Privacy policy

We manage our websites according to the principles set out below:

We undertake to comply with the legal provisions on data protection and always endeavour to observe the principles of data avoidance and data minimisation.

1. the name and address of the person responsible

The responsible person in terms of the basic data protection regulation and other national data protection laws of the member states of the European Union as well as other data protection regulations is

EduMode Software UG

Kronenstr. 69

10117 Berlin

2. definitions of terms

We have designed our data protection declaration according to the principles of clarity and transparency. However, if there are any ambiguities regarding the use of different terms, the corresponding definitions can be viewed here.

3. legal basis for the processing of personal data

We process your personal data such as your name and first name, your e-mail address and IP address etc. only if there is a legal basis for this. According to the basic data protection regulation, three regulations in particular come into consideration here:

  1. You have given us your consent to process your personal data for one or more purposes, Art. 6 para. 1 sentence 1 lit. a DSGVO. In this context, you will be informed by us in detail about the purpose(s) of the processing and we will document your express consent.
  2. The processing of your personal data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures with you, Art. 6 para. 1 sentence 1 lit. b DSGVO.
  3. The processing of personal data is necessary to safeguard our legitimate interests, unless your interests or fundamental rights and freedoms prevail, Art. 6 para. 1 sentence 1 letter f DSGVO.

However, we would like to point out once again at the relevant points the legal basis on which your personal data is processed.

4. disclosure of personal data

Your personal data will not be transferred to third parties for purposes other than those listed below. We only pass on your personal data to third parties if:

  1. you have given your express consent in accordance with Art. 6 para. 1 sentence 1 lit. a DSGVO,
  2. the disclosure pursuant to Art. 6 para. 1 sentence 1 letter f DSGVO is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,
  3. there is a legal obligation to pass on the data in accordance with Art. 6 Para. 1 sentence 1 lit. c DSGVO
  4. this is legally permissible and required under Art. 6 para. 1 sentence 1 lit. b DSGVO for the processing of contractual relationships with you.

5. storage duration and deletion

We store all personal data that you submit to us only for as long as it is needed to fulfill the purposes for which the data was submitted or as long as it is required by law. Upon fulfilment of the purpose and/or expiry of the statutory storage periods, the data will be deleted or blocked by us.

6. SSL encryption

This website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as the requests you send to us as website operator. You can recognise an encrypted connection by the fact that the address line of your browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL encryption is activated, the data you transmit to us cannot be read by third parties.

7. collection and storage of personal data as well as the nature and purpose of their use

When visiting the website

When you visit our websites, we temporarily store so-called usage data on the basis of Article 6 paragraph 1 letter f of the Basic Data Protection Regulation. We use the usage data for statistical purposes to improve the quality of our websites and for security purposes. We also use this information to enable you to access our website, to control and administer our systems and to improve the design of our websites. These purposes pursued by us also constitute a legitimate interest within the meaning of Article 6 paragraph 1 letter f of the Basic Data Protection Regulation.

The data set consists of:

  • the page from which the file was requested
  • the name of the file
  • the date and time of the query
  • the amount of data transferred
  • the access status (file transferred, file not found)
  • the description of the type of web browser used
  • the IP address of the requesting computer

The stored data is thus stored anonymously. The creation of personal user profiles is thus excluded. Data about persons or your individual behaviour is not collected.

Data that allow an inference to your person, such as the IP address, will be deleted after 7 days at the latest. Should we store the data beyond this period, these data will be pseudonymised, so that an assignment to you is no longer possible.

Contact form / e-mail contact

We provide you with a form on our website, so that you have the possibility to contact us at any time. In order to use the contact form, it is necessary to enter a name for a personal form of address and a valid e-mail address for contacting us, so that we know who the request comes from and can process it.

If you send us enquiries via the contact form, your details from the enquiry form, including the contact data you provide there, as well as your IP address in accordance with Art. 6 para. p. 1 lit. b and f DSGVO, will be processed for the purpose of carrying out pre-contractual measures taken in response to your enquiry or to safeguard our legitimate interest, i.e. to carry out our business activities.

You are welcome to send us an e-mail instead using the e-mail address provided on our website. In this case, we will store and process your e-mail address and the information you provide in the e-mail in accordance with Art. 6 para. p. 1 lit. b and f DSGVO for the purpose of processing your message.

The inquiries as well as the associated data will be deleted at the latest 3 months after receipt, unless they are required for a further contractual relationship.

8. analysis and tracking tools

To design our website in line with requirements, we create pseudonymous user profiles using Google Analytics on the basis of Article 6 paragraph 1 letter f of the Basic Data Protection Regulation. This is a product of Google Inc. (“Google”), Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, since we have activated IP anonymisation on this website, your IP address will first be shortened by Google within member states of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and only shortened there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. These purposes pursued by us also represent a legitimate interest within the meaning of Article 6 paragraph 1 letter f of the Basic Data Protection Regulation.

You can object to the creation of the pseudonymous user profiles at any time. There are several possibilities for this:

1) One way to object to the web analysis by Google Analytics is to set an opt-out cookie which instructs Google not to store or use your data for web analysis purposes. Please note that with this solution, web analytics will only not take place as long as the opt-out cookie is stored by the browser. If you would like to set the opt-out cookie now, please click here.

2. you can prevent the storage of cookies by adjusting your browser software accordingly.

3. depending on the browser you are using, you have the option to install a browser plugin that prevents tracking. To do so, please click here and install the browser plugin available there.

Facebook pixel

This website uses the visitor action pixel of Facebook to measure conversion. This service is provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected is also transferred to the USA and other third countries.

This allows the behaviour of site visitors to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This allows the effectiveness of Facebook Ads to be evaluated for statistical and market research purposes and future advertising campaigns to be optimised.

The collected data is anonymous for us as the operator of this website, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook Data Usage Policy. This allows Facebook to enable the placement of advertisements on pages of Facebook as well as outside of Facebook. This use of the data cannot be influenced by us as a site operator.

The use of Facebook pixels is based on your consent (Art. 6 para. 1 lit. a DSGVO). This consent can be revoked at any time for the future.

You will find further information on the protection of your privacy in the Facebook privacy statement: https://de-de.facebook.com/about/privacy/.

You can also disable the Custom Audiences remarketing feature in the Advertising Settings section of https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. You must be logged in to Facebook to do this.

If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/

9. rights of the data subject

You are entitled to the following rights:

Information

In accordance with Art. 15 of the DSGVO, you have the right to request information about your personal data processed by us. This right of information includes information about

  • the processing purposes
  • the categories of personal data
  • the recipients or categories of recipients to whom your data has been or will be disclosed
  • the planned storage period or at least the criteria for determining the storage period
  • the existence of a right of rectification, erasure, restriction of processing or opposition
  • the existence of a right of appeal to a supervisory authority
  • the origin of your personal data, as far as they were not collected by us
  • the existence of automated decision-making, including profiling and, where appropriate, meaningful information on its details

Corrigendum

According to Art. 16 DSGVO you have the right to have incorrect or incomplete personal data stored by us corrected without delay.

Deletion

In accordance with Art. 17 DSGVO, you have the right to demand the immediate deletion of your personal data from us, unless further processing is necessary for one of the following reasons:

  • on the exercise of the right to freedom of expression and information
  • to comply with a legal obligation imposed on the controller by the law of the European Union or of the Member States to which the controller is subject or in the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
  • for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 DSGVO
  • for archiving, scientific or historical research purposes in the public interest or for statistical purposes pursuant to Art. 89 para. 1 DSGVO, insofar as the law referred to in section a) is likely to render impossible or seriously prejudice the attainment of the objectives of such processing
  • to assert, exercise or defend legal claims

Restriction of processing

In accordance with Art. 18 DSGVO, you can request the restriction of the processing of your personal data for one of the following reasons:

  • You dispute the correctness of your personal data.
  • The processing is unlawful and you object to the deletion of personal data.
  • We no longer need the personal data for the purposes of processing, but you do need the data to assert, exercise or defend legal claims.
  • They lodge an objection to the processing pursuant to Art. 21 (1) DSGVO.

Information

If you have requested the rectification or deletion of your personal data or a restriction of processing in accordance with Art. 16, Art. 17 para. 1 and Art. 18 FADP, we will notify all recipients to whom your personal data has been disclosed, unless this proves impossible or involves a disproportionate effort. You can demand that we inform you of these recipients.

Transmission

You have the right to receive the personal data you have provided us with in a structured, common and machine-readable format. You also have the right to request the transfer of this data to a third party, provided that the processing was carried out with the aid of automated procedures and is based on consent pursuant to Art. 6, para. 1, sentence 1, letter a or Art. 9, para. 2, letter a or on a contract pursuant to Art. 6, para. 1, sentence 1, letter b DPA.

Revocation

In accordance with Art. 7 Para. 3 DSGVO, you have the right to revoke the consent you have given to us at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until revocation. In future, we may no longer continue the data processing that was based on your revoked consent.

Complaint

Under Art. 77 DSGVO you have the right to complain to a supervisory authority if you believe that the processing of your personal data violates the DSGVO.

Opposition

If your personal data are processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sentence 1 letter f DSGVO, you have the right to object to the processing of your personal data in accordance with Art. 21 DSGVO if there are reasons for doing so arising from your particular situation or if the objection is directed against direct marketing. In the latter case, you have a general right of objection, which will be implemented by us without indicating the specific situation. If you wish to exercise your right of revocation or objection, simply send an e-mail to oliver.laux@edumode.org.

Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, that has legal effect on you or significantly affects you in a similar manner. This shall not apply if the decision

  1. is necessary for the conclusion or performance of a contract between you and us
  2. is authorised by the law of the European Union or of the Member States to which we are subject and that law provides for appropriate measures to safeguard your rights and freedoms and your legitimate interests
  3. has been made with your express consent

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DPA, unless Art. 9 para. 2 lit. a or g DPA applies and appropriate measures have been taken to protect rights and freedoms and your legitimate interests.

With regard to the cases referred to in i) and iii), we shall take appropriate measures to safeguard your rights and freedoms and your legitimate interests, which shall include at least the right to obtain the intervention of a person from our side, to express your point of view and to challenge the decision.

10. modification of the privacy policy

Should we change the privacy policy, this will be indicated on the website and registered customers will be informed by e-mail.

Status 07.07.2020