
Email: idpc.info_ett_@gov_dot_.mt
Website: www.dataprotection.gov.mt

Before contacting the supervisory authority, you are welcome to reach out to our Data Protection Officer first, so that we can try to resolve your concern directly.

We reserve the right to update our security and data protection measures as technology develops. When we do, we will also update this Privacy Policy. Please check the latest version regularly.

If you have any questions or concerns about this Privacy Policy, you can contact our Data Protection Officer, Simon Wismeth, using the details below:

SPRACHCAFFE Languages Plus
Address: Alamein Road, St. Julians, Pembroke, PBK 1776 Malta
Phone: +356 21 373574
Email: privacy_ett_@sprachcaffe_dot_.com

Company responsible for the Privacy Policy

SPRACHCAFFE Languages Plus
Address: Alamein Road, St. Julians, Pembroke, PBK 1776 Malta
Phone: +356 21 373574
Fax: +356 21 373577
Email: malta_ett_@sprachcaffe_dot_.com