Privacy policy

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Privacy policy

1. introduction

In the following, we inform 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

Responsible person acc. Art. 4 par. 7 EU General Data Protection Regulation (GDPR) is aledu GmbH, Bismarckstraße 67, 47057 Duisburg, 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 bases

The scope of the processing of the data, processing purposes and legal bases we detail below. The following are generally considered as the legal basis for data processing:

  • 6 para. 1 p. 1 it. a DSGVO serves us 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 fulfillment 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, such as inquiries about our products or services.
  • 6 para. 1 p. 1 lit. c DSGVO applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • 6 para. 1 p. 1 lit. f DSGVO serves as the legal basis if we can rely on 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, i.e., 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 ensure the security of the data transfer. Many of the providers have given contractual guarantees that protect data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of data or regarding an obligation of the third party to notify data subjects when law enforcement bodies want to access data.

1.4. Storage duration

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 are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are 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 data subjects

Data subjects have the following rights vis-à-vis us with regard to the personal data concerning them:

  • Right to information,
  • Right to rectification or deletion,
  • 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 enter into 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. If we use these procedures in individual cases, we will provide separate information on this if required by law.

1.8. Contact

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) to respond to inquiries directed to us. We delete the data accruing in this context after the storage is no longer required or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their needs better. In the process, 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 S. 1 lit f DSGVO is. 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 GDPR. Our legitimate interest lies in direct marketing (recital 47 DSGVO). Customers may object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail 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, Germany (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 informational 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 is.

These data are:

  • IP address
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (concrete 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 the legal basis for data processing is Art. 6 para. 1 p. 1 lit. f DSGVO is.

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 for 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 responding to inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. f GDPR.
We delete the data accruing in this context after the storage is no longer required or restrict the processing if there are legal retention obligations.

3.4. Job ads

We post jobs that are available within our company on our website, on sites 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 process. Insofar as these are necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. 1 DSGVO in conjunction with § 26 para. 1 BDSG. We have marked or refer to the data required for the application process accordingly. If applicants do not provide this information, we will not be able to 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 resumes and cover letters. They are not required for application. If applicants nevertheless provide relevant information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a DSGVO).

Finally, we process 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 GDPR.

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 will not delete the data until the employment relationship has ended. Otherwise, we will 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. Appointment booking

Site visitors can book appointments with us on our website. For this purpose, we process meta or communication data in addition to the data entered. We have a legitimate interest in offering interested parties a user-friendly way to make appointments. Therefore, the legal basis for data processing is Art. 6 para. 1 p. 1 lit. f GDPR. To the extent that we use a third party tool for the Agreement, the information about it can be found under “Third Party Providers”.

3.6. Reviews

Site visitors can leave reviews on our website for our goods, services or generally about our company. For this purpose, we process meta or communication data in addition to the data entered. We have a legitimate interest in receiving feedback from site visitors about our offerings. Therefore, the legal basis for data processing is Art. 6 para. 1 p. 1 lit. f GDPR. To the extent that we use a third party tool for the Agreement, the information about it 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 in order to fulfill 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 GDPR is.

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 credentials 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 the single sign-on method, we receive information from the provider that the site visitor is logged in to the provider and the provider receives information that the site visitor is using the single sign-on method on our website. Depending on the settings of the site visitor in his account on the site of the provider, it may be that additional information is provided to us by the provider. The legal basis of 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)

Which data we receive from Facebook is communicated to site visitors by Facebook as part of the registration process. Information about Facebook and the contact details of the data protection officer, as well as further information about how Facebook processes personal data, including the legal basis and the options for exercising rights as a data subject against Facebook, can be found at https://www.facebook.com/about/privacy. We are jointly responsible with Facebook for the data processing that takes place through Facebook as part of the use of the procedure and have entered into a shared responsibility agreement (Art. 26 DSGVO) with Facebook. There, we have defined the respective responsibilities for fulfilling the obligations under the GDPR with regard to joint processing. We are required to provide the above information and Facebook has assumed responsibility for the other data subject rights under Art. 15-20 GDPR.

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 sets 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 offer 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 GDPR. 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 supplier

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 GDPR. The processing is based on consent. Data subjects may 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 is available 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. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects may 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 legal basis for the transfer 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 of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects may 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 legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is ensured by means of the verification procedure pursuant to Art. 93 para. 2 DSGVO standard data protection clauses are guaranteed (Art. 46 para. 2 lit. c DSGVO), which we have agreed with the provider.

We delete the data when the purpose for which it was collected 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.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects may 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 legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is ensured by means of the verification procedure pursuant to Art. 93 para. 2 DSGVO standard data protection clauses are guaranteed (Art. 46 para. 2 lit. c DSGVO), which we have agreed with the provider.

We delete the data when the purpose for which it was collected 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.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a GDPR. The processing is based on consent. Data subjects may 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 legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is ensured by means of the verification procedure pursuant to Art. 93 para. 2 DSGVO standard data protection clauses are guaranteed (Art. 46 para. 2 lit. c DSGVO), which we have agreed with the provider.

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 is available in the provider’s privacy policy at https://policies.google.com/privacy?hl=de.

4. data processing on social media platforms

We are represented in social media networks 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 behavior, which are used, for example, to show advertising on the networks’ pages and elsewhere on the Internet that matches users’ interests. For this purpose, the operators of the networks store information on usage behavior 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 privacy statements of the respective operators listed below. It may also be that the operators or their servers are located in non-EU countries, so they process data there. This can result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies gain access to the data.

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

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, under our agreement with Facebook, we are required to forward requests to Facebook. So, affected people will get a faster 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. 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 feel free to contact us using the contact information provided above.

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