PRIVACY POLICY WEBSITE 

Version: 23. August 2023
 

1. Introduction

In the following, we provide information about the collection of personal data when using

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is MyGU GmbH, Steinstraße 5-7, 20095 Hamburg, Germany, email: [email protected]. We are legally represented by Tobias Bargmann & Stephan Paulini.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: [email protected].

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

3. Data processing on our website

3.1. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2. Web hosting and provision of the website

Our website is hosted by Hetzner. The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://www.hetzner.com/rechtliches/datenschutz?country=de.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

We use the content delivery network Cloudflare for our website. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at https://www.cloudflare.com/privacypolicy/.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

3.3. Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR.
We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

3.4. Vacant positions

We publish positions that are vacant in our company on our website, on pages linked to the website or on third-party websites.

The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR.

We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application.

3.5. Customer account

Site visitors can open a customer account on our website. We process the data requested in this context based on the consent of the site visitor. Legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR.

The consent may be revoked at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. If the consent is revoked we will delete the data insofar as we are not obliged or have a right to retain it further.

Beyond the data entered during registration, we process 

  • location data based on your IP-address
  • language based on your browser
  • UTM parameters 
  • visited pages on our website
  • Type of sign up (per email or single sign-on

3.6 Webinars

Through our website, users can participate in webinars. We use Zoom Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA to conduct the webinars. The provider processes contact data (e.g. name, email address, telephone number, address, country, IP address and username) in the USA.

The legal basis is Art. 6 para. 1 p. 1 lit. b GDPR, as the processing is necessary for the performance of a contract to which the data subject is a party, or as it is necessary for the performance of pre-contractual measures which are carried out at the request of the data subject.

The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

The data are deleted when the purpose of their collection has ceased to apply and there is no obligation to retain them. Further information is available in the provider's privacy policy at https://explore.zoom.us/trust/privacy.

3.7. Single sign-on procedure Facebook

Site visitors can log in to our website using a single sign-on procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. When a site visitor logs in using a single sign-on procedure, we receive information from the provider that the site visitor is logged in with the provider and the provider receives information that the site visitor is using the single sign-on procedure on our website. Depending on the settings of the site visitor in his account on the provider's site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the site visitor who registers with us using the account (Art. 6 para. 1 s. 1 lit. a GDPR).

The provider of the single sign-on procedure is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland ("Facebook"). Which data we receive from Facebook is communicated to page visitors by Facebook as part of the registration process. Information about Facebook and the contact details of the data protection officer, as well as further information about how Facebook processes personal data, including the legal basis and the options for exercising rights as a data subject against Facebook, can be found at https://www.facebook.com/about/privacy. We are jointly responsible with Facebook for the data processing taking place through Facebook in the context of the use of the procedure and have concluded a joint controller agreement (Art. 26 GDPR) with Facebook. There we have defined the respective responsibilities for the fulfillment of the obligations under the GDPR with regard to joint processing. We are required to provide the above information and Facebook has assumed responsibility for the other data subject rights under Art. 15-20 GDPR.

3.8. Single sign-on procedure Google

Site visitors can log in to our website using a single sign-on procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. When a site visitor logs in using a single sign-on procedure, we receive information from the provider that the site visitor is logged in with the provider and the provider receives information that the site visitor is using the single sign-on procedure on our website. Depending on the settings of the site visitor in his account on the provider's site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the site visitor who logs in to our site with the account (Art. 6 para. 1 s. 1 lit. a GDPR). The provider of the procedure is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (privacy policy: https://policies.google.com/privacy).

3.9. Offer of services

We offer services via our website. In doing so, we process the following data as part of the ordering process:

  • first and last name
  • email address
  • billing address
  • means of payment

 

The processing of the data is carried out for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 s. 1 lit. b GDPR).

3.10. Payment processors

For the processing of payments, we use payment processors and initiators who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

  • giropay GmbH
  • Klarna Bank AB (publ), Sweden (for "Klarna Sofort")
  • Mastercard Europe SA, Belgium
  • PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxemburg
  • Visa Europe Services Inc., Great Britain

We use Unzer GmbH, Vangerowstraße 18, 69115 Heidelberg, Germany, as payment service initiator.

3.11. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, we set technically necessary cookies for the following purpose or purposes:

  • Cookies that store log-in data,
  • Cookies that adopt language settings,
  • Cookies that payment providers set for payment processing and do not analyze user behavior, 
  • Cookies that store the shopping cart, and 
  • Cookies that remember search terms

3.12. Third parties

3.12.1. ​Google Webfonts​

We use Google Webfonts for fonts on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. However, the processing only takes place on our servers. We process meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in using a font that is easy to use and inexpensive on our website.

Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.12.2. ​CookieYes

We use CookieYes to manage consents. The provider is CookieYes Limited, 3 Warren Yard Warren Park,  Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom. The provider processes meta/communication data (e.g. device information, IP addresses) in the UK.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. c GDPR. The processing is necessary for the fulfillment of a legal obligation to which we are subject.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.cookieyes.com/privacy-policy/.

3.12.3. ​Google Marketing Platform​

We use Google Marketing Platform for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.12.4. ​Google Maps​

We use Google Maps for maps on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Irland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are consents.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.12.5. ​Google Tag Manager​

We use Google Tag Manager for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.12.6. ​Google Conversion Tag​

We use Google Conversion Tag for conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en and https://support.google.com/tagmanager/answer/9323295?hl=en&ref_topic=3441532.

3.12.7. ​Cloudflare​

We use Cloudflare for application security. The provider is Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in increasing the security of our app by preventing malicious traffic from reaching our server.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.cloudflare.com/en-gb/privacypolicy/.

3.12.8. ​Google Analytics​

We use Google Analytics for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.12.9. ​Google reCAPTCHA​

We use Google reCAPTCHA to manage authentifications. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are consents.

Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.12.10. YouTube videos

We use YouTube videos for videos on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for transfers to a country outside the EEA is consent.

Further information is available in the provider's privacy policy at https://policies.google.com/privacy.

3.12.11. WeChat

We use WeChat to communicate with customers from China. The provider is Tencent International Service PTE. LTD, International Plaza, 10 Anson Road, #21-07, Postal 079903, Singapore. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms), contact data (e.g. email addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses) and master data (e.g. names, addresses) in Singapore and Hong Kong.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. b GDPR.

The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Art. 93 (2) GDPR (Art. 46 (2) c GDPR), which we have agreed with the provider.

3.13. Performance analysis

We analyze how non-registered users visit the pages of partner schools on our website and provide anonymized data to partner schools as part of reports (see also 4. for registered users). We have a legitimate interest in analyzing the performance of our offers for partner schools. The legal basis in this respect is therefore Art. 6 para. 1 s. 1 lit. f GDPR.

4. Data processing in joint controllership with partner universities

In joint controllership with our partner universities, we collect the following data via lead forms:

  • Salutation
  • First name
  • Last name
  • E-mail
  • Phone
  • Nationality
  • Country of origin
  • Course of study
  • Place of study
  • Address
  • Type of study program
  • Start of study related to year
  • Start of study in the month

We also send prospective students e-mails with information on courses of study at our partner universities that are of interest to them. All partner universities are listed on our website.

We analyze the performance of our offers for partner universities. We make this data available to the partner universities in anonymized form as part of the Performance Report. This gives the partner universities the opportunity to evaluate their offerings.

The legal basis for the aforementioned processing is in each case consent pursuant to Art. 6 para. 1 s. 1 a GDPR. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The following service providers are used within the scope of joint responsibility:

 

Name

Function

Location of server

Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen

Hoster

EU

Itera Research sp. zo.o., ul. GESIA, nr 8, lok. 201, 31-535 Krakow, Poland

IT Development

EU

​NeverBounce, 805 Broadway St., Suite 900, Vancouver, WA, 98660, USA

​Email verification

USA

Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA

Content delivery network

worldwide

 

Within the scope of joint responsibility, we are obliged to fulfill the information obligations from Art. 13, 14 GDPR and from Art. 26 para. 2 GDPR. Data subjects can assert their rights arising from Art. 15 to 22 GDPR against us.

5. Data processing on social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

5.1. Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

5.2. Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

5.3. YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de.

5.4. Twitter

We maintain a profile on Twitter. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy. One way to object to data processing is via the settings for advertisements: https://twitter.com/personalization.

5.5. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5.6. Xing

We maintain a profile on XING. The operator is New Work SE, Am Strandkai 1, 20457 Hamburg. The privacy policy is available here: https://privacy.xing.com 

5.7 VK.com

We maintain a profile on VK.com. The operator is Vkontakte, 125167, Leningradsky prospekt 39, bld. 79, Moskow, Russia. The privacy policy is available here: https://vk.com/privacy/eu.

6. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

7. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.