Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “Online Offer”).

The terms used are not gender-specific.

Status: 17 March 2021

Table of contents

Responsible

Beate D. Pfeiffer
Volgersweg 42
30175 Hannover
+49 (0) 511 348 1390
lbc@kabelmail.de
www.language-business-and-culture.de

Anne Biebuyck
Immengarten 5
30177 Hannover
+49 (0) 511 66 22 09
anne.biebuyck@gmx.de

Claudia Giusti
Fliederweg 6
D – 30952 Ronnenberg
+ 49 (0) 511 606 44 11
Claudia@si-sprachtraining.de
www.Si-Sprachtraining.de

Maria del Pilar Peña de Brack
Roncallihof 31
30459 Hannover
+49 (0) 511 5295471
pilarbrack@yahoo.es

Imprint: https://www.sprachnetzwerk.info/impressum/

Overview of the processing operations

The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).

Categories of data subjects

  • Communication partners.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Provision of our online services and user experience.
  • Office and organisational procedures.
  • Contact requests and communication.
  • Provision of contractual services and customer service.

Relevant legal basis

Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

  • netcup: Services in the field of provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe, Germany; Website: https://www.netcup.de/; Privacy policy: https://www.netcup.de/kontakt/datenschutzerklaerung.php.

Video conferencing, online meetings, webinars and screen sharing

We use platforms and applications from other providers (hereinafter referred to as “conferencing platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.

Zoom

What data is processed?

Various types of data are processed when using “Zoom“. The scope of the data also depends on the data you provide before or during participation in an “online meeting”.

The following personal data are subject to processing:

User details: first name, last name, telephone (optional), e-mail address, password, profile picture (optional).

Meeting metadata: Topic, description (optional), participant IP addresses, device/hardware information.

For recordings (optional): MP4 file of all video, audio and presentation recordings, M4A file of all audio recordings, text file of online meeting chat.

For dial-in with the telephone: information on the incoming and outgoing call number, country name, start and end time. If necessary, further connection data such as the IP address of the device can be stored.

Text, audio and video data: You may have the opportunity to use the chat, question or survey functions in an “online meeting”. In this respect, the text entries you make will be processed in order to use them in the “online meeting” and, if necessary, to record them. In order to enable the display of video and the playback of audio, the data from the microphone of your terminal device and from any video camera of the terminal device are processed accordingly for the duration of the meeting. You can switch off or mute the camera or microphone yourself at any time via the “Zoom” applications.

To participate in an “online meeting” or to enter the “meeting room”, you must at least provide information about your name.

Scope of processing

We use “Zoom” to conduct “online meetings”. If we want to record “online meetings”, we will transparently inform you in advance and – where necessary – ask for consent. The fact of the recording will also be displayed to you in the “Zoom” app.

If it is necessary for the purposes of logging the results of an online meeting, we will log the chat content. However, this will not usually be the case.

In the case of webinars, we may also process questions asked by webinar participants for the purposes of recording and following up webinars.

If you are registered as a user at “Zoom”, then reports on “online meetings” (meeting metadata, telephone dial-in data, questions and answers in webinars, survey function in webinars) may be stored at “Zoom” for up to one month.

Automated decision-making within the meaning of Art. 22 DSGVO is not used.

Legal basis for data processing

Insofar as personal data is processed, § 26 BDSG is the legal basis for data processing. If, in connection with the use of “Zoom”, personal data is not required for the establishment, implementation or termination of the employment relationship, but is nevertheless an elementary component in the use of “Zoom”, Art. 6 (1) f) DSGVO is the legal basis for data processing. In these cases, our interest lies in the effective implementation of “online meetings”.

Otherwise, the legal basis for data processing when conducting “online meetings” is Art. 6 para. 1 lit. b) DSGVO, insofar as the meetings are conducted within the framework of contractual relationships.

If there is no contractual relationship, the legal basis is Art. 6 para. 1 lit. f) DSGVO. Here, too, our interest is in the effective conduct of “online meetings.

Recipients / passing on of data

Personal data processed in connection with participation in “online meetings” will not be passed on to third parties as a matter of principle, unless they are specifically intended to be passed on. Please note that the content of “online meetings”, as well as personal meetings, is often used to communicate information with customers, interested parties or third parties and is therefore intended to be passed on.

Other recipients: The provider of “Zoom” necessarily receives knowledge of the above-mentioned data insofar as this is provided for in the context of our order processing agreement with “Zoom”.

Data processing outside the European Union

“Zoom” is a service provided by a provider from the USA. A processing of personal data therefore also takes place in a third country. We have concluded a commissioned processing contract with the provider of “Zoom” which complies with the requirements of Art. 28 DSGVO.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Our data protection notices may also contain further details on the retention and deletion of data which have priority for the respective processing operations.

Amendment and updating of the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

Rights of the data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to revoke any consent given at any time.
  • Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
  • Complaint to the supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Definition of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, whether collecting, analysing, storing, transmitting or erasing.

Translated version of the german Privacy Policy created with free Datenschutz-Generator.de by Dr. Thomas Schwenke