Privacy Policy

We are very pleased about your interest in our company. The management of Allgeier Education GmbH attaches particular importance to data protection. The Allgeier Education GmbH website can generally be used without providing any personal data. However, if a person concerned wishes to make use of special services offered by our company via our website, it may become necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we generally obtain the consent of the person concerned.

The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the basic data protection regulation and in compliance with the country-specific data protection regulations applicable to Allgeier Education GmbH. By means of this data protection declaration, our company wishes to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. In addition, this data protection declaration informs affected persons about their rights.

As the person responsible for processing, Allgeier Education GmbH has implemented numerous technical and organisational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, such as by telephone.

1. Definitions

The data protection declaration of Allgeier Education GmbH is based on the terms used by the European legislator for directives and regulations when the basic data protection regulation (DS-GVO) was issued. Our data protection declaration should be easy to read and understand, both for the public and for our clients and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms, among others, in this privacy policy:

(a) personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, on-line identification, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

(b) the person concerned

Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

(c) Processing

Processing is any operation or set of operations, performed with or without the aid of automated means, which is performed upon personal data, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

(d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

(e) Profiling

Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, conduct, location or change of location of that natural person.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the need for additional information, provided that this additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data is not attributed to an identified or identifiable natural person.

(g) controller or controller responsible for processing

Controller or data controller is the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or National law, provision may be made for the controller or for the specific criteria for his or her designation in accordance with Union or National law.

(h) Contract processors

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

(i) Consignee

The recipient is any natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not that person is a third party. However, authorities which may receive personal data in the context of a specific investigation mandate under Union or National law shall not be considered as recipients.

j)      Third party

Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.

(k) Consent

Consent shall mean any freely given and informed unequivocal expression of the data subject’s wishes in the specific case, in the form of a statement or any other unequivocal affirmative act by which the data subject signifies his or her consent to the processing of personal data relating to him or her.

2. Name and address of the controller

The person responsible within the meaning of the basic data protection regulation, other data protection laws applicable in the member states of the European Union and other regulations of a data protection nature is the:

Allgeier Education GmbH
Kaiserswertherstr. 229
40474 Düsseldorf
Germany

Phone: +49 211 54 5563-55
e-mail: datenschutz@allgeier-education.com
Website: www.allgeier-education.com

3. Name and address of the Data Protection Officer

The Data Protection Officer of the controller is
Dr. Ivo Großner
Allgeier SE
Einsteinstr. 172
81677 Munich
Germany

Phone: +49 89 99 84 21 44
E-mail: igrossner@allgeier.com
Website: www.allgeier.com

Every person concerned can contact our data protection officer directly at any time with all questions and suggestions regarding data protection.

4. Cookies

The Allgeier Education GmbH website uses cookies. Cookies are text files that are stored on a computer system via an Internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters which can be used to assign Internet pages and servers to the specific Internet browser in which the cookie was stored. This enables the Internet pages and servers visited to distinguish the individual browser of the person concerned from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified by means of the unique cookie ID.

By using cookies, Allgeier Education GmbH can provide users of this website with more user-friendly services that would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimised in the interest of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter his or her access data each time he or she visits the website, because this is done by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in the online shop. The online shop uses a cookie to remember the articles that a customer has placed in the virtual shopping cart.

The person concerned can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the person concerned deactivates the setting of cookies in the Internet browser used, it is possible that not all functions of our website can be fully used.

5. Collection of general data and information

The Allgeier Education GmbH website collects a series of general data and information every time a person or automated system accesses the website. These general data and information are stored in the server’s log files. The following can be recorded: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of an access to the Internet site, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information which serve to avert danger in the event of attacks on our information technology systems.

When using this general data and information, Allgeier Education GmbH does not draw any conclusions about the person concerned. In fact, this information is required in order to (1) deliver the contents of our website correctly, (2) optimise the contents of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. These anonymously collected data and information are therefore statistically evaluated by Allgeier Education GmbH on the one hand and also with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a person concerned.

6. Routine deletion and blocking of personal data

The controller shall process and store personal data relating to the data subject only for the period of time necessary to achieve the purpose of storage or where provided for by the European legislator or other legislator in laws or regulations to which the controller is subject.

If the purpose of storage ceases to apply or if a storage period prescribed by the European Directive and Regulation Provider or another competent legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.

7. Rights of the data subject

(a) Right to confirmation

Every data subject has the right, granted by the European Directive and Regulation, to obtain from the controller confirmation as to whether personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact an employee of the controller.

(b) Right of information

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain at any time and free of charge from the data controller information on personal data relating to him/her and a copy thereof. The European Data Protection Supervisor has also granted the data subject access to the following information:

• the processing purposes

• the categories of personal data processed

• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or international organisations

• if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration

• the existence of a right of rectification or erasure of personal data relating to him or her, or of a restriction on processing by the controller or a right to object to such processing

• the existence of a right of appeal to a supervisory authority

• if the personal data are not collected from the data subject: All available information on the origin of the data

• the existence of automated decision-making, including profiling, in accordance with article 22(1) and (4) of the DPA and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject

The data subject shall also have the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, he or she may at any time contact an employee of the controller.

(c) Right of rectification

Any person affected by the processing of personal data has the right, granted by the European legislator, to request the rectification without delay of inaccurate personal data concerning him. The data subject shall also have the right to obtain the completion of incomplete personal data, including by means of a supplementary declaration, having regard to the purposes of the processing.

If a data subject wishes to exercise this right of rectification, he or she may at any time contact an employee of the controller.

(d) Right of cancellation (right to be forgotten)

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain from the controller the immediate erasure of personal data relating to him/her, if one of the following reasons applies and provided that the processing is not necessary:

• The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.

• The data subject withdraws his or her consent on which the processing was based pursuant to article 6(1)(a) DPA or article 9(2)(a) DPA and there is no other legal basis for the processing.

• The data subject lodges an objection to the processing pursuant to article 21(1) of the DPA and there are no overriding legitimate reasons for processing, or the data subject lodges an objection to the processing pursuant to article 21(2) of the DPA.

• The personal data were processed unlawfully.

• The deletion of personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.

• The personal data were collected in relation to information society services offered in accordance with article 8(1) of the DS-GVO.

If one of the above reasons applies and a data subject wishes to request the deletion of personal data stored by Allgeier Education GmbH, he/she can contact an employee of the data controller at any time. The employee of Allgeier Education GmbH will ensure that the request for deletion is complied with immediately.

If the personal data has been made public by Allgeier Education GmbH and our company, as the responsible party, is obliged to delete the personal data in accordance with art. 17 para. 1 DS-GVO, Allgeier Education GmbH will take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data that the data subject has requested that these other data controllers delete all links to these personal data or copies or replications of these personal data, unless the processing is necessary. The employee of Allgeier Education GmbH will make the necessary arrangements in individual cases.

e) Right to restrict processing

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain from the controller the restriction of processing if one of the following conditions is met:

The accuracy of the personal data is contested by the data subject, for a period of time that allows the controller to verify the accuracy of the personal data.

The processing is unlawful, the data subject refuses to have the personal data deleted and instead requests that the use of the personal data be restricted.

The controller no longer needs the personal data for the purposes of the processing, but the data subject needs them for the purpose of asserting, exercising or defending legal claims.

The data subject has lodged an objection to the processing pursuant to article 21 (1) of the DPA and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.

If one of the above-mentioned conditions is met and a data subject wishes to request the restriction of personal data stored by Allgeier Education GmbH, he/she can contact an employee of the data controller at any time. The employee of Allgeier Education GmbH will arrange for the restriction of the processing.

(f) Right to data portability

Any person affected by the processing of personal data has the right, granted by the European Directive and Regulation Provider, to receive the personal data concerning him/her, which have been provided by the data subject to a controller, in a structured, common and machine-readable format. He or she also has the right to have this data communicated to another controller without hindrance by the controller to whom the personal data has been made available, provided that the processing is based on the consent pursuant to article 6 paragraph 1 letter a DPA or article 9 paragraph 2 letter a DPA or on a contract pursuant to article 6 paragraph 1 letter b DPA and that the processing is carried out by means of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising their right to data transfer, the data subject has the right, in accordance with article 20 paragraph 1 of the DPA, to obtain that personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and provided that it does not adversely affect the rights and freedoms of other persons.

In order to assert the right to data transferability, the person concerned can contact an employee of Allgeier Education GmbH at any time.

(g) Right of appeal

Every person concerned by the processing of personal data has the right, granted by the European legislator, to object at any time, for reasons arising from his or her particular situation, to the processing of personal data concerning him or her carried out pursuant to article 6(1)(e) or (f) of the DPA. This also applies to profiling based on these provisions.

In the event of an objection, Allgeier Education GmbH no longer processes the personal data, unless we can prove compelling reasons for processing worthy of protection that outweigh the interests, rights and freedoms of the person concerned, or the processing serves to assert, exercise or defend legal claims.

If Allgeier Education GmbH processes personal data in order to carry out direct advertising, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling, insofar as it is related to such direct mail. If the data subject objects to Allgeier Education GmbH processing for the purposes of direct advertising, Allgeier Education GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right to object, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her carried out at Allgeier Education GmbH for the purposes of scientific or historical research or for statistical purposes in accordance with article 89 (1) of the DPA, unless such processing is necessary for the performance of a task carried out in the public interest.

In order to exercise the right of objection, the person concerned may contact directly any employee of Allgeier Education GmbH or any other employee. The data subject is also free to exercise his/her right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.

(h) Automated case-by-case decisions including profiling

Every person concerned by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or significantly affects him/her in a similar way, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union or National legislation to which the controller is subject and such legislation provides for adequate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is taken with the explicit consent of the data subject.

If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) is made with the express consent of the data subject, Allgeier Education GmbH shall take reasonable measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which shall include at least the right to obtain the intervention of a person from the controller, to express his or her point of view and to challenge the decision.

If the data subject wishes to exercise rights relating to automated decisions, he or she may at any time contact a member of staff of the controller.

i) Right to revoke a data protection consent

Every person affected by the processing of personal data has the right, granted by the European Directive and Regulation Provider, to revoke his or her consent to the processing of personal data at any time.

If the data subject wishes to exercise his or her right to withdraw consent, he or she may at any time contact an employee of the controller.

8. Privacy policy on the use and application of Google Analytics (with anonymisation function)

The person responsible for processing has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the collection and evaluation of data on the behaviour of visitors to websites. Among other things, a web analysis service collects data on which website a person concerned came to a website from (so-called referrers), which sub-pages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is mainly used to optimise a website and to analyse the cost-benefit of internet advertising.

The operating company of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The data controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the data subject’s Internet connection is shortened by Google and made anonymous if our Internet pages are accessed from a member state of the European Union or from another state that is a party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is the analysis of visitor flows on our website. Among other things, Google uses the data and information obtained to evaluate the use of our website in order to compile online reports for us which show the activities on our website and to provide further services in connection with the use of our website.

Google Analytics places a cookie on the information technology system of the person concerned. What cookies are has already been explained above. By setting the cookie, Google is able to analyse the use of our website. Each time one of the individual pages of this website, which is operated by the data controller and on which a Google Analytics component has been integrated, is called up, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. Within the scope of this technical procedure, Google receives knowledge of personal data, such as the IP address of the person concerned, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements.

The cookie is used to store personal information, such as the time of access, the location from which an access originated and the frequency of visits to our website by the person concerned. Each time our website is visited, this personal data, including the IP address of the Internet connection used by the person concerned, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical process to third parties.

The person concerned can prevent the setting of cookies by our website, as already described above, at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the person concerned. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the opportunity to object to and prevent the collection of data generated by Google Analytics and relating to the use of this website and the processing of this data by Google. To do this, the person concerned must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as a contradiction. If the data subject’s information technology system is deleted, formatted or reinstalled at a later date, the data subject must reinstall the Browser Add-On in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the person concerned or another person within his or her sphere of control, the browser add-on may be reinstalled or reactivated.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link https://www.google.com/intl/de_de/analytics/.

9. Legal basis of the processing

Art. 6 I lit. a DS-GVO serves our company as a legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations necessary for the supply of goods or provision of other services or consideration, the processing is based on art. 6 I lit. b DS-GVO. The same applies to such processing operations which are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which makes it necessary to process personal data, for example to fulfil tax obligations, processing is based on art. 6 I lit. c DS-GVO. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our company were to be injured and his or her name, age, health insurance details or other vital information had to be disclosed to a doctor, hospital or other third party. In this case the processing would be based on art. 6 I lit. d DS-GVO. Finally, processing operations could be based on art. 6 I lit. f DS-GVO. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or of a third party, unless the interests, fundamental rights and freedoms of the data subject prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, there is a view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 DS-GVO).

10. legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on article 6 I lit. f DS-GVO, our legitimate interest is to carry out our business activities for the benefit of the well-being of all our employees and our shareholders.

11. Duration for which the personal data are stored

The criterion for the duration of storage of personal data is the respective legal retention period. After expiry of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfilment or initiation of the contract.

12. Legal or contractual provisions providing the personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of not providing the data

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a data subject provides us with personal data, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him/her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before the person concerned makes personal data available, the person concerned must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

13. Existence of an automated decision making process

As a responsible company, we avoid automatic decision making or profiling.

This sample data protection declaration was created by the data protection declaration generator of the DGD Deutsche Gesellschaft für Datenschutz GmbH, which conducts data protection audits, in cooperation with the media law firm WILDE BEUGER SOLMECKE.