Privacy policy SIBE GmbH

Status: 18.05.2018

This privacy policy explains the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online services and the associated websites, functions and content as well as external online presences, such as our social media profile. (hereinafter collectively referred to as “online services”). With regard to the terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Name/Fa.: SIBE GmbH
Street no.: Kalkofenstr. 53
Zip code, city, country: 71083 Herrenberg, Germany
Commercial register no.: AG Stuttgart HRB 727153
Managing Director: Prof. Dr. Dr. h.c. Werner G. Faix, Prof. Dr. Stefanie Kisgen
Telephone number 07032 / 94 58 – 0
E-mail address: info@steinbeis-sibe.de

Data protection officer:

Name: Dr. Eva Feldbaum
Street No.: Kalkofenstr. 53
Zip code, City, Country: 71083 Herrenberg, Germany
Telephone number: +49 (0) 7032 / 94 58 – 0 +49 (0) 7032 / 94 58 – 0
E-mail address: datenschutz@steinbeis-sibe.de

1. basic information on data processing and legal basis

1.1 This privacy policy explains the nature, scope and purpose of the processing of personal data within our online services and the associated websites, functions and content (hereinafter collectively referred to as “online services” or “website”). The Privacy Policy applies regardless of the domains, systems, platforms and devices (e.g. desktop or mobile) on which we are active online.

1.2 With regard to the terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

1.3 The personal data of users processed as part of our online services include

* limited in each case to the data required for the purpose of processing

1.4 Processing of special categories of data (Art. 9 para. 1 GDPR)
Note text: Please select whether and, if so, which categories of special categories of personal data are processed. This includes data concerning: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, data concerning sex life or sexual orientation:
In principle, no special categories of data are processed unless they are submitted for processing by users, e.g. entered in online forms.

1.5 Purpose of the processing:
– Provision of the online offer, its content and functions
– Provision of contractual services, service and customer care
– Responding to contact requests and communicating with users
– Marketing, advertising and market research

1.6 The term “user” includes all categories of data subjects affected by data processing. These include interested parties, applicants, students, alumni, company representatives, lecturers, cooperation partners and other visitors to our online services. The terms used, such as “user”, are to be understood as gender-neutral.

1.7 We only process users’ personal data in compliance with the relevant data protection regulations. This means that user data will only be processed if we have legal permission to do so. I.e., in particular if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) and online services, or is required by law, if the user has given consent, as well as on the basis of our legitimate interests, i.e. interest in the analysis, optimization and economic operation and security of our online services within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR. This applies in particular to reach measurement, the creation of profiles for advertising and marketing purposes, the collection of access data and the use of third-party services.

1.8 We would like to point out that the legal basis for consent is Art. 6 para. 1 lit. a. and Art. 7 GDPR, the legal basis for processing to fulfill our services and carry out contractual measures Art. 6 para. 1 lit. b. GDPR, the legal basis for processing for the fulfillment of our legal obligations Art. 6 para. 1 lit. c. GDPR, and the legal basis for the processing for the protection of our legitimate interests Art. 6 para. 1 lit. f. GDPR is.

2. security measures

2.1 In accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of security appropriate to the risk; the measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and their separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

2.2 The security measures include, in particular, the encrypted transmission of data between your browser and our server.

3 Cooperation with processors and third parties

3.1 If we disclose data to other persons and companies (processors or third parties) in the course of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Art. 6 para. 1 lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

3.2 If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

4 Disclosure of data to third parties and third-party providers

4.1 Data will only be passed on to third parties within the framework of the legal requirements. We only pass on user data to third parties if this is necessary, for example, on the basis of Art. 6 para. 1 lit. b) GDPR for contractual purposes or on the basis of legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR in the economic and effective operation of our business operations.

4.2 If we use cooperation partners to provide our services, we take appropriate legal precautions and appropriate technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal regulations.

5. transfer to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA), in which the GDPR is not directly applicable law) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

6 Rights of the data subjects

6.1 You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

6.2 You have in accordance with. Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

6.3 In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.

6.4 You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transfer to other controllers.

6.5 You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.

7. right of revocation

You have the right to withdraw your consent in accordance with Art. 7 (3) GDPR with effect for the future.

8. right to object

Users can object to the future processing of their personal data in accordance with the legal requirements at any time. The objection can be made in particular against processing for direct marketing purposes.

9. provision of contractual services

9.1 We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit. b. GDPR. GDPR. The entries marked as mandatory in online forms are required for the purpose of processing.

9.2 Users can fill out a contact form or apply online and upload their application documents. Users will be informed of the required mandatory information. The data transmitted via contact forms or via the applicant tool is not public and cannot be indexed by search engines.

9.3 As part of the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the legitimate interests of users in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c GDPR.

9.4 The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); information in the customer account remains until its deletion.

10. contacting us

10.1 When contacting us (via contact form or e-mail), the user’s details are processed to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.

10.2 The user’s details may be stored in our server’s own IT system on the basis of our legitimate interests (rapid processing).

11 Comments and contributions

11.1 When users leave comments or other contributions, their IP addresses are stored on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR for 7 days. GDPR for 7 days.

11.2 This is done for our security in the event that someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.

12. collection of access data and log files

12.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), pseudonymized IP address and the requesting provider.

12.2 Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum period of 7 days (or 14 days in the case of backups) and then deleted. Only pseudonymized IP addresses of visitors to the website are stored. At web server level, this is done by storing an IP address 123.123.123.XXX, where XXX is a random value between 1 and 254, in the log file instead of the visitor’s actual IP address, e.g. 123.123.123.123. It is therefore no longer possible to establish a personal reference. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.

13. online presence in social media

13.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

13.2 Unless otherwise stated in our privacy policy, we process users’ data if they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages.

14 Cookies & reach measurement

14.1 Cookies are information that is transferred from our web server or third-party web servers to the user’s web browser and stored there for later retrieval. Cookies may be small files or other types of information storage.

14.2 We use “session cookies”, which are only stored for the duration of the current visit to our online presence (e.g. to enable the storage of your login status and thus the use of our online services at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online services and log out or close the browser, for example.

14.3 Users will be informed about the use of cookies in the context of pseudonymous reach measurement as part of this privacy policy.

14.4 If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of the online services.

14.5 You can object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

15 Google Analytics

15.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online services within the meaning of Art. 6 para. 1 lit. f. GDPR), we use Google Analytics, a web analysis service provided by Google Inc. GDPR) Google Analytics, a web analysis service of Google Inc. (“Google”). Google uses cookies. The information generated by the cookie about the use of the online services by users is usually transmitted to a Google server in the USA and stored there.

15.2 Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

15.3 Google will use this information on our behalf to evaluate the use of our online services by users, to compile reports on the activities within these online services and to provide us with further services associated with the use of the online services and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

15.4 We use Google Analytics to display the ads placed by Google and its partners within advertising services only to those users who have also shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Google (so-called “remarketing” or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interest of users and are not annoying.

15.5 We only use Google Analytics with activated IP anonymization. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

15.6 The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online services and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

15.7 You can find further information on data use by Google, setting and objection options on Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when you use our partners’ websites or apps”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.de/settings/ads (“Manage information that Google uses to show you advertising”).

16 Google Re/Marketing Services

16.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online services within the meaning of Art. 6 para. 1 lit. f. GDPR), we use the marketing and remarketing services of Google Inc. GDPR) the marketing and remarketing services (“Google Marketing Services” for short) of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

16.2 Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

16.3 Google marketing services allow us to display advertisements for our website in a more targeted manner in order to present users only with advertisements that potentially match their interests. If, for example, a user is shown ads for products that they have shown an interest in on other websites, this is referred to as “remarketing”. For these purposes, when other websites on which Google marketing services are active are called up, a code from Google is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, what content they are interested in and which offers they have clicked on, as well as technical information about the browser and operating system, referring websites, time of visit and other information about the use of online services. The IP address of the user is also recorded, whereby we inform you in the context of Google Analytics that the IP address is shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases is it transmitted in full to a Google server in the USA and shortened there. The IP address is not merged with the user’s data within other Google offers. Google may also combine the aforementioned information with such information from other sources. If the user subsequently visits other websites, they can be shown ads tailored to their interests.

16.4 User data is processed pseudonymously as part of Google marketing services. This means that Google does not store and process the user’s name or email address, for example, but processes the relevant data in relation to cookies within pseudonymous user profiles. This means that, from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by Google Marketing Services about users is transmitted to Google and stored on Google’s servers in the USA.

16.5 The Google marketing services we use include the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected with the help of the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.

16.6 We can integrate third-party advertisements on the basis of the Google marketing service “DoubleClick”. DoubleClick uses cookies that enable Google and its partner websites to place ads based on users’ visits to this website or other websites on the Internet.

16.7 We may also use the “Google Optimizer” service. Google Optimizer allows us to track the effect of various changes to a website (e.g. changes to input fields, design, etc.) as part of so-called “A/B testing”. Cookies are stored on users’ devices for these test purposes. Only pseudonymous user data is processed.

16.8 We may also use the “Google Tag Manager” to integrate and manage Google analysis and marketing services on our website.

16.9 You can find more information on the use of data for marketing purposes by Google on the overview page: https://www.google.com/policies/technologies/ads, Google’s privacy policy is available at https://www.google.com/policies/privacy.

16.10. If you wish to object to interest-based advertising by Google marketing services, you can use the setting and opt-out options provided by Google: http://www.google.com/ads/preferences.

17 Facebook Social Plugins

17.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online services within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are recognizable by one of the Facebook logos (white “f” on a blue tile, the terms “Like”, “Gefällt mir” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

17.2 Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

17.3 When a user accesses a function of this online service that contains such a plugin, their device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online service. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

17.4 By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online service. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out their IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.

17.5 The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the relevant rights and setting options for protecting the privacy of users, can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.

17.6 If a user is a Facebook member and does not want Facebook to collect data about them via these online services and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

18 Facebook, Custom Audiences and Facebook marketing services

18.1 Within our online services, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used due to our legitimate interests in the analysis, optimization and economic operation of our online services and for these purposes.

18.2 Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

18.3 With the help of the Facebook pixel, Facebook is able to determine the visitors to our online services as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

18.4 The Facebook pixel is integrated directly by Facebook when you visit our website and can store a so-called cookie, i.e. a small file, on your device. If you subsequently log in to Facebook or visit Facebook while logged in, the visit to our online services will be noted in your profile. The data collected about you is anonymous to us, so it does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and can be used by Facebook and for its own market research and advertising purposes. If we transmit data to Facebook for comparison purposes, this data is encrypted locally in the browser and only then sent to Facebook via a secure https connection. This is done for the sole purpose of creating a comparison with the data that is also encrypted by Facebook.

18.5 Furthermore, when using the Facebook pixel, we use the additional function “extended matching” (here, data such as telephone numbers, e-mail addresses or Facebook IDs of the users) to form target groups (“Custom Audiences” or “Look Alike Audiences”) are transmitted to Facebook (encrypted). Further information on “extended matching”: https://www.facebook.com/business/help/611774685654668).

18.6 The processing of data by Facebook takes place within the framework of Facebook’s Data Usage Policy. Accordingly, general information on the display of Facebook ads, in Facebook’s data usage policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.

18.7 You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set which types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

18.8 You can also object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

19 Newsletter

19.1 With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

19.2 Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the content of the newsletter is specifically described when registering for the newsletter, it is decisive for the user’s consent. Otherwise, our newsletters contain information about our study offers, promotions / events and our company.

19.3 Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no-one can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

19.4 Mailing service provider: The newsletter is sent via “MailChimp”, a newsletter mailing platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the mailing service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active).

19.5 Sending service provider: The newsletter is sent by Mailjet SAS, 13-13 bis, rue de l’Aubrac, 75012 Paris, France, hereinafter referred to as the “sending service provider”. You can view the data protection provisions of the mailing service provider here: https://www.mailjet.de/sicherheit-datenschutz/

19.6 Furthermore, according to its own information, the mailing service provider may use this data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. for the technical optimization of the mailing and presentation of the newsletter or for statistical purposes to determine from which countries the recipients come. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or pass it on to third parties.

19.7 Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, you can enter a name to be addressed personally in the newsletter.

19.8 Statistical survey and analyses – The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the server of the mailing service provider when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, is initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the mailing service provider to observe individual users. The evaluations serve much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

19.9 The use of the mailing service provider, the performance of statistical surveys and analyses and the logging of the registration process are based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. We are interested in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of users.

19.10. Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. At the same time, your consent to its dispatch by the dispatch service provider and the statistical analyses will expire. Unfortunately, it is not possible to withdraw your consent to the newsletter being sent by the newsletter service provider or to the statistical analysis separately. You will find a link to unsubscribe from the newsletter at the end of each newsletter. If users have only registered for the newsletter and have canceled this registration, their personal data will be deleted.

20. integration of third-party services and content

20.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online services within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online services. GDPR) content or service offers from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online services, as well as being linked to such information from other sources.

20.2 The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out):
▪ Functions of the Google+ service are integrated within our online services. These functions are offered by the third-party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you are logged into your Google+ account, you can link the content of our pages to your Google+ profile by clicking on the Google+ button. This allows Google to associate your visit to our pages with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Google+. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
▪ Videos from the “YouTube” platform of the third-party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
▪ Functions of the Instagram service are integrated into our online services. These functions are offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged into your Instagram account, you can link the content of our pages to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate your visit to our pages with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Instagram. Privacy policy: http://instagram.com/about/legal/privacy/.
▪ Our online service uses functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time one of our pages containing LinkedIn functions is accessed, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click on the LinkedIn “Recommend” button and are logged into your LinkedIn account, LinkedIn is able to associate your visit to our website with you and your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn. Privacy policy: https://www.linkedin.com/legal/privacy-policy, opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
▪ Functions of the Twitter service may be integrated into our online services. These functions are offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. By using Twitter and the “Re-Tweet” function, the websites you visit are linked to your Twitter account and made known to other users. Data is also transmitted to Twitter in the process. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Twitter. Twitter’s privacy policy at http://twitter.com/privacy. You can change your data protection settings on Twitter in the account settings at http://twitter.com/account/settins
▪ We use functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Each time one of our pages containing Xing functions is accessed, a connection to Xing servers is established. To the best of our knowledge, no personal data is stored in the process. In particular, no IP addresses are stored or usage behavior evaluated. Privacy policy: https://www.xing.com/app/share?op=data_protection.
▪ External code of the JavaScript framework “jQuery”, provided by the third-party provider jQuery Foundation, https://jquery.org.
▪ External fonts from Google, Inc, https://www.google.com/fonts (“Google Fonts”). Google Fonts are integrated by calling up a Google server (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.

21 Data processing for payment processing for admission tickets (graduation ceremony)

We work with the following partners to create admission tickets and process payments for admission tickets for participants (graduates, accompanying persons, business mentors and lecturers) who wish to attend the graduation ceremony: technical service providers, credit institutions, payment service providers.

The admission tickets are created automatically after successful payment/registration via the WordPress plugin Tickera, which is operated on our own server. The personal data (first name, surname, email address) of the purchaser and all ticket recipients will be collected and irrevocably deleted no later than three months after the graduation ceremony.

If necessary, you will be redirected to the payment service provider Mollie for payment during the ordering process. Depending on the payment method,Mollie collects the data required to process the payment itself, e.g. on its own website or via a technical integration in the ordering process. Their privacy policy applies in this respect. If you have any questions about our payment processing partners and the basis of our cooperation with them, please use the contact option described in this privacy policy.

22 Deletion of data

22.1 The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

22.2 In accordance with legal requirements, data is stored in particular for 6 years in accordance with Section 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

23 Changes to the privacy policy

23.1 We reserve the right to amend the privacy policy in order to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this only applies with regard to declarations on data processing. If user consent is required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.

23.2 Users are requested to inform themselves regularly about the content of the privacy policy.