Privacy
Responsible party pursuant to data protection laws, in particular the EU General Data Protection Regulation (GDPR), is datenschutzbeauftragter@startsteps.org
Your rights as the data subject
You can exercise the following rights at any time using the contact details of our data protection officer:
- Information on your data stored by us and the processing thereof (Art. 15 GDPR),
- Rectification of inaccurate personal data (Art. 16 GDPR),
- Deletion of your data stored by us (Art. 17 GDPR),
- Restriction of the data processing, provided that we may not delete your data due to legal obligations (Art. 18 GDPR),
- Objection to the processing of your data with us (Art. 21 GDPR) and
- Data portability, provide that you have consented to the data processing or have entered into a contract with us (Art. 20 GDPR).
If you have given us consent, you may withdraw it at any time, which will remain in effect in the future.
You can contact a supervisory authority with a complaint at any time, e.g. the supervisory authority of the state of your residence or the authority that oversees us as the responsible party.
You’ll find a list of supervisory authorities (for the non-public area) with their respective addresses at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.
Collecting general information during a visit to our website
Type and purpose of the processing
When you access our website – i.e. if you do not register or submit information – information of a general nature will be collected automatically. This information (server log files) contains the type of web browser, the operating system used, the domain name of your Internet service provider, your IP address and the like.
It is processed in particular for the following purposes:
- Ensuring an unproblematic website connection
- Ensuring seamless use of our website
- Analysis of system security and stability as well as
- For additional administrative purposes.
We will not use your data to draw conclusions about your person. This type of information will be statistically analysed by us if necessary to optimise our website and its underlying technology.
Legal basis
The processing occurs according to Art. 6 Para. 1 (f) GDPR, based on our legitimate interest in improving the stability and functionality of our website.
Recipients
Recipients of the data may be technical service providers, who work on the operation and maintenance of our website as the processor.
Retention period
The data will be deleted as soon as they are no longer required for the reason they were collected. This is generally the case, after the respective session has ended, for data that are used to make the website available.
Mandatory or required provision
The provision of the aforementioned personal data is neither legally nor contractually mandatory. Without the IP address however, the service and functionality of our website are not guaranteed. Furthermore, individual services can be unavailable or limited. For this reason, an objection is excluded.
Registration on our website
Type and purpose of the processing
With the registration to use our personalised services, some personal data such as name, address, contact and communication information (e.g. phone number and e-mail address) are collected. If you are registered with us, you can access content and services that we only offer to registered users. Registered users also have the ability to change or delete the data entered during registration at any time. At any time, we will also provide you with information on the personal data about you that we have saved.
Legal basis
The data entered during registration are processed on the basis of the user’s consent (Art. 6 Para. 1 (a) GDPR).
If the registration fulfils the obligations of a contract, whose contractual party is the data subject, or serves to implement pre-contractual measures, the additional legal basis for the data processing is Art. 6 Para. 1 (b) GDPR.
Recipients
Recipients of the data may be technical service providers, who work on the operation and maintenance of our website as the processor.
Retention period
Data are only processed in this context provided that the corresponding consent has been given. The data will be deleted thereafter, provided that no statutory retention obligations prohibit the deletion. To contact us in this regard, please use the contact information provided at the end of this privacy policy.
Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. Without the provision of your personal data, we cannot give you access to our content and services.
Lead Sharing with German Educational Resellers
Type and purpose of the processing
Our company generates qualified leads that we may share with our German educational resellers. The personal information shared with the resellers is necessary for the purpose of completing a sales or educational cycle.
Legal basis
We ensure that our German educational resellers have a lawful basis for processing the shared personal information. Our company is a data controller and is committed to protecting the privacy rights of individuals in accordance with the General Data Protection Regulation (GDPR).
Recipients
The qualified leads are shared with our German educational resellers who are separate data controllers. They are responsible for their own processing activities, including the use of personal data for sales and educational purposes.
Retention period
We retain a record of the data sharing for the purpose of demonstrating our compliance with GDPR.
Mandatory or required provision
Individuals have the right to access, rectify, erase, or restrict the processing of their personal information held by our German educational resellers. They can exercise these rights by contacting the reseller or us directly.
This privacy policy does not apply to the German educational resellers’ processing activities and we encourage individuals to review their privacy policies for further information on how their personal information is used.
Newsletter
Type and purpose of the processing
Your data will be used exclusively to send you the newsletter you subscribed for via e-mail. We request your name so that we can address you personally in the newsletter and identify you as needed should you want to exercise your rights as a data subject.
To receive the newsletter, providing your e-mail address is sufficient. When you subscribe to our newsletter, the data you provide will be used exclusively for this purpose. Subscribers can also be notified by e-mail about circumstances that are relevant to the service or registration (such as changes to the newsletter offer or technical matters).
We need a valid e-mail address to complete your registration. In order to verify that a registration is actually made by the owner of an e-mail address, we utilise the ‘double opt-in’ procedure. To this end, we log the newsletter subscription request, when a confirmation e-mail is sent and the receipt of the requested reply. Additional data is not collected. The data will be used exclusively for sending the newsletter and will not be shared with third parties.
Legal basis
Based on your express consent (Article 6 (1) a DSGVO), we will send you our newsletter on a regular basis or comparable information via e-mail to your specified e-mail address.
The consent to save and use your personal data for the newsletter may be withdrawn at any time and remain in effect in the future. Every newsletter contains a corresponding link, and you can also unsubscribe on this website at any time or inform us of your cancellation via the contact option indicated at the end of this privacy policy.
Recipients
Recipients of the data may be processors.
Retention period
Data are only processed in this context provided that the corresponding consent has been given. The data will be deleted thereafter.
Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. Unfortunately, we cannot send you our newsletter without your consent.
Contact form
Type and purpose of the processing
The data you enter are used for individual communication with you. A valid e-mail address and your name are required for this communication, which serves to organize your inquiry and the respective subsequent reply. Providing additional information is optional.
Legal basis
The processing of the data entered in the contact form occurs on the basis of a legitimate interest (Art. 6 Para. 1 (f) GDPR).
By providing the contact form, our aim is to facilitate an uncomplicated means for you to contact us. The information you enter will be used to process the inquiry and saved for possible follow-up questions.
If you contact us to request an offer, the processing of the information provided in the contact form will occur in order to implement pre-contractual measures (Art. 6 Para. 1 (b) GDPR).
Recipients
Recipients of the data may be processors.
Retention period
The data will be deleted no later than 6 months after processing the inquiry.
Provided that we enter into a contract together, we will use the statutory retention periods in the German Commercial Code (Handelsgesetzbuch) and delete your data according to the respective stipulated deadlines.
Mandatory or required provision
The provision of your personal data is voluntary. However, we can only process your inquiry if you provide us with your name, e-mail address and the reason for your inquiry.
Using Google Analytics
Type and purpose of the processing
This website uses Google Analytics, a web analytics service of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 USA (hereinafter: ‘Google’). Google Analytics uses so-called ‘cookies’, i.e. text files that are stored on your computer and allow an analysis of your use of the website. The information generated by the cookie about your use of this website is typically transmitted to a Google server in the U.S. and stored there. However, due to the activation of IP anonymisation on these websites, your IP address will be truncated beforehand by Google within the 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 sent to a Google server in the U.S. and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, summarise reports on website activities and provide other services related to website and Internet usage to the website operator. The IP address transferred from your browser as part of Google Analytics will not be combined with other data from Google.
The data processing purposes are the website-use analysis and the summary of reports on activities on the website. Based on the use of the website and the Internet, other related services will be provided.
Legal basis
The processing of the data occurs on the basis of the user’s consent (Art. 6 Para. 1 (a) GDPR).
Recipients
The recipient of the data is Google as the processor. For this, we have entered into the corresponding data-processing contract with Google.
Retention period
The deletion of the data occurs as soon as they are no longer necessary for our recording-keeping purposes.
Third country transfers
Google processes your data in the United States of America and is subject to the EU-U.S. Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.
Revocation of consent
You can prevent the storage of cookies by a corresponding setting in your browser software; however, please note that in this case you may not be able to use all the functions of this website in their entirety. Furthermore, you can prevent the collected data generated by the cookie and the data related to your use of the website (including your IP address) being transmitted to Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: browser add-on to deactivate Google Analytics.
In addition, or as an alternative to the browser add-on, you can prevent tracking by Google Analytics on our web pages by clicking this link, which will install an opt-out cookie on your device. This will prevent data collection by Google Analytics for this website and for this browser in the future, as long as the cookie remains installed in your browser.
Profiling
With the assistance of the tracking tool Google Analytics, the browsing behaviour of the website visitors can be evaluated and their respective interests can be analysed. For this analysis, we create a pseudonymous user profile.
Using script libraries (Google Webfonts)
Type and purpose of the processing
In order to present our content correctly and graphically appealing across all browsers, we use ‘Google Webfonts’ from Google LLC (1600 Amphitheater Parkway, Mountain View, CA 94043, USA, hereinafter ‘Google’) to display fonts on this website.
You’ll find the data protection guidelines of the library operator Google here: https://www.google.com/policies/privacy/
Legal basis
Your consent is the legal basis for the integration of Google Webfonts and the associated data transfer to Google (Art. 6 Para. 1 (a) GDPR).
Recipients
The use of script libraries or font libraries automatically triggers a connection to the operator of the library. It is theoretically possible – but currently also unclear whether and to what end – that the operator, in this case Google, will collect data.
Retention period
We do not collect any personal data via the integration of Google Webfonts.
You’ll find additional information on Google Webfonts at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/.
Third country transfers
Google processes your data in the United States of America and is subject to the EU-U.S. Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
Mandatory or required provision
The provision of your personal data is neither legally nor contractually required. However, the correct presentation of standard-fonts content is not possible without this provision.
Revocation of consent
The programming language JavaScript is regularly used to display content. Thus, you can opt out of the data processing by disabling JavaScript execution in your browser or by installing a JavaScript blocker. Please note that this may result in functional limitations on the website.
Using Google Maps
Type and purpose of the processing
We use Google Maps on this website. Google Maps is operated by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (hereinafter ‘Google’). This allows us to show you interactive maps directly on the website, allowing you to conveniently use the map feature.
You’ll find additional information about Google’s data processing on the Google privacy policy page, where you can also change your personal privacy settings in the data protection center.
Click here for detailed instructions on how to manage your own data related to Google products.
Legal basis
Your consent is the legal basis for the integration of Google Maps and the associated data transfer to Google (Art. 6 Para. 1 (a) GDPR).
Recipients
By visiting the website, Google receives information that you have accessed the corresponding subpage of our website. This occurs regardless of whether Google provides a user account that you are logged into or if there is no user account. When you’re logged into Google, your data will be directly assigned to your account.
If you do not want this assignment in your Google profile, you must log out of Google before activating the button. Google stores your data as usage profiles and uses them for advertising, market research and/or tailor-made design of its website. Such an analysis occurs in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the formation of these user profiles, but you must submit this objection to Google.
Retention period:
We do not collect any personal data via the integration of Google Maps.
Third country transfers
Google processes your data in the United States of America and is subject to the EU-U.S. Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
Revocation of consent
If you do not want Google to collect, process or use information about you via our website, you can disable JavaScript in your browser settings. In this case, you cannot or only partially use our website.
Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.
Embedded YouTube videos
Type and purpose of the processing
We embed YouTube videos on several of our websites. The operator of the respective plugins is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (hereinafter ‘YouTube’). YouTube, LLC is a subsidiary of Google LLC, 1600 Amphitheater Pkwy, Mountain View, CA 94043, USA (hereinafter ‘Google’). When you visit a page with the YouTube plug-in, a connection to YouTube’s servers will be created, which tells YouTube which pages you visit. When you are logged into your YouTube account, YouTube can associate your browsing behaviour with you personally. You can prevent this by logging out of your YouTube account beforehand.
If a YouTube video is started, the provider uses cookies that collect information about user behaviour.
You will find additional information on the purpose and scope of the data collection and its processing by YouTube in the provider’s privacy policy, as well as additional information on your rights and setting options for protecting your privacy (https://policies.google.com/privacy). Google processes your data in the United States of America and is subject to the EU-U.S. Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
Legal basis
Your consent is the legal basis for the integration of YouTube and the associated data transfer to Google (Art. 6 Para. 1 (a GDPR).
Recipients
Visiting YouTube automatically triggers a connection to Google. .
Retention period and revocation of consent
Everyone who has disabled the storage of cookies for the Google ad programme will not have to expect any cookies when watching YouTube videos. However, YouTube also stores non-personal usage information in other cookies. If you would like to prevent this, you must block the storage of cookies in the browser.
You’ll find additional information on data protection at ‘YouTube’ in the provider’s privacy policy at: https://policies.google.com/privacy.
Third country transfers
Google processes your data in the United States of America and is subject to the EU-U.S. Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.
Google AdWords
Type and purpose of the processing
Our website uses Google Conversion Tracking. The operating company of the Google AdWords services is Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. If you have reached our website via a Google advertisement, Google Adwords will place a cookie on your computer. The conversion tracking cookie is used when a user clicks on an ad from Google.
If the user visits certain pages on our website, and the cookie has not expired, we and Google can recognise that the user clicked on the ad and was redirected to this page. Every Google AdWords customer receives a different cookie. Thus, cookies cannot be tracked by the websites of AdWords customers. The information gathered by the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. The customers see the total number of users who clicked on their advertisement and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
Legal basis
Your consent is the legal basis for the integration of Google AdWords and the associated data transfer to Google (Art. 6 Para. 1 (a) GDPR).
Recipients
Whenever you visit our website, your personal information, including your IP address, is transferred to Google in the U.S. This personal information is saved by Google. Google may transfer such personal data collected through the technical process to third parties.
We do not receive information from Google that could identify the data subject.
Retention period
These cookies lose their validity after 30 days and are not used for personal identification.
Third country transfers
Google processes your data in the United States of America and is subject to the EU-U.S. Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
Revocation of consent
If you do not want to participate in the tracking, you can reject the required cookie use – for example via a general browser setting that disables the automatic use of cookies or configures your browser to block cookies from the domain ‘googleleadservices.com’.
Please note that you should not delete the opt-out cookies as long as you do not want to save measurement data. If you have deleted all your cookies in the browser, you must use the respective opt-out cookie again.
Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.
Using Google Remarketing
Type and purpose of the processing
This website uses the remarketing function of Google Inc. The operating company of the Google Remarketing services is Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, United States (hereinafter “Google”).
The function is designed to present interest-based ads to website visitors within the Google advertising network. A so-called ‘cookie’ is saved in the browser of the website visitor, which makes it possible to recognise the visitor when he or she visits websites that belong to the advertising network of Google. On these pages, visitors can be presented with ads related to content that the visitor previously viewed on websites using Google’s remarketing feature.
Legal basis
Your consent is the legal basis for the integration of Google Remarketing and the associated data transfer to Google (Art. 6 Para. 1 (a) GDPR).
Recipients
With every visit of our website, personal data, including your IP address, are transmitted to Google in the U.S. These personal data are saved by Google. Google may transfer these personal data collected through the technical process to third parties.
We do not receive any information from Google that could identify the data subject.
Revocation of consent
According to its own statements, Google does not collect any personal data during this process. However, if you still do not want Google’s Remarketing feature, you can always disable it in general via the corresponding settings at https://support.google.com/adwordspolicy/answer/143465. Alternatively, you can disable the use of cookies for interest-based advertising via the advertising network initiative by following the instructions at: http://www.networkadvertising.org/managing/opt_out.asp.
Mandatory or required provision
The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.
SSL encryption
To protect the security of your data during transmission, we use state-of-the-art encryption methods (such as SSL) via HTTPS.
Revision of our privacy policy
We reserve the right to amend this privacy policy so that it always complies with current legal requirements or to implement changes to our services in the privacy policy, e.g. when introducing new services. Your next visit will be subject to the new privacy policy.
Questions for the data protection officer
If you have any questions pertaining to data protection, please send us an e-mail or contact the person responsible for data protection in our organization:
paddy@startsteps.org
The privacy policy was created via the activeMind AG privacy policy generator (Version: #2018-09-24).