Privacy policy
This privacy policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profiles. (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
RESPONSIBLE
Name/Company: Lernstudio Barbarossa MegaKids Fortbildungs GmbH
Street no.: Mühlstraße 25
Zip code, City, Country: 67659 Kaiserslautern, Germany
Commercial register no.: HRB 3783
Managing directors: Michael Thier, Klaus Müller
Telephone number: 0631 362410
E-mail address: info@lernstudio-barbarossa.de
Data Protection Officer:
Name: Peter Stephens
E-mail address: p.stephens@lernstudio-barbarossa.de
Types of data processed:
Inventory data (e.g., names, addresses).
Contact details (e.g., e-mail, telephone numbers).
Content data (e.g., text entries, photographs, videos).
Contract data (e.g., subject matter of the contract, term, customer category).
Payment data (e.g. bank details, payment history).
Usage data (e.g., websites visited, interest in content, access times).
Meta/communication data (e.g., device information, IP addresses).
Processing of special categories of data (Art. 9 para. 1 GDPR):
No special categories of data are processed.
Categories of data subjects affected by the processing:
Customers / interested parties / suppliers.
Visitors and users of the online offer.
In the following, we also refer to the persons concerned collectively as “users”.
Purpose of the processing:
Provision of the online offer, its contents and functions.
Provision of contractual services, service and customer care.
Answering contact requests and communicating with users.
Marketing, advertising and market research.
Status: 15.05.2018
1. in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).
The security measures include in particular the encrypted transmission of data between your browser and our server.
4. cooperation with processors and third parties
4.1. If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Art. 6 para. 1 lit. b GDPR), you have given your consent, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
4.2. If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
5. transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
6. rights of the data subjects
6.1. You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
6.2. You have accordingly. Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
6.3. In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.
6.4. You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transfer to other controllers.
6.5. In accordance with Art. 77 GDPR, you also have the right to lodge a complaint with the competent supervisory authority.
7. right of withdrawal
You have the right to withdraw your consent in accordance with Art. 7 (3) GDPR with effect for the future.
8. right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. In particular, you may object to processing for direct marketing purposes.
9. cookies and right to object to direct advertising
We use temporary and permanent cookies, i.e. small files that are stored on users’ devices (for an explanation of the term and function, see the last section of this privacy policy). Some of the cookies are used for security purposes or are necessary for the operation of our online offering (e.g. to display the website) or to save the user’s decision when confirming the cookie banner. In addition, we or our technology partners use cookies to measure reach and for marketing purposes, about which users will be informed in the course of the privacy policy.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that you may then not be able to use all the functions of this website.
Error: The domain WWW.LERNSTUDIO-BARBAROSSA.DE is not authorized to show the cookie declaration for domain group ID 7b41af87-90d4-4573-9255-dd27ed326e42. Please add it to the domain group in the Cookiebot Manager to authorize the domain.
10. deletion of data
10.1. The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
10.2. In accordance with legal requirements, storage is carried out in particular for 6 years in accordance with Section 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).
11. provision of contractual services
11.1. We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.
We process usage data (e.g., the websites visited on our online offering, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile, e.g., to display product information to users based on the services they have used to date.
11.2. The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); information in the customer account remains until its deletion.
12. credit report
12.1. If we make advance payments (e.g. when purchasing on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard our legitimate interests.
12.2. As part of the credit report, we transmit the following personal data of the customer (name, postal address, date of birth, details of the type of contract, bank details) to the following credit agencies:
SCHUFA company (SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden), data protection information: https://www.schufa.de/de/ueber-uns/daten-scoring/.
12.3. We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.
12.4. The decision as to whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information provided by the credit agency.
12.5. If we obtain express consent from you, the legal basis for the credit report and the transmission of the customer’s data to the credit agencies is consent pursuant to Art. 6 para. 1 lit. a, 7 GDPR. If no consent is obtained, our legitimate interests in the security of your payment claim are the legal basis in accordance with Art. 6 para. 1 lit. f. GDPR.
13. contact
13.1. When contacting us (via contact form or e-mail), the user’s details are processed to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.
13.2. User data may be stored in our Customer Relationship Management System (“CRM System”) or comparable inquiry organization.
13.3. We delete the requests if they are no longer required. We review the necessity every two years; we store inquiries from customers who have a contract with us permanently and refer to the details of the customer account for deletion. In the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
14. collection of access data and log files
14.1. We collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
14.2. Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
15. online presence in social media
15.1. On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we maintain online presences within social networks and platforms. GDPR, we maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
15.2. Unless otherwise stated in our privacy policy, we process users’ data if they communicate with us within social networks and platforms, e.g. write posts on our online presences or send us messages.
16. cookies & reach measurement
16.1. Cookies are pieces of information that are transferred from our web server or third-party web servers to the user’s web browser and stored there for later retrieval. Cookies may be small files or other types of information storage.
16.2. We use “session cookies”, which are only stored for the duration of the current visit to our online presence. A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close the browser, for example.
16.3. Users are informed about the use of cookies in the context of pseudonymous reach measurement in this privacy policy.
16.4. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
16.5. You can object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative(http://optout.networkadvertising.org/) and additionally the US website(http://www.aboutads.info/choices) or the European website(http://www.youronlinechoices.com/uk/your-ad-choices/).
17 Google Analytics
17.1. If you have given your consent, Google Analytics, a web analysis service of Google Ireland Limited (“Google”), is used on this website. The use includes the “Universal Analytics” operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID and thus to analyze the activities of a user across devices.
17.2. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on this website, your IP address will be shortened by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. We would like to point out that Google Analytics has been extended to include IP anonymization on this website in order to ensure anonymous collection of IP addresses (so-called IP masking). The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can find more information on terms of use and data protection at https://www.google.com/analytics/terms/de.html or at https://policies.google.com/?hl=de.
17.3 Purposes of processing
Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.
17.4 Legal basis
The legal basis for the use of Google Analytics is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.
17.5 Recipients / categories of recipients
The recipient of the collected data is Google.”
17.6 Transfer to third countries
The personal data is transferred to the USA under the EU-US Privacy Shield on the basis of the adequacy decision of the European Commission. You can download the certificate here.
17.7 Duration of data storage
The data sent by us and linked to cookies, user identifiers (e.g. user ID) or advertising IDs are automatically deleted after 14 months. Data that has reached the end of its retention period is automatically deleted once a month.
17.8 Rights of data subjects
You can revoke your consent at any time with effect for the future by preventing the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.
17.9. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser add-on. Opt-out cookies prevent the future collection of your data when you visit this website. To prevent Universal Analytics from collecting data across different devices, you must opt out on all systems used. If you click here, the opt-out cookie will be set: Deactivate Google Analytics
18. use of the remarketing or “similar target groups” function of Google Inc.
18.1. We use the remarketing or “similar target groups” function of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”) on our website. If you have your habitual residence in the European Economic Area or Switzerland, Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) is the controller responsible for your data. Google Ireland Limited is therefore the company affiliated with Google that is responsible for the processing of your data and compliance with the applicable data protection laws. The application serves the purpose of analyzing visitor behavior and visitor interests. Google uses cookies to carry out the analysis of website usage, which forms the basis for the creation of interest-based advertisements. Cookies are used to record visits to the website and anonymized data on the use of the website. No personal data of visitors to the website is stored. If you subsequently visit another website in the Google Display Network, you will be shown advertisements that are highly likely to take into account previously accessed product and information areas. Your data may be transferred to the USA. Google has certified itself in accordance with the US-EU data protection agreement “Privacy Shield” and is therefore obliged to comply with European data protection guidelines. Data processing, in particular the setting of cookies, is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. You can find more information about Google Remarketing and the associated privacy policy at: https://www.google.com/privacy/ads/
19. use of Google Ads conversion tracking
19.1. We use the online advertising program “Google Ads” on our website and in this context conversion tracking (visit action evaluation). Google Conversion Tracking is an analysis service of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). If you have your habitual residence in the European Economic Area or Switzerland, Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) is the controller responsible for your data. Google Ireland Limited is therefore the company affiliated with Google that is responsible for processing your data and complying with the applicable data protection laws. When you click on an advertisement placed by Google, a cookie for conversion tracking is stored on your computer. These cookies have a limited validity, do not contain any personal data and are therefore not used for personal identification. If you visit certain pages of our website and the cookie has not yet expired, Google and we can recognize that you have clicked on the ad and have been redirected to this page. Each Google Ads customer receives a different cookie. It is therefore not possible for cookies to be tracked via the websites of Ads customers. The information obtained with the help of the conversion cookie is used to create conversion statistics. This tells us the total number of users who clicked on one of our ads and were redirected to a page with a conversion tracking tag. However, we do not receive any information with which users can be personally identified. Your data may be transferred to the USA. Google has certified itself in accordance with the US-EU data protection agreement “Privacy Shield” and is therefore obliged to comply with European data protection guidelines. Data processing, in particular the setting of cookies, is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. You can find more information and Google’s privacy policy at: https://www.google.de/policies/privacy/
20. newsletter
20.1. With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
20.2. Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter “newsletter”) with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Our newsletters also contain information about our products, offers, promotions and our company.
20.3. Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no-one can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.
20.4. Dispatch service provider: The newsletter is sent via “MailChimp”, a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the mailing service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European level of data protection(https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active).
20.5. Furthermore, the mailing service provider may, according to its own information, use this data in pseudonymous form, i.e. without allocation to a user, to optimize or improve its own services, e.g. to technically optimize the mailing and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or pass it on to third parties.
20.6. Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.
20.7. Performance measurement – The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the server of the mailing service provider when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, is initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the mailing service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
20.8. The newsletter is sent and its success measured on the basis of the recipient’s consent in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with Section 7 para. 2 no. 3 UWG or on the basis of legal permission in accordance with Section 7 para. 3 UWG.
20.9. The logging of the registration process is based on our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR and serves as proof of consent to receive the newsletter.
20.10. Cancellation/revocation – Newsletter recipients can cancel the receipt of our newsletter at any time, i.e. revoke their consent. You will find a link to unsubscribe from the newsletter at the end of each newsletter. At the same time, their consent to the performance measurement expires. Unfortunately, it is not possible to cancel the performance measurement separately; in this case, the entire newsletter subscription must be canceled. When you unsubscribe from the newsletter, your personal data will be deleted, unless their retention is legally required or justified, in which case their processing will be limited to these exceptional purposes. In particular, we may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them for the purpose of sending newsletters in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time.
21. integration of third-party services and content
21.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR) content or service offers from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.
21.2. The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out):
External fonts from Google, LLC, https://www.google.com/fonts (“Google Fonts”). Google Fonts are integrated by calling up a Google server (usually in the USA). Privacy policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
Maps of the “Google Maps” service of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
Videos from the “YouTube” platform of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
We use functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Each time one of our pages containing Xing functions is accessed, a connection to Xing servers is established. To the best of our knowledge, no personal data is stored in the process. In particular, no IP addresses are stored or usage behavior evaluated. Privacy policy: https://www.xing.com/app/share?op=data_protection.
We use the functions of the TrustPilot network. The provider is Trustpilot A/S, Pilestraede 58, 5th floor, 1112 Copenhagen, Denmark, CVR no.: 30276582. TrustPilot is a rating system for customers via which the customer can rate the services of Lernstudio Barbarossa. Privacy policy: https://de.legal.trustpilot.com/end-user-privacy-terms
External code of the JavaScript framework “jQuery”, provided by the third-party provider jQuery Foundation, https://jquery.org.
The State Commissioner for Data Protection and Freedom of Information Rhineland-Palatinate
Prof. Dr. Dieter Kugelmann
Postal address:
P.O. Box 30 40
55020 Mainz
Visitor address:
Hintere Bleiche 34
55116 Mainz
Phone: 06131 208-2449
E-mail: poststelle@datenschutz.rlp.de
Web: https://www.datenschutz.rlp.de/de/themenfelder-themen/der-landesbeauftragte/