Online Studienkolleg (OSK)
c/o Excentric Marketing
Rua guilhermina suggia 6A Lisbon
Link to the imprint: https://onlinestudienkollegs.com/imprint/
Types of processed data:
– Inventory data (eg, names, addresses).
– Contact details (eg, e-mail, telephone numbers).
– Content data (eg, text input, photographs, videos).
– Usage data (eg, visited websites, interest in content, access times).
– Meta / communication data (eg, device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach Measurement / Marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term goes far and includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organisational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behaviour, whereabouts, or relocation of that natural person.
‘Responsible person’ means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, body or body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing in order to fulfil our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the case, that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.
We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organisational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and segregation. In addition, we have established procedures to ensure the enjoyment of data subject rights, the erasure of data and the response to data threats. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 DSGVO).
Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant access to the data, this is done only on the basis of a legal permission (eg if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfil the contract), you have consented to a legal obligation or based on our legitimate interests (eg the use of agents, webhosters, etc.).
Insofar as we commission third parties to process data on the basis of a so-called “contract processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure, or transmission of data to third parties, this will only be done if it is to fulfil 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 process or have the data processed in a third country only in the presence of the special requirements of Art. 44 et seq. DSGVO. This means that the processing takes place eg on the basis of special guarantees, such as the officially recognised statement of a data protection level corresponding to the EU.
Rights of data subjects
You have the right to request a confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted without delay, or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other responsible persons.
You have gem. Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.
You have the right to consent according to. Art. 7 para. 3 DSGVO with effect for the future.
Right to object
You may at any time object to the future processing of your data in accordance with Art. 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right to object to direct mail
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. “Persistent” or “persistent” refers to cookies that remain stored even after the browser has been closed. For example, the login status can be saved, when users visit them after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person responsible for providing the online offer (otherwise, if only their cookies are called “first-party cookies”).
If users do not want cookies stored on their machine, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy statement, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legally permitted 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 kept for commercial or tax reasons.
According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, for taxation relevant Documents, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).
According to legal regulations in Austria the storage takes place in particular for 7 J in accordance with § 132 exp. 1 BAO (accounting documents, receipts / invoices, accounts, documents, business papers, statement of income and expenses, etc.), for 22 years in connection with land and for 10 years in the case of documents related to electronically supplied services, telecommunications, broadcasting and television services provided to non-EU companies in EU Member States for which the Mini-One-Stop-Shop (MOSS) is used.
Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organisation, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services.
We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, organisers and other business partners on the basis of our business interests, eg for the purpose of contacting you later. We generally store this majority of company-related data permanently.
Business analysis and market research
In order to operate our business economically, to be able to recognise market tendencies, wishes of the contractors and users, we analyse the data available to us for business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata on the basis of Art 6 para. 1 lit. f. DSGVO, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business analysis, marketing and market research. In doing so, we can take into account the profiles of the registered users with information, eg on their services used. The analyses serve us to increase the user-friendliness, the optimisation of our offer and the business economy. The analyses are for us alone and will not be disclosed externally unless they are anonymous, aggregated value analyses.
If these analyses or profiles are personal, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analyses and general trend provisions are created anonymously if possible.
We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfil our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO insofar as the processing of data is necessary for us eg in the context of legal procedures (in Germany additionally § 26 BDSG applies).
The application process requires applicants to provide us with the applicant data. The necessary applicant data are, as far as we offer an online form marked, otherwise result from the job descriptions and basically include the information on the person, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and the certificates. In addition, applicants can voluntarily provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b DSGVO (eg health data, such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (eg health data, if necessary for the profession).
If provided, applicants can submit their applications via our online form on our website. The data will be encrypted and transmitted to us according to the state of the art.
Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent encrypted and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Because instead of applying via the online form and e-mail, applicants still have the opportunity to send us the application by post.
The data provided by the applicants may be further processed by us in the event of a successful application for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time.
The cancellation is subject to a legitimate withdrawal of the candidates, after the expiration of a period of six months, so that we can answer any follow-up questions to the application and meet our proof obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.
Users can create a user account. As part of the registration, the required mandatory information is communicated to the users and based on Art. 6 para. 1 lit. b DSGVO processed for purposes of providing the user account. The processed data include in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.
Users may be informed by e-mail about information relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with respect to the user account, subject to a statutory retention requirement. It is the responsibility of the users to secure their data upon termination prior to the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
In the context of the use of our registration and registration functions as well as the use of the user account, the IP address and the time of the respective user action will be saved. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorised use. A transfer of these data to third parties does not take place, unless it is necessary for the pursuit of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO. The IP addresses will be anonymised or deleted after 7 days at the latest.
When contacting us (eg by contact form, e-mail, telephone or via social media), the information provided by the user to process the contact request and its processing acc. Art. 6 para. 1 lit. b) DSGVO processed. User information can be stored in a Customer Relationship Management System (“CRM System”) or comparable request organisation.
We delete the requests, if they are no longer required. We check the requirement every two years; Furthermore, the legal archiving obligations apply.
Hosting and e-mailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mail delivery, security and technical maintenance services we use to operate this online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of contract processing contract).
Collection of access data and log files
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on every access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider ,
Logfile information is stored for security reasons (eg to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes are excluded from the erasure until the final clarification of the incident.
Google AdWords and conversion measurement
We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (ie interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 (1) lit. DSGVO) , USA, (“Google”).
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use Google’s online AdWords marketing tool “AdWords” to place ads on the Google advertising network (eg, in search results, in videos, on websites, etc.) to show them to users who have a suspected interest in the ads. This allows us to better target advertisements for and within our online offering so that we only present ads to users that potentially match their interests. For example, if a user sees ads for products he’s been looking for on other online offerings, that’s called re-marketing. For these purposes, when we visit our and other websites where the Google Advertising Network is active, Google will immediately execute Google code and become so-called (re) marketing tags (invisible graphics or code, also referred to as “web beacons”) incorporated into the website. With their help, the user’s device stores an individual cookie, ie a small file (instead of cookies, comparable technologies can also be used). In this file is noted which web pages the user visited, for what content he is interested and what offers the user has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer.
Furthermore, we receive an individual “conversion cookie”. The information obtained through the cookie is used by Google to generate conversion statistics for us. However, we only hear about the anonymous total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive information that personally identifies users.
The data of the users are pseudonym processed in the context of the Google advertising network. For example, Google does not store and process users’ names or e-mail addresses, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. That is, from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.
Online presence in social media
We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
Integration of services and contents of third parties
Based on our legitimate interests (ie interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services Integrate services such as videos or fonts (collectively referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavour to use only content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate 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, among other things, technical information about the browser and operating system.
Use of Facebook social plugins
On the basis of our legitimate interests (ie interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO) we use social plugins (“plugins”) of the social network facebook.com, which operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). The plugins can represent interaction elements or content (eg videos, graphics or text contributions) and can be recognised by one of the Facebook logos (white “f” on blue tile, the terms “Like”, “Like” or a “thumbs up” sign ) or are marked with the addition “Facebook Social Plugin”. The list and the look of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ .
Facebook is certified under the Privacy Shield Agreement, providing a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ).
When a user invokes a feature of this online offering that includes such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the device of the user and incorporated by him into the online offer. In the process, user profiles of the processed data can be created. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore informs users according to our level of knowledge.
By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example, press the Like button or leave a comment, the information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address. According to Facebook, only an anonymous IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his member data stored on Facebook, he must log out of Facebook and delete his cookies before using our online offer. Other settings and inconsistencies regarding the use of data for promotional purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US-American site http://www.aboutads.info / choices / or the EU page http://www.youronlinechoices.com/ . The settings are platform-independent, ie they are adopted for all devices, such as desktop computers or mobile devices.