Privacy Policy for Snipwise

Disclaimer: Only the German version of this legal text is legally binding. This English translation is provided for informational purposes only and does not constitute a legal document.

As of March 26, 2026

This privacy policy applies to the Snipwise offering of Max Universe GmbH—in particular the Snipwise website, the Snipwise app, and the functions and services offered in that context.

Important note on scope:
This privacy policy does not apply to other offerings under the domain max-talent.de, in particular not to recruiting, talent pool, or career services of Max Universe GmbH. Separate privacy notices apply to those offerings.

1. Controller

The controller responsible for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:

Max Universe GmbH
Im Mediapark 5
50670 Cologne
Germany

Email: Luis@max-talent.de

No data protection officer has been appointed at this time.

2. General Information on Data Processing

We process personal data of our users in order to provide Snipwise, enable use of our content, operate the website and app technically, improve the user experience, communicate with you, and—where offered—process paid services.

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

We process personal data only to the extent permitted by law, in particular:

for the performance of a contract or for steps prior to entering into a contract,
on the basis of consent,
for compliance with legal obligations,
or on the basis of our legitimate interests, unless your overriding interests or fundamental rights prevail.

3. What Data We Process

Depending on how you use Snipwise, we process in particular the following categories of personal data:

Contact and registration data (e.g. name, email address)
Access credentials (e.g. password in hashed form)
Profile data (e.g. interests, goals, industry context, approximate age group)
Usage data (e.g. content read or listened to, learning progress, completed units, bookmarks/favorites)
Device and technical data (e.g. IP address, device information, operating system, app version, browser information, access times, log data)
Communication data (e.g. content of support requests, messages via the feedback form, email communication)
Marketing and tracking data (e.g. cookie IDs, advertising IDs, usage events, campaign attribution)
Payment-related data (where paid services are offered), in particular information on subscription status, payment status, and transaction-related identifiers of the payment providers or app store platforms used

4. Registration, User Account and Login

Using Snipwise requires creating a user account.

In connection with registration and account management, we process in particular:

name
email address
password (stored exclusively in hashed form)
technical data related to login, security, and session management

Purposes of processing:

setting up and managing the user account
authentication and login
provision of personalized features
fraud prevention and security
communication in connection with the user account

Legal bases:

Art. 6(1)(b) GDPR (performance of a contract)
Art. 6(1)(f) GDPR (legitimate interest in IT security, fraud prevention, and stable provision of the service)

5. Onboarding, Profile Data and Personalization

During onboarding we may process additional information from you, in particular regarding:

your industry or professional environment,
your approximate age group,
your goals and interests (e.g. further education, knowledge building, career development),
your preferences regarding content and use.

Purposes of processing:

adaptation and personalization of content and recommendations
user-friendly design of the offering
improvement of our content and product features
statistical analysis of use and interests in aggregated form

Legal bases:

Art. 6(1)(b) GDPR, where the data are required to provide personalized features
Art. 6(1)(f) GDPR, where processing serves our legitimate interest in user-oriented product design and product improvement
Art. 6(1)(a) GDPR, where we obtain consent for individual personalization or tracking measures

6. Use of the App and Service

When you use Snipwise, we process data necessary to provide content and features. This includes in particular:

content accessed
audio usage
learning progress
completed books, summaries, or learning units
bookmarks/favorites
technical events within the app or website

Purposes of processing:

provision of content and core functionality
synchronization of your progress via your user account
improvement of stability, performance, and user experience
error analysis and fraud prevention

Legal bases:

Art. 6(1)(b) GDPR (provision of the service)
Art. 6(1)(f) GDPR (product improvement, system security, error analysis)
Art. 6(1)(a) GDPR, where consent-based tracking or analytics technologies are used

7. Contact, Support and Feedback Form

If you contact us or use the feedback form in the app, we process the data you provide. These may include in particular:

name
email address
content of your message
where applicable, technical context information relating to the request

Purposes of processing:

handling your inquiry
support and troubleshooting
documentation and quality assurance
further development of our offering based on your feedback

Legal bases:

Art. 6(1)(b) GDPR, where your inquiry relates to use of our offering or a contract
Art. 6(1)(f) GDPR (legitimate interest in efficient support, communication, and product improvement)

8. Email Communication, Product Information and Newsletter

We process your email address to send you contract- or use-related information about your account or our offering. This includes e.g. registration confirmations, security-related notices, notices of changes to our services, or information about your subscription.

Where you give separate consent or this is permitted under applicable law, we also process your data to send you newsletters, product information, or notices about new features and content.

Purposes of processing:

sending transactional emails
communication regarding your user account
product updates
newsletters and direct marketing

Legal bases:

Art. 6(1)(b) GDPR for contract- and account-related emails
Art. 6(1)(a) GDPR for newsletters and other consent-based marketing communications
Art. 6(1)(f) GDPR, where processing constitutes permissible communications to existing customers to the extent allowed by law

For sending emails and newsletters we may use external service providers, in particular Brevo, where that service is actually used.

9. Push Notifications

If you enable push notifications on your device, we may send you notices about new content, reminders, product updates, or use-related notifications.

In doing so, we process in particular device-related push tokens and information on whether and when notifications were delivered or opened, where technically available.

Legal basis:

Art. 6(1)(a) GDPR, where sending is based on your consent or activation of push notifications
Art. 6(1)(b) GDPR, where individual notifications are necessary for use of the service

You can disable push notifications at any time in your device or app settings.

10. Payments, Subscriptions and Paid Services

Where we offer paid services, subscriptions, or in-app purchases, we process personal data to initiate, perform, and manage those services.

Depending on the payment option offered, this may include in particular:

selected subscription model (e.g. monthly, annual)
contract start, term, renewal, and cancellation status
payment status
transaction or order identifiers
platform-specific identifiers of app store operators
where applicable, billing or payment information required to process the transaction

Possible payment channels:

in-app purchases via the Apple App Store
in-app purchases via the Google Play Store
payments via our website, in particular via payment service providers such as Stripe, where such a payment function is offered

Please note that app store operators and payment service providers may process certain data as independent controllers under data protection law.

Purposes of processing:

provision of paid services
billing and payment processing
managing your subscription status
detection and prevention of abuse and fraud
handling refunds, cancellations, and support cases

Legal bases:

Art. 6(1)(b) GDPR (performance of a contract)
Art. 6(1)(c) GDPR, where statutory retention and documentation obligations apply
Art. 6(1)(f) GDPR (fraud prevention, enforcement of claims, secure payment processing)

Based on your instructions, we currently store primarily payment status and provider IDs where this is necessary to manage your access.

11. Hosting, Technical Service Providers and Infrastructure

To operate Snipwise technically, we use external service providers, in particular for hosting, data storage, authentication, app infrastructure, analytics, message delivery, and IT security.

Based on the information you have provided, we use in particular Firebase. Depending on configuration, this may include services for hosting, authentication, database, app operations, analytics, performance measurement, crash reporting, or push notifications.

Where we engage external processors, this is done on the basis of data processing agreements where required by law.

Legal bases:

Art. 6(1)(b) GDPR, where use is necessary to perform our contract with you
Art. 6(1)(f) GDPR, where use serves our legitimate interest in secure, efficient, and scalable technical provision
Art. 6(1)(a) GDPR, where individual services are used only on the basis of your consent

12. Server Log Files and Technical Provision

When you visit our website or use our app, technically necessary information is generated that may be processed in server log files or comparable system logs. This includes in particular:

IP address
date and time of access
requested content
information about browser, operating system, device, or app version
referrer URL, where transmitted
error messages and system events

Purposes of processing:

technical provision of the website and app
system security and stability
error diagnosis
abuse and attack mitigation

Legal basis:

Art. 6(1)(f) GDPR (legitimate interest in secure and stable operation)
Art. 6(1)(b) GDPR, where applicable, where processing is necessary to provide the service

13. Cookies, SDKs, Tracking and Analytics

We use cookies, pixels, tags, SDKs, and comparable technologies on our website and in our app. Some of these technologies are strictly necessary; others serve reach measurement, analysis, personalization, or advertising.

Based on the information you have provided, we use or plan to use in particular the following services or categories of services:

Google Analytics (GA4)
Google Tag Manager
Google Search Console
Meta Pixel
Meta SDK
Firebase (depending on implementation, e.g. analytics, performance, push, crash reporting)

13.1 Strictly necessary technologies

We use strictly necessary technologies to provide the website and app, enable logins, implement security features, store settings, or operate the service stably.

Legal bases: Art. 6(1)(b) GDPR; Art. 6(1)(f) GDPR

13.2 Analytics and reach measurement

Where you have consented, we use analytics and statistics services to better understand use of our website and app, measure reach, detect errors, and improve our offering.

This may involve processing in particular:

pseudonymous identifiers
device and browser information
interactions with pages, content, and features
session data
campaign attribution
conversions and usage events

Legal basis: Art. 6(1)(a) GDPR (consent)

13.3 Advertising and marketing measurement

Where you have consented, we may use marketing and advertising technologies to measure campaign effectiveness, build audiences, enable recognition, or better align content and ads with user interests.

This may include in particular use of the Meta Pixel or Meta SDK.

Legal basis: Art. 6(1)(a) GDPR (consent)

13.4 Google Tag Manager

Google Tag Manager is used to manage website tags and scripts technically. Google Tag Manager itself is generally an administration service. Where additional consent-based services are loaded via Tag Manager, those are activated only after you give the relevant consent.

13.5 Google Search Console

Where we use Google Search Console, we receive from Google in particular aggregated or technical information on findability and performance of our website in Google Search. You typically do not enter personal data directly into Google Search Console via this process.

13.6 Consent management / cookie banner

For technologies that are not strictly necessary, we use a consent management tool on our website. Through this tool you can grant, refuse, or later change your consents.

Please note that the specific scope of cookies, SDKs, and similar technologies used may depend on the current technical implementation.

14. Recipients and Categories of Recipients

We disclose personal data only where permitted by law or where a legal basis exists. Recipients may include in particular:

technical hosting and infrastructure service providers
providers of analytics, tracking, and marketing services
providers for email communication and newsletters
payment service providers and app store operators
support, IT, and security service providers
consultants, lawyers, auditors, or tax advisers, where necessary
authorities or courts where we are legally required to do so
potential acquirers or successors in the context of a corporate restructuring, where permitted under data protection law

15. International Data Transfers

Some services we use or their subprocessors may transfer personal data to countries outside the European Union or the European Economic Area, in particular to the United States.

Such transfers occur only where the statutory requirements are met. This may be the case in particular when:

an adequacy decision exists for the third country concerned,
the recipient is certified under a recognized data protection framework,
standard contractual clauses have been concluded,
or another legally permissible basis applies.

Where we use Google, Meta, Firebase, or Stripe services, it cannot be ruled out that data will be transferred to the United States.

16. Data Retention

We store personal data only as long as necessary for the respective purposes.

In detail, this may mean in particular:

Account data: we generally store these for the duration of your user account.
Profile data and progress: we generally store these as long as your account exists and the data are needed to use the service.
Support and communication data: we store these as long as necessary to handle the matter and follow up on any further questions.
Records of consent: we store these as long as we need proof that consent was given or withdrawn.
Billing and contract data: we store these within the scope of statutory commercial and tax retention obligations.
Log data: we generally store these only for a limited period where necessary for security, stability, and error analysis.

After the purpose ceases to apply, we delete the data unless statutory retention obligations or legitimate interests in further storage—for example for legal defense—prevent deletion.

17. Your Rights

Subject to statutory requirements, you have in particular the following rights:

right of access
right to rectification
right to erasure
right to restriction of processing
right to data portability
right to object to processing based on legitimate interests
right to withdraw consent at any time with effect for the future

If you believe that the processing of your personal data infringes data protection law, you also have the right to lodge a complaint with a supervisory authority.

18. Objection to Direct Marketing

Where we process personal data for direct marketing on the basis of legitimate interests, you have the right to object at any time to processing of your personal data for such marketing.

If you have given consent for newsletters, marketing, or certain tracking technologies, you may withdraw that consent at any time with effect for the future.

19. No Obligation to Provide Certain Data

You are generally not obliged to provide us with personal data. Without certain data, however, we cannot provide core functions of Snipwise or can do so only incompletely. This applies in particular to registration data, login data, and data required to operate a user account or a paid subscription.

20. No Automated Decisions with Legal Effect

We may use personal data to personalize content, recommendations, and communication. Under the current setup, we do not use solely automated decision-making that produces legal effects or similarly significantly affects you.

21. Minors

Our offering is aimed primarily at adults but is not exclusively limited to adults.

Where minors use our offering, we expect this to comply with applicable legal requirements. If we become aware that personal data have been processed unlawfully, we will take appropriate measures.

22. Changes to This Privacy Policy

We may update this privacy policy from time to time, in particular when our offering, technical processes, service providers used, or the legal framework change.

The version available at the time of your visit or use applies in each case.

23. Contact

If you have questions about data protection or wish to exercise your rights, you can contact us at any time:

Max Universe GmbH
Im Mediapark 5
50670 Cologne
Germany
Email: Luis@max-talent.de