Privacy policy
Preamble
With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy 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: 20 February 2024
Person responsible
Gesellschaft für digitale Bildung mbH
A Converge Company
Friesenweg 5g
22763 Hamburg
Germany
Telephone: +49 (0)040 7344861-20
E-Mail: hallo@convergetp.de
Contact data protection officer
The data protection officer of the data controller is
QuaSi Consult GbR
Mrs Tina Walloschek
Gaußscher Bogen 11
29646 Bispingen
Germany
E-Mail: datenschutz@convergetp.de
Overview of data processing
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.
- Contact details.
- Content data.
- Usage data.
- Meta, communication and process data.
Categories of affected persons
- Communication partner.
- Users.
Purposes of the processing
- Contact enquiries and communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Managing and responding to enquiries.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the 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, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.
Safety measures
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
TLS/SSL encryption (https): To protect user data transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.
Transmission of personal data
Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. If this transfer takes place for administrative purposes, the transfer of the data is based on our legitimate business and commercial interests or takes place if it is necessary to fulfil our contractual obligations or if the consent of the data subjects or legal permission exists.
Deletion of data
Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to a supervisory authority: In accordance with the legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
Use of cookies
Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, storage of user preferences and selection options or similar purposes related to the provision of the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.
Information on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is the consent they have given. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.
General information on revocation and objection (so-called “opt-out”): Users can revoke the consent they have given at any time and object to the processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online services and user-friendliness.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a procedure for consent management: procedure for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices and their processing, in the context of which the user’s consent to the use of cookies, respectively the processing and providers mentioned in the consent management: Procedure for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices and their processing procedure, can be obtained and managed and revoked by the users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. Consent can be stored on the server and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Cookie opt-out: In the footer of our website you will find a link that you can use to change your cookie settings and revoke your consent; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Provision of the online offer and web hosting
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes 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 may be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is excluded from erasure until the respective incident has been finally clarified.
- WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offers; Service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data Processing Agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third country transfers: Data Privacy Framework (DPF).
- Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.
Contact and enquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partner.
- Purposes of processing: Contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- HubSpot: Customer management as well as process and sales support with personalised customer care with multi-channel communication, i.e. management of customer enquiries from different channels as well as analysis and feedback functions; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hubspot.de; Privacy Policy: https://legal.hubspot.com/de/privacy-policy; Data processing agreement: https://legal.hubspot.com/dpa. Basis for third country transfers: Data Privacy Framework (DPF).
Advertising communication via e-mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.
After revocation or objection, we store the data required to prove the previous authorisation for contacting or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers).
- Affected persons: Communication partner.
- Purposes of processing: Direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Web analysis, monitoring and optimisation
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offering or its functions or content are most frequently used or invite visitors to reuse them. We can also understand which areas require optimisation.
In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and read out from it. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- fathom: Web analysis and reach measurement (no use of cookies, measurement is limited to our online offering, use of data protection-friendly pseudonymisation procedures, see https://usefathom.com/data); Service provider: Conva Ventures Inc. BOX 37058 Millstream PO, Victoria, BC, V9B 0E8, Canada; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://usefathom.com/; Privacy Policy: https://usefathom.com/privacy. Basis for third country transfers: Adequacy decision (Canada).
- HubSpot: Marketing software for lead generation, marketing automation and analysis; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.hubspot.de; Privacy Policy: https://legal.hubspot.com/de/privacy-policy; Data processing agreement: https://legal.hubspot.com/dpa. Basis for transfers to third countries: Data Privacy Framework (DPF).
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user’s data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF); Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Further information: We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data for the purpose of creating the “page insights” (statistics) of our LinkedIn profiles.
This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user’s profile, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s data protection information: https://www.linkedin.com/legal/privacy-policy
We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum (the ‘Addendum’)”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of Ireland Unlimited Company, which relates in particular to the transfer of data to the parent company LinkedIn Corporation in the USA.
Amendment and updating of the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.