Directors Academy – Privacy Policy

1. COLLECTION, PROCESSING AND USE OF PERSONAL DATA

1.1 General information
Personal data is any information relating to an identified or identifiable natural person (e.g. name, address, telephone number, date of birth, e-mail address).

1.2 Registration
If you wish to make use of services that require a contract to be concluded, we will ask you to register. Within the scope of registration, we collect the personal data required for the conclusion and fulfilment of the contract. The information marked with an asterisk is mandatory, which we absolutely need.

1.3 Processing purposes
We process your personal data for the following purposes:
– Conclusion of contract
– contract performance including invoicing
– Sending an e-mail newsletter.

1.4 Transfer of data to third parties and service providers
Your personal data will only be passed on by us to third parties if this is necessary for the fulfilment of the contract or if we have your consent.

In addition, data may be transferred to third parties if we are obliged to do so by law or by enforceable official or court order.

We reserve the right to use service providers for the collection and processing of data. These are integrated as so-called commissioned data processors, who may only process personal data in accordance with our instructions. Service providers only receive the personal data from us that they need for their specific activities. For example, your e-mail address may be passed on to a service provider so that they can send you a newsletter you have ordered. Service providers may also be commissioned to provide server capacity.

1.5 Duration of storage
We store your data for as long as this is necessary to fulfil the contract or other services (e.g. newsletter). Otherwise, we delete your personal data, unless we need to keep them for the fulfilment of contractual or legal (e.g. tax or commercial law) retention periods. Data that are subject to a retention period will be blocked until the expiry of the period.

2. DISCLOSURE OF DATA TO CREDIT INSTITUTIONS AND PAYMENT SERVICE PROVIDERS

We use external payment service providers. Depending on which payment method you select in the order process, we will pass on the data collected for the processing of payments (e.g. bank details or credit card data) to the bank or payment service provider commissioned by us. In some cases, the payment service providers also collect this data on their own responsibility. In this respect the data protection declaration of the respective payment service provider applies.

We reserve the right to have receivables collected by service providers who collect them as so-called order data processors.

3. LOG FILES

Every time you use the Internet, your Internet browser automatically transmits certain information and we store it in so-called log files.

The log files are stored by us for one week solely for the purpose of detecting malfunctions and are deleted afterwards. Log files, whose further storage is required for evidence purposes, are excluded from deletion until the incident has been finally clarified and will also be passed on to investigating authorities if necessary.

The following information in particular is stored in the log files:
IP address (Internet Protocol address) of the terminal device from which our online offer was accessed;
– Internet address of the website from which the online offer was accessed (so-called origin or referrer URL);
– Name of the service provider via which the online service was accessed;
– Name of the files or information retrieved;
– date and time as well as duration of the access;
– transferred data volume;
– Operating system and information on the Internet browser used, including installed add-ons (e.g. for the Flash Player);
– http status code (e.g. “request successful” or “requested file not found”).

The legal basis for this data processing is Art. 6 para. 1 sentence 1 lit. f. DSGVO. Our legitimate interest is to ensure a smooth connection and comfortable use of the website.

 

4. COOKIES

After the user logs in, so-called “cookies” are stored on the user’s computer. A cookie is a small text file in a designated file directory of the computer. If the corresponding website is called up again, the user’s browser sends the contents of the cookie back and thus enables the user to be recognised again.

Some cookies are automatically deleted at the end of the browser session, others are stored on the user’s computer for a certain period of time and then delete themselves automatically. You can delete stored cookies at any time in your browser.

In principle, no personal data is stored in cookies, only an online identification.

Certain cookies are required in order for us to provide our online services securely. In addition, we use analysis cookies to record and statistically evaluate usage behaviour. We also use cookies for advertising purposes. We use the profiles created with the help of these cookies to show you advertising and offers that are tailored to your interests. For the reasons stated above, we are entitled to process data using cookies in accordance with Art. 6 Para. 1 S. 1 lit. f DSGVO.

5. WEB ANALYSIS

We need statistical information about the use of our online offer in order to make it more user-friendly, to carry out coverage measurements and to conduct market research.

For this purpose, we use web analysis tools on the basis of Art. 6 para. 1 sentence 1 lit. f DSGVO. The usage profiles created by the tools using analysis cookies or by evaluating log files are not combined with personal data.

The providers of the tools process data only as commissioned data processors in accordance with our instructions and not for their own purposes. The tools either do not use IP addresses of users at all or shorten them immediately after collection.

The tools are the following:
Google Analytics
We use Google Analytics, a web analysis service of Google Inc. (“Google”). Google uses cookies. The information generated by the cookie about the use of the website by the user is usually transferred to a Google server in the USA and stored there.
Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with further services associated with the use of this website and the Internet. The processed data can be used to create pseudonymous user profiles of the users.

We only use Google Analytics with activated IP anonymisation. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there. The IP address transmitted by the user’s browser is not merged with other Google data.

Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on Google’s use of data for advertising purposes, setting and objection options can be found on Google’s websites: https://www.google.com/intl/de/policies/privacy/partners/ (“Google’s use of data when you use our partners’ websites or apps”), http://www.google.com/policies/technologies/ads (“Use of data for advertising purposes”), http://www.google.de/settings/ads (“Manage information that Google uses to show you advertising”) and http://www.google.com/ads/preferences/ (“Determine which advertising Google shows you”).

Note on Google Analytics according to the model of lawyer Dr. Thomas Schwenke

At the following web addresses you will find more detailed information about the respective provider of the web analysis tools and how you can object to the collection of data by the respective tool:
Further information on Google’s use of data for advertising purposes, setting and objection options can be found on Google’s websites: https://www.google.com/intl/de/policies/privacy/partners/ (“Google’s use of data when you use our partners’ websites or apps”), http://www.google.com/policies/technologies/ads (“Use of data for advertising purposes”), http://www.google.de/settings/ads (“Manage information that Google uses to show you advertising”) and http://www.google.com/ads/preferences/ (“Determine which advertising Google shows you”).

Note on Google Analytics according to the model of lawyer Dr. Thomas Schwenke

 

6. NEWSLETTER

We offer you the possibility to subscribe to a newsletter. You can revoke your consent at any time. Please use the unsubscribe link at the end of the newsletter or contact us via our e-mail address.

Notes on the newsletter and consent
With the following information, we would like to inform you about the contents of our Directors Academy newsletter, as well as the registration, mailing and statistical evaluation procedures and your right to object. By subscribing to our newsletter, you agree to receive it and to the described procedures.

Content of the newsletter
We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletters”) only with the consent of the recipients or a legal permission.

Double-Opt-In and Logging
The registration to our newsletter is done in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses.

The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the time of registration and confirmation as well as the IP address. Changes to your data stored with MailChimp are also logged.

Use of the dispatch service provider “MailChimp
The newsletters are 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.

The e-mail addresses of our newsletter recipients, as well as their other data described in this notice, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. Furthermore MailChimp may use this data according to its own information to optimize or improve its own services, e.g. for technical optimization of sending and presentation of the newsletters or for economic purposes to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them or pass them on to third parties.

We trust in the reliability and the IT and data security of MailChimp. MailChimp is certified under the US-EU data protection agreement “Privacy Shield” and is committed to comply with the EU data protection regulations. Furthermore, we have concluded a “Data-Processing-Agreement” with MailChimp. This is a contract in which MailChimp undertakes to protect the data of our users, to process it on our behalf according to its data protection regulations and in particular not to pass it on to third parties. The privacy policy of MailChimp can be viewed here.

Registration data
To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally we ask you to enter your first and last name and the form of address. This information is only used to personalize the newsletter.

Statistical survey and analyses
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file which is retrieved from the server of MailChimp when the newsletter is opened. In the context of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined by means of the IP address) or the access times.

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 ambition nor that of MailChimp to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.

Online access and data management
There are cases where we direct the newsletter recipients to the websites of MailChimp. E.g. our newsletters contain a link with which the newsletter recipients can retrieve the newsletters online (e.g. in case of display problems in the e-mail program). Furthermore newsletter recipients can correct their data, e.g. the e-mail address, afterwards. Likewise the privacy policy of MailChimp is only available on their site.

In this context we would like to point out that on the websites of MailChimp cookies are used and therefore personal data is processed by MailChimp, its partners and service providers (e.g. Google Analytics). We have no influence on this data collection. Further information can be found in the privacy policy of MailChimp. We would also like to draw your attention to the possibility to object to the collection of data for advertising purposes on the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European area).

Cancellation/Revocation
You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. Your consent to receive the newsletter via MailChimp and the statistical analyses will expire at the same time. A separate cancellation of the dispatch via MailChimp or the statistical analysis is unfortunately not possible.

You will find a link to cancel the newsletter at the end of each newsletter.

Legal basis Basic data protection regulation
In accordance with the provisions of the Basic Data Protection Regulation (DSGVO), which will apply from 25 May 2018, we hereby inform you that consent to the sending of e-mail addresses is given on the basis of Art. 6 Para. 1 lit. a, 7 DSGVO and § 7 Para. 2 No. 3, or Para. 3 UWG. The use of the mail service provider MailChimp, the execution of statistical surveys and analyses as well as the logging of the registration procedure are based on our legitimate interests according to art. 6 para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.

We would also like to point out that you can object to the future processing of your personal data in accordance with the legal requirements pursuant to Art. 21DSGVO at any time. The objection can be made in particular against processing for the purposes of direct advertising.

“Note on the newsletter according to the sample of lawyer Dr. Thomas Schwenke”.

 

 

7. RESPONSIBLE AUTHORITY

Directors Academy GmbH is the body responsible for data processing.
You can reach us as follows:

Directors Academy GmbH
Lilienstraße 11
20095 Hamburg

Phone: +49 174 695 62 82
e-mail: office@directors-academy.com