a. The right to lodge a complaint with a supervisory authority in accordance with Article 13 paragraph 2 (d) GDPR and Article 14 paragraph 2 (e) GDPR.
b. Right of access in accordance with Article 15 GDPR
c. Right to rectification in accordance with Article 16 GDPR
d. Right to erasure („right to be forgotten“) in accordance with Article 17 GDPR
e. Right to restriction of processing in accordance with Article 18 GDPR
f. Right to data portability in accordance with Article 20 GDPR
g. Right to objection in accordance with Article 21 GDPR
Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.
The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.
1. We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
2. These security measures include in particular the encrypted transfer of data between your browser and our server.
1. A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
2. If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
3. If we use content, tools or other means from other companies (hereinafter collectively referred to as "third party providers") whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third-party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.
1. When using our online-service, information may be transferred automatically from the browser of the user to us; this information includes the name of the accessed website, file, date and time of the access, amount of data transferred, notification about successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
2. The processing of this information takes place based on legitimate interests in accordance with Article 6 paragraph 1 (f) GDPR (e.g. to optimize the online service) as well as to ensure the security of processing in accordance with Article 5 paragraph 1 (f) GDPR (e.g. for the defence and clarification purposes of cyberattacks)
3. This information will be automatically deleted 30 days after the termination of the connection, unless any other retention periods require otherwise.
4. The collection of the data and the storage of the data in log files is essential for the provision of the online service. Therefore users are not entitled to the options of erasure, objection or correction.
2.2 Amazon CloudFront CDN
1. We use the content delivery network (CDN) Cloudfront. The provider is Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855, Luxembourg (hereinafter "Amazon"). Amazon will act as a subcontractor of Webflow.
2. Amazon CloudFront CDN is a globally distributed content delivery network. This technically routes the transfer of information between your browser and our website through the Content Delivery Network. This allows us to increase the global accessibility and performance of our website.
3. The use of Amazon CloudFront CDN is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6 para. 1 lit. f DSGVO).
4. Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/.
5. More information about Amazon CloudFront CDN can be found here:
https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice__German_Translation.pdf.
2.3 Youtube
1. data processing
We have integrated YouTube videos into our online offer, which are stored on the YouTube platform and can be played directly from our website. YouTube is a service of Google LLC, D / B / A YouTube. 901 Cherry Ave, San Bruno, CA 94066, USA (hereinafter referred to as "Google").
We have no influence on transmission of user data to Google. The data transfer takes place regardless of whether Google provides a user account through which you are logged in or whether there is no user account. If you are logged in to Google, your data will be directly assigned to your account.
2. purposes and legal basis
The legal basis for the processing of your personal data is your legitimate interest according to Art. 6 para. 1 sentence 1 lit. a) GDPR. We use YouTube videos on our website to present them in a simple way.
3. During the data transfer to Google, your personal data will be transferred to Google servers, which may also be located in the USA. The USA is a country without a level of data protection adequate to that of the EU. This means, in particular, that the US authorities can access personal data in a simplified manner and that there are limited rights to such measures. When you enable the YouTube video feature, you expressly consent to the transfer of data to Google and to the transfer of your personal data to servers in the United States.
4. Further information
Further information on data processing, in particular the legal basis and the storage period of Google, can be found in the privacy policy of the provider (https://policies.google.com/privacy) and in the privacy banner on the YouTube platform. There you will also find further information on your rights and setting options to protect your privacy.
Google reloads further services, these include in particular
a. DoubleClick
b. Google Fonts
c. Google Photos
d. Google Video
e. Google (https://www.google.com)
In doing so, Google may also process your data in the USA, a third country without sufficient data protection.
3 Processing for the purpose of carrying out our business processes
3.1 Registration
1. Every user will create their own account on the platform by signing up. The user has to register with their full name, email address (these are the defaults fields that need to be filled in), job title, organisation name and location (the latter information is needed to ensure that the correct target audience takes the course). Then the user also sets up a username and password. Already during registration the user of the platform is informed about the data protection relevant processing via this privacy policy.
2. Upon approval by FOUR PAWS the user’s account will be activated. The user will be informed by email about the activation of his account as well as about the individual course assignment. The communication via email is necessary for the execution of the contractual relationship between FOUR PAWS and the user of the platform.
3. When the user logs-in for the first time, he/she must read and agree to the terms of use (TOS).
3.2 Participation in an online course
1. For participation in an online course on our platform, we process data for the provision of an individual account (e.g. name, password).
2. Furthermore, our platform collects usage data (e.g. time of registration, learning progress) in order to control the learning process and evaluate your level of knowledge.
3. These processing is necessary for the execution of the contractual relationship between FOUR PAWS and the user of the platform.
3.3 Links to other websites
1. While using some of our services, you will be automatically redirected to other websites.
2. Please note that this privacy policy does not apply there. The privacy policy of the linked website may differ significantly from this one.
4 Cookie Policy
4.1 General Information
1. Cookies are information transmitted by our web server or third-party web servers to the users' web browsers where they are stored for later retrieval. Cookies can be in the form of small files or any other types of information storage.
2. In the case that users do not want that cookies are stored on their computer, they will be asked to disable the corresponding option in their browser's system settings. Saved cookies may be deleted in the system settings of the browser. The exclusion of cookies can lead to functional impairments of this online service.
4.2 Cookie overview
|
Name
|
Provider
|
Purpose
|
Term
|
|
login_token
|
talentlms.com
|
‚Login token‘ is used to recognise users across sessions
|
Duration of session
|
|
PHPSESSID
|
talentlms.com
|
‚PHPSESSID“ is used to provide functions across pages.
|
1 day
|
|
VISITOR_INFO1_LIVE
|
youtube.com
|
This is a cookie that YouTube sets to calculate the user's
bandwidth.
|
180 days
|
|
YSC
|
youtube.com
|
‘YSC’ is used by YouTube to remember user input and
associate a user’s actions. This cookie lasts for as long as the user keeps
their browser open.
|
Duration of session
|
4.3 Objection Options
You may object to the use of cookies that are used for measuring the range of coverage and promotional purposes via
a. deactivation page of the Network Advertising Initiative: http://optout.networkadvertising.org/
b. the US-American website: http://www.aboutads.info/choices
c. the European website http://www.youronlinechoices.com/uk/your-ad-choices/
5 Changes to the Data Privacy Policy
1. We reserve the right to change this Data Privacy Policy with regards to the data processing, in order to adapt it to changed legal situations, to changes of the online service or of the data processing.
2. If users' consents are required or if elements of the Data Privacy Policy contain provisions in regards to the contractual relationship with the users, the changes will only be made with the consent of the users.
3. Users are requested to keep themselves informed about the content of this Data Privacy Policy on a regular basis.
