Privacy Policy – Effective, May 2018

 

1.  Name and contact details of organisation responsible for data processing

 

This data protection information applies to data processing carried out by:

 

Organisation:        

executive english

c/o Quantumcat GmbH & Co. KG,

represented by Managing Director Beth Negus,

Hanselmannstraße 39, 80809 München

Email : info @executiveenglish.eu

 

2.  Collection and storage of personal data, data type and usage

 

When you visit our website www.executiveenglish.eu, the browser on your device automatically sends information to the server on our website. This information is temporarily stored in a so-called log file. The following information is routinely stored and remains so until it is automatically deleted:

 

·    ·  IP-address of the requesting computer

·       Date and time of access

·       Name und URL of the retrieved file

·       Website from which access is made (referrer URL)

·      The browser used and, if applicable, your computer’s operating system as well as the name of your access provider.  

 

The data identified above are leveraged by us in the following way:

 

·     To ensure an uninterrupted website connection

·     To ensure a satisfactory user-experience whilst visiting our website

·       To evaluate system security and stability

·     For other administrative purposes

 

The legal framework that supports this data processing is pursuant to Art. 6 para. 1 s. 1 lit. f of the General Data Protection Regulation forthwith referred to as the “GDPR.” Our legitimate interest in your data surrounds the usages listed above that relate to our collection of data. Under no circumstances do we use the data collected for the purpose of building intelligence about you personally.

 

In addition, we use cookies and analytics when you visit our website. For more information, see below.

 

If you have expressly consented to our using your email address in order to send regular newsletters, then this is carried out according to Art. 6 para. 1 s. 1 lit. a of the GDPR. In order to receive the newsletter, it is sufficient to provide us with an e-mail address. When you register to receive one of our newsletters the so-called "double opt-in procedure" applies. This means that upon receipt of your registration to receive our newsletter, we will contact you to confirm that you still wish to receive it. If you do not confirm your registration, your information will be blocked and automatically deleted by the following quarter. During this time, we will store your corresponding IP addresses and the time of both your registration and confirmation. The justification for this is simply to be able to prove that you have opted in and, if under scrutiny, to provide transparency relating to any possible misuse of your personal data.

 

You are free to unsubscribe from our newsletters at any time using the link provided at the end. Alternatively, you can send your un-subscribe request, at any time, by e-mail to info@executiveenglish.eu or to the contact details given in the imprint.

 

If you should have any questions of any sort, you are free to contact us using the contact form available on the website. A valid e-mail address is required, in order to identify the origin of the sender and respond appropriately. Additional information may be provided voluntarily. This data associated with contacting us, are processed in accordance with Art. 6 para. 1 s. 1 lit. a of the GDPR that pertains to the handling of data provided to us voluntarily.  The same applies to the use of the questionnaire that we send out prior to one of our seminars. The personal data collected by us through our contact form will be automatically deleted once your request has been processed. This applies further to any personal data collected by us in the questionnaire – which will be deleted automatically 14 days after the event has taken place.

 

3.  The sharing of your personal data

 

Your personal data will not be passed on to third parties for purposes other than those listed below.

 

We will only provide third parties with your personal data if:

·     You have given your expressed consent pursuant to Art. 6 Para. 1 s. 1 lit. f of the GDPR

·       The disclosure, pursuant to Art. 6 para. 1 s. 1 lit. f of the GDPR, is deemed necessary in order to assert, exercise or defend legal claims assuming there is no reason to think that it’s in your overriding interest to have your data protected and withheld.

·     The disclosure, pursuant to Art. 6 para. 1 s. 1 lit. f of the GDPR, is deemed necessary in order to assert, exercise or defend legal claims assuming there is no reason to think that it’s in your overriding interest to have your data protected and withheld.

·        A legal obligation exists, pursuant to Art. 6 para. 1 s. 1 lit. c of the GDPR, in which disclosure is found to be legally permissible and deemed necessary for the processing of the contractual relationship with you pursuant to Art. 6 para. 1 s. 1 lit. b of the GDPR.

 

4.  Cookies

 

We use cookies on our site. These are small files that your browser automatically generates when you visit our site and which are stored on your device (laptop, tablet, smartphone, etc.). Cookies cause no damage to your end device, do not contain viruses, trojans or other malware.

Information is stored in the cookie that is generated uniquely through the connection with your specifically used terminal device. However, this action does not mean that we are able to immediately capture information relating to your identity.

The use of cookies is two-fold. Firstly, they serve to make your experience with us more enjoyable. For example, we use so-called session cookies able to recognise whether you have visited specific pages on our website. These are then automatically deleted upon your leaving our site. Additionally, we also use temporary cookies that are stored on your end device for a specified period of time to optimise user-friendliness. If you visit our site again to use our services, it will automatically recognise that you have already been with us and what entries you made and settings you selected so that you are not requested to enter them again.

 

Secondly, we use cookies to statistically capture the activity on our website and to evaluate it for you with a view to optimising our service offering (see Section 5). These cookies enable us to automatically recognise when you revisit our site and register that you were already with us. These cookies are automatically deleted after a defined period of time.

 

The data collected by cookies is required for the aforementioned purposes in order to protect our legitimate interests and those of third parties pursuant to Art. 6 Para. 1 s. 1 lit. f of the GDPR. Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to reduced functionality or restricted features on our website.

 

5.  Analysis tools

 

The tracking methods listed below, and used by us, are carried out pursuant to Art. 6 para. 1 s. 1 lit. f of the GDPR. Through the use of these tracking methods, we can ensure that our website is designed to meet the requirements of our customers and optimised on an ongoing basis. Additionally, we use these tracking methods to statistically capture the activity on our website and to evaluate it for the purpose of optimising our service offering to you. These interests are deemed to be legitimate according to the afore mentioned provision. The reasons given for data processing and data categories are listed below relational to the corresponding tracking tools:

 

Google Analytics

For the purpose of demand-oriented design and continuous optimisation of our pages, we use Google Analytics, a web analysis service of the

Google Inc.   (https://www.google.de/intl/de/about/)  (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google"). In this context, pseudonymized user profiles are created and cookies are used. The information gathered during your website visit through the use of cookies is transferred to a Google server in the USA and stored there. This information includes:

 

·       Browser type/version,

·       Operating system used

·       Referrer URL (the previously visited page)

·       Host name of the accessing computer (IP address)

·       Time of the server request

 

The information is used to evaluate the use of the website, to compile reports on website activities, to provide further services associated with the use of the website and the Internet, and for the purposes of market research and demand-oriented design of these internet pages. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of the company. Under no circumstances will your IP address be combined with other data from Google. The IP addresses are anonymized so that such an assignment is rendered impossible (IP masking).

 

You may choose to deactivate the use of cookies by selecting the appropriate settings on your browser, however you should note that doing this may lead to reduced functionality or restricted features on this website.

You may also choose to prevent the collection of data generated by cookies in relation to the use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).   (https://tools.google.com/dlpage/gaoptout?hl=de).

 

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking on the above link. An opt-out cookie is then activated to prevent future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will be required to reset the opt-out cookie.

 

Further information on data protection in connection with Google Analytics can be found in the Google Analytics Help (https://support.google.com/analytics/answer/6004245?hl=en). .

 

6.  Google Adwords conversion tracking  

We use the online advertising program "Google AdWords" and conversion tracking as part of Google AdWords. Google Conversion Tracking is an analysis service belonging to Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, “Google”).

When you click on an ad served by Google, a conversion tracking cookie is placed on your computer. These cookies lose their validity after 30 days, 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 recognise that you clicked on the ad and were redirected to this page. This information is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. If you do not wish to participate in tracking, you can object by preventing the installation of cookies and setting your browser software accordingly (deactivation option). They are then not included in the conversion tracking statistics. Further information and Google's privacy policy can be found at:

http://www.google.com/policies/technologies/ads/, http://www.google.de/policies/privacy/   http://www.google.de/policies/privacy/

 

 

7.  Social media plugins

 

We use social plugins for the social networks published on our website pursuant to Art. 6 par. 1 s. 1 lit. f of the GDPR to raise awareness of our company. The underlying reason for this namely - advertising - is deemed to be a legitimate interest stipulated by the GDPR. The responsibility for ensuring data protection-compliant operations lies with the respective provider.

 

We currently use the following social media plug-ins:

Facebook and LinkedIn.

 

When you access a page of our website that contains such a plugin, your browser establishes a direct connection to the servers of the respective provider. The content of the plugin is transmitted directly to your browser and integrated into the website.

By integrating the plugins, the respective provider receives the information that your browser has called up the corresponding page of our website, even if you do not have an account or are not currently logged in with the respective provider. By activating the plugin, personal data are transferred from you to the respective plugin provider and stored there (for US providers in the USA). Since the plugin provider collects data particularly via cookies, we recommend that you delete all cookies before clicking on the greyed-out box using your browser's security settings.

 

If you are logged in with the respective provider at the time, this provider can directly assign the visit of our website to your respective account and store corresponding information. The plugin provider stores the data collected about you as user profiles and uses these for the purposes of advertising, market research and/or the demand-oriented design of its website. In particular, this analysis (also for non-logged-in users) enables them to conduct demand-oriented design-based advertising and provide other users of that social network with information about your activities on our website. You have the right to object to the creation of such user profiles, although you must personally contact the respective plug-in provider so as to exercise this right. Through these plugins, we offer you the possibility to interact with social networks and other users, so that we can improve our service offering and make it more relevant for you as a user. The legal foundation for the use of the plugins is Art. 6 para. 1 s. 1 lit. f of the GDPR.

 

Regarding these plug-ins, we have no control over the data collected or the data processing practices applied, nor are we aware of the full extent of data collection, the reasons for its collection, or the storage periods. We also have no information pertaining to the deletion of the data collected by the plug-in provider.

 

As outlined above, this data transfer happens independently of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plugin provider, your data collected with us will be directly assigned to your existing account with the plugin provider. If you click the activate button and, for example, link to the page, the plugin provider will also save this information in your user account and communicate it to your contacts publicly. We recommend that you log out regularly after using a social network, especially before clicking the activate button, as this way you can avoid being assigned to your profile with the plugin provider.

 

Further information on the reasons for and scope of data processing by the plug-in provider can be found in the data protection declarations of these providers listed below. They will also provide you with further information regarding your rights in this matter and enable options for you to protect your privacy.

 

Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA;

http://www.facebook.com/policy.php ;

Further information on data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and http://www.facebook.com/about/privacy/your-info#everyoneinfo. Facebook is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy.

hLinkedIn is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

 

8.  Integration of YouTube videos

 

We have YouTube videos integrated into our online service offering, which are stored at http://www.YouTube.com and can be viewed directly on our website.

 

By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. This is independent of whether YouTube provides a user account through which you are logged in or whether no such user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on YouTube, you must log out before clicking the activate button. YouTube stores your data as user profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. Such an analysis takes place in particular (even for non-logged-in users) for the serving of customised advertising and to inform other social network users about your activities on our website. You have the right to object to the creation of these user profiles, although you must contact YouTube personally to exercise this right.

 

For further information on the reasons for and scope of data processing by YouTube, please refer to their privacy policy. There, you will also find supplementary information about your rights and the settings you can select to protect your privacy: https://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

9.  Rights of the persons concerned

 

You have the legal right to:

 

·     Request information about your personal data collected by us pursuant to Art. 15 of the GDRP. In particular, you may request information about the reasons for our collecting and processing data, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the envisaged storage period, the existence of a right to rectification, deletion, processing restrictions or objection, the existence of a right to appeal, the origin of your data – should this not have us at its source – as well as details surrounding the existence of any automated decision making processes that may possibly include profiling or the harnessing of significant information.

·     Demand the immediate rectification of incorrect or incomplete personal data collected by us pursuant to Art. 16 of the GDRP.

·     Demand the immediate deletion of your personal data stored by us pursuant to Art. 17 of the GDRP unless this data are deemed necessary in order to exercise the right to freedom of expression and information, to fulfil a legal obligation for reasons of public interest, or to assert, exercise or defend a legal claim.

·     Restrict the processing of your personal data pursuant to Art. 18 of the GDPR in cases where you dispute its accuracy, deem the processing of it unlawful, wish to have the data processing restricted but do not wish to have it deleted altogether, we no longer need the personal data for the purposes of the processing but they are required by you to assert, exercise or defend a legal claims, or where you have filed an objection to the processing pursuant to Art. 21 of the GDPR.

·     ·       Request that you receive the personal data that you have provided to us in a structured, current and machine-readable format or to request its transfer to another person responsible pursuant to Art. 20 of the GDPR.

·     Revoke your consent to the processing of your data at any time rendering us prohibited from the continued processing of that data in the future and pursuant to Art. 7 para. 3 of the GDPR.

·     Complain to a supervisory authority pursuant to Art. 77 of the GDPR. As a rule, you can contact either the supervisory authority with jurisdiction in your usual place of residence or place of work or that of our organisations.

 

10.       Right of objection

 

If your personal data are processed on the basis of legitimate interests pursuant to Art. 6 para. 1 s.1 lit. f of the GDRP, you have the right to object to the processing of your personal data pursuant to Art. 21 of the GDPR, provided that there are grounds for this which arise due to your particular situation or your objection to direct advertising. In the latter case, you have a general right of objection, which we must act upon without your being required to specify any details. If you wish to exercise your right of revocation or objection, simply send an e-mail to info@executiveenglish.eu.

 

11.       Data security

 

We use the most common standard SSL procedure (Secure Socket Layer) in connection with the highest encryption level supported by your browser. Usually this is a 256 bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. You can tell whether a single page of our website is transmitted in encrypted form by referring to the icon in your browser that displays a locked key.

 

We also use suitable technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.