Privacy policy

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Privacy policy

1. introduction

In the following, we provide information about the processing of personal data when using

our website https://www.aledu.de
of our profiles in social media.

Personal data is any data that can be related to a specific natural person, e.g. their name or IP address.

1.1 Contact details

The person responsible pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is aledu GmbH, Bismarckstraße 67, 47057 Duisburg, Germany, e-mail: [email protected]. We are legally represented by Zeynep Köksal.

Our data protection officer is heyData GmbH, Kantstr. 99, 10627 Berlin, www.heydata.eu, e-mail: [email protected].

1.2 Scope of data processing, processing purposes and legal basis

The scope of data processing, processing purposes and legal bases are explained in detail below. The following can be considered as the legal basis for data processing:

Section 6 (1) sentence 1 it. a DSGVO serves as the legal basis for processing operations for which we obtain consent.
6 para. 1 p. 1 lit. b DS GVO is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of enquiries about our products or services.
Section 6 (1) sentence 1 lit. c DSGVO applies if we fulfil a legal obligation by processing personal data, as may be the case in tax law, for example.
6 (1) p. 1 lit. f DSGVO serves as the legal basis if we can invoke legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed, where available (e.g. for the UK, Canada and Israel), by adequacy decisions of the EU Commission (Art. 45 Ab. 3 DSGVO).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer is usually standard contractual clauses, unless we indicate otherwise. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b DSGVO, they guarantee the security of the data transfer. Many of the providers have given contractual guarantees that protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding an obligation of the third party to inform data subjects if law enforcement bodies want to access data.

1.4 Storage period

Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their 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 is restricted, i.e. the data is blocked and not processed for other purposes. This applies, for example, to data that we must retain for reasons of commercial or tax law.

1.5 Rights of the persons concerned

Data subjects have the following rights with respect to personal data concerning them:

Right to information,
Right to rectification or erasure,
Right to restriction of processing,
Right to object to processing,
Right to data portability,
Right to revoke consent given at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6 Obligation to provide data

Within the scope of a business relationship or other relationship, customers, interested parties or third parties only have to provide us with the personal data that is required for the establishment, implementation and termination of the business relationship or for the other relationship or which we are legally obliged to collect. Without this data, we will usually have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7 No automatic decision-making in individual cases

For the establishment and implementation of a business relationship or other relationship, we generally do not use fully automated decision-making pursuant to Article 22 DSGVO. Should we use these procedures in individual cases, we will inform you separately if this is required by law.

1.8 Contacting

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 p. 1 lit. f DSGVO) in answering enquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are statutory retention obligations.

1.9 Customer surveys

From time to time we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 p. 1 lit f DSGVO. We delete the data when the results of the surveys have been evaluated.

2. newsletter

We reserve the right to inform customers who have already used services from us or purchased goods about our offers from time to time by e-mail or other electronic means, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Our legitimate interest lies in direct advertising (recital 47 DSGVO). Customers can object to the use of their email address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each email or by sending an email to our above-mentioned email address.

Based on the consent of the recipients (Art. 6 para. 1 p. 1 lit. a DSGVO), we also measure the opening and click-through rate of our newsletters to understand which content is relevant to our recipients.

We send newsletters with the tools

Mailchimp of the provider Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (privacy policy: https://mailchimp.com/legal/privacy/). The provider processes content, usage, meta/communication data and contact data in the USA.
rapidmail of the provider rapidmail GmbH, Augustinerplatz 2, 79098 Freiburg (privacy policy: https://www.rapidmail.de/datenschutz). The provider processes content, usage, meta/communication data and contact data in the EU.

3. data processing on our website

3.1 Informational use of the website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

These data are:

IP address
Date and time of the request
Time zone difference from Greenwich Mean Time (GMT)
Content of the request (specific page)
Access Status/HTTP Status Code
Data volume transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2 Web hosting and provision of the website

Our website is hosted by webgo GmbH, Heidenkampsweg 81 20097 Hamburg. In doing so, the provider processes the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis of the data processing is Art. 6 para. 1 p. 1 lit. f DSGVO.

We use a content delivery network to help provide our website. The provider is Cloudflare Inc, 106 East 6th Street, Suites 350 and 400, Austin, TX 78701, USA (privacy policy: https://www.cloudflare.com/en-gb/privacypolicy/). In doing so, the provider processes the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis of the data processing is Art. 6 para. 1 p. 1 lit. f DSGVO.

3.3 Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in answering enquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. f DSGVO.
We delete the data accruing in this context after storage is no longer necessary or restrict processing if there are statutory retention obligations.

3.4 Job advertisements

We publish vacancies that are available in our company on our website, on pages linked to the website or on third-party websites.
The processing of the data provided as part of the application is carried out for the purpose of implementing the application procedure. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 (1) DSGVO in conjunction with Section 26 (1) BDSG. We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, this is based on their consent (Art. 6 para. 1 p. 1 lit. a DSGVO).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing in the context of the processing of the CV or covering letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a DSGVO).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 p. 1 lit. a DSGVO.

We pass on the applicants' data to the responsible employees in the HR department, to our order processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we only delete the data after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to also use their data for further application procedures, we will not delete their data until one year after receipt of the application.

3.5 Booking appointments

Site visitors can book appointments with us on our website. For this purpose, we process meta data or communication data in addition to the data entered. We have a legitimate interest in offering interested parties a user-friendly option for making appointments. Therefore, the legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Insofar as we use a tool from a third-party provider for the agreement, the information on this can be found under "Third-party providers".

3.6. assessments

Site visitors can leave reviews on our website for our goods, services or generally about our company. For this purpose, we process meta data or communication data in addition to the data entered. We have a legitimate interest in receiving feedback from site visitors about our offer. Therefore, the legal basis of the data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Insofar as we use a tool from a third-party provider for the agreement, the information on this can be found under "Third-party providers".

3.7 Customer area

Site visitors can open a customer account on our website. We process the data requested in this context to fulfil the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 p. 1 lit. b DSGVO.

We process the data entered during registration, e.g. name, address and certificates.

3.8 Single sign-on procedure

Site visitors can log in to our website using single sign-on procedures. In doing so, they use the login data already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. When a site visitor logs in using single sign-on procedures, we receive information from the provider that the site visitor is logged in with the provider and the provider receives information that the site visitor is using the single sign-on procedure on our website. Depending on the settings of the site visitor in his account on the provider's site, additional information may be provided to us by the provider. The legal basis for the processing is the usage agreements concluded between the user and the provider.

The providers of the procedures are:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Privacy Policy: https://policies.google.com/privacy)
Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook", for Facebook and Instagram)

The data we receive from Facebook is disclosed to site visitors by Facebook as part of the registration process. Information on Facebook and the contact details of the data protection officer as well as further information on how Facebook processes personal data, including the legal basis and the options for exercising rights as a data subject vis-à-vis Facebook, can be found at https://www.facebook.com/about/privacy. We are jointly responsible with Facebook for the data processing taking place through Facebook in the context of the use of the procedure and have concluded a joint responsibility agreement (Art. 26 DSGVO) with Facebook. There we have defined the respective responsibilities for the fulfilment of the obligations under the GDPR with regard to joint processing. We are obliged to provide the above information and Facebook has assumed responsibility for the further data subject rights pursuant to Art. 15-20 DSGVO.

3.9 Offer of goods or services

We offer goods or services through our website. In the ordering process or shipping, we may involve PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg (for Paypal and/or Braintree), which only receive the personal data required in each case to provide a service. The processing of the data takes place for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 p. 1 lit. b DSGVO).

3.10. Technically necessary cookies

Our website uses cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the website more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, we use technically necessary cookies that store log-in data.

3.11. Third party providers

3.11.1 Visitor analytics

We use Visitor analytics for analysis. The provider is Visitor Analytics GmbH, Stefan-George-Ring 19, 81929 Munich, Germany. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a DSGVO. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://www.visitor-analytics.io/de/support/rechtliches-datenschutz-zertifikate/visitor-analytics-webseite/datenschutzerklaerung/.

3.11.2 YouTube videos

We use YouTube videos for videos on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for transfers to a country outside the EEA is consent.

Further information is available in the provider's privacy policy at https://policies.google.com/privacy.

3.11.3 Facebook Custom Audiences

We use Facebook Custom Audiences for advertising. The provider is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

We delete the data when the purpose for collecting it no longer applies. Further information is available in the provider's privacy policy at https://www.facebook.com/policy.php.

3.11.4 Google Tag Manager

We use Google Tag Manager for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.

We delete the data when the purpose for collecting it no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.11.5 Google Analytics

We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

4. data processing on social media platforms

We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behaviour, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. For this purpose, the operators of the networks store information on user behaviour in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies have access to the data.

When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the enquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

4.1 Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. One way to object to data processing is via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are jointly responsible for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 DSGVO with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a quicker response if they contact Facebook directly.

4.2 Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

4.3 Tiktok

We maintain a profile on Tiktok. The operator is musical.ly Inc, 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA. The privacy policy is available here: https://www.tiktok.com/de/privacy-policy.

4.4 Pinterest

We maintain a profile on Pinterest. The operator is Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA. The privacy policy is available here: https://about.pinterest.com/de/privacy-policy. One way to object to data processing is via the settings for advertisements: https://about.pinterest.com/de/privacy-policy.

4.5 YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de.

4.6 LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

4.7 Xing

We maintain a profile on Xing. The operator is New Work SE, Dammtorstraße 29-32, 20354 Hamburg. The privacy policy is available here: https://privacy.xing.com/de/datenschutzerklaerung.

5. changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

6. questions and comments

If you have any questions or comments regarding this privacy policy, please contact us using the details above.