Privacy Policy

 

updated 23/06/2022

1. Introduction

The following information provides an overview on how we
process your personal data and your rights according to data protection regulations. In this regard, it is important that you only submit information to us that is required to enter into or perform a business relationship, or required for a service, provided we are not obligated to process your data for legal reasons. All other data is disclosed on a voluntary basis.

If you have any questions on the topic of data protection, or if you would like to lodge a complaint or exercise your rights, please contact us at the following contact details, which you can also use to contact the data controller. We shall address your concern as quickly as possible.

You can reach our Data Protection Officer by contacting:

ada Learning GmbH
- Data Protection Officer -
c/o 3rd Room
Leopoldstraße 26
40211 Düsseldorf

Germany
Email: privacy@join-ada.com

We process your personal data to varying extents as required, for instance, when

  • you visit our website
  • you contact us via another channel (e.g. via a contact form)
  • you register for one of our services, e.g. our newsletter
  • you book a ticket for one of our events
  • you conclude a magazine subscription with us, or
  • you participate in our fellowship program


A number of our services can only be offered once we have obtained your prior consent. In certain cases, we shall receive your data within the scope of a contract. For other processing operations, we process your data on the basis of our legitimate interest (as per the GDPR), as in the respective case we are unable to ask for your consent in advance, for instance, when you visit our website. In this case, data is automatically collected and processed when you access our website. As we intend to explain all processing in as much detail and as transparently as possible in the following, this policy is rather long, but hopefully easy to understand. If you struggle to understand any of the information, please contact us at (privacy@join-ada.com).

2. Data processing performed by us and your rights

2.1 Visits to our website

When you visit our website, we collect data on your access to our server (server log files) on the basis of our legitimate interest as per Art. 6, para. 1, sentence 1, lit. f GDPR. Data processed upon access includes the date, time, transferred data volume, browser type and version, the referrer URL (the website you were previously on), your IP address, the requesting provider and your operating system. We store the log files for security reasons (e.g. for clarification in the case of misuse) for a maximum of 7 days, provided we are not required to collect any evidence.

Furthermore, we also use cookies on our website. Cookies are small text files that are automatically generated by your browser and stored on your device (laptop, table, smartphone, etc.) when you visit our website(s). Cookies do not incur any damage on your device and do not contain any viruses, trojans or other malware. Information generated in relation with the specific device is stored in the cookie. However, this does not entail that we receive direct knowledge of your identity. There are several types of cookies.

  • Technically required cookies: These are cookies that we are required to set in order to provide our website or to facilitate use of our website (session cookies). These cookies are automatically set, irrespective of user consent, on the basis of our legitimate interest as per 6, para. 1, lit. f GDPR.
    Cookies that we only set with your consent as per 6, para. 1, lit. a GDPR. These cookies serve a variety of purposes, for instanceCookies for statistical purposes such as reach measurement
  • Marketing cookies that we use to analysis information on a website visit in order to send you suitable ads and also to make visiting our website easier for you, as you are consequently not required to load certain content anew each time your visit our website (first-party cookies)
    If you landed on this page from our “cookie consent” bar,  you will have already obtained an overview of our cookie policy and your options. However, this information can also be found at the end of this privacy policy.


You can revoke your consent at any time. Any changes to your settings may affect the functionality of certain services on our website.

2.2 Contacting us

We would be glad to establish communication with you. If you would like us to call you or send an email, we shall process the data that you have submitted to us for this purpose on the basis of your consent as per Art. 6, para. 1, lit. f GDPR. We shall delete this information once we have processed your matter.

2.3 Participation in or use of journalistic formats (e.g. events, magazine subscriptions)

You are required to register with us in order to purchase a magazine subscription or event ticket from us. In this regard, we shall store

  • Your name and email address, incl. postal address and phone number if required
  • The usage data for a visit to our website (visited websites, interests, access times)
  • Communication data (IP addresses, device information)
  • Payment information
  • For events, we also store content related to your person that we recorded during the event (such as photos, audio and video files for documenting the event)


This data is stored on the basis of the contract concluded with you as per Art. 6, para. 1, lit. b GDPR, your consent as per Art. 6, para. 1, lit. a GDPR, and on the basis of our legitimate interest as per Art. 6, para. 1, lit f GDPR. You can revoke your consent at any time in whole or in part; however, it may be the case that we are consequently unable to render the services or fulfil our contract with you.

With regard to events held in times of special health caution, we process your personal data, in particular your name and contact details, within the scope of the applicable recording and reporting obligations in connection with the measures to control the SARS-CoV-2 virus. We only disclose personal data to the responsible authorities if and to the extent that we are legally obliged to do so. In this respect, the processing is based on Art. 6, para. 1, lit. c DSGVO.

In all other cases, based on ​​§22 para. 1 (c) BDSG, we still want to run quick checks of your test, vaccination or recovery certificates. As stipulated in Art. 5 GDPR, we will ensure that: no data will be stored through us, meaning test, vaccination or recovery status will only be checked at the doors, but not recorded. Also data will only be checked via established technical tools, such as QR code scanning via apps.

If you no longer make use of our services after the expiration of the contract, we shall delete your data. However, this shall not apply to data that we are required to store as per statutory retention obligations, such as invoicing documents. We shall store these documents for the legally prescribed duration.

2.4 Participation in the fellowship program

All participants in our fellowship program must register with us. In this regard, we shall store

  • Your name, address, email address, phone number and your employer
  • The usage data for your visit to our website (visited websites, interests, access times)
  • Communication data (IP addresses, device information)
  • Content related to your person that you disclose to us during the program (such as audio files, photos, direct quotes, text)


This data is stored on the basis of the contract concluded with your employer as per Art. 6, para. 1, lit. b GDPR, your consent as per Art. 6, para. 1, lit. a GDPR, and on the basis of our legitimate interest as per Art. 6, para. 1, lit f GDPR. You can revoke your consent at any time in whole or in part; however, it may be the case that we are consequently unable to render the ada fellowship services or fulfil our contract with your employer.

If you no longer make use of our services after the expiration of the contract, we shall delete your data as soon as we have concluded the contractual services in full with your employer. However, this shall not apply to data that we are required to store as per statutory retention obligations, such as invoicing documents. We shall store these documents for the legally prescribed duration.

2.5 ada services (e.g. the newsletter)

We provide a number of free services, such as our weekly newsletter. For the provision thereof, we process the following information

  • Your name and email address
  • The usage data for a visit to our website (visited websites, interests, access times)
  • Communication data (IP addresses, device information)

We store this data on the basis of your consent as per Art. 6, para. 1, lit. a GDPR. You can revoke this consent at any time via customerservice@join-ada.com. If you revoke your consent, we will no longer be able to provide these services.

3. Data transfers

We shall not disclose your personal data to third parties for their own purposes without your consent. If this is required as a one-off for individual services, we shall separately inform you thereof in advance and inform you of the purpose of processing and the cooperation partner.

Moreover, if any data is processed by third parties, this takes place on our account. Third parties in this regard include, for example:

  • Our data centre
  • Media technology
  • Printers and shipping companies
  • Survey software


We have concluded a job processing contract with each of these service providers and specified that data must be processed with the same level of security that we protect your data with. Furthermore, we also have the right to supervise and issue instructions.

4. Your rights

When you access our website, you will be informed about the use of cookies for analytical purposes. At this point, your consent to the processing of your personal data for this purpose shall be obtained. You shall also be informed of this privacy policy.

Under certain conditions, you reserve the right to assert the following data protection rights against us by contacting us at the contact details specified in Section 1:

  • You are entitled to revoke your consent to processing performed by us at any time. Following this revocation, we shall no longer be entitled for process your data on the basis of this consent;
  • Upon your request, we shall provide information on your personal data processed by us, provided this right to information is not restricted by statutory limitations;
  • Upon your request, we shall rectify or complete any of your personal data that we have stored if it is deemed incorrect or inaccurate;
  • Upon your request, we shall delete your data, provided continued storage thereof is not required by statutory regulations (such as statutory retention obligations). However, this shall not apply if the deletion of your data impinges upon our overriding interests (e.g. to defend our rights and claims);
  • You reserve the right to demand that we restrict the processing of your data, e.g. if we no longer require it for a service;
  • Upon your request, we shall provide you or a third party with all data disclosed on the basis of your consent or a contract in a structured, conventional and machine-readable format;
  • You reserve the right to object to the processing of your data. In this case, we shall stop processing your data. However, this objection shall only apply if you are able to present exceptional personal circumstances and provided the objection does not impinge on our rights;
  • Finally, you are also entitled to lodge a complaint with the competent data supervisory office for our domicile. At present, this is the State Data Protection and Freedom-of-Information Officer for North Rhine-Westphalia, ldi.nrw.de. However, we would appreciate it if you were to first contact us regarding your concern.


 5. Location of data processing

As a rule, we process your data in Germany or in a member state of the European Union. Data transfers to locations in states outside the European Union (EU) or the European Economic Area (EEA) (third countries) shall only occur if this is required for the fulfilment of a contract or to render one of our services for which you have granted us your consent, or for job processing that takes place abroad. If the country in question is not a signatory to an adequacy decision from the EU commission on the adequate level of data protection in the country, as per the EU data protection guidelines, we shall ensure that your rights and liberties are adequately protected and guaranteed through the conclusion of corresponding contracts.

Please contact us to receive information on the suitable or adequate guarantees and to receive a copy thereof from us.

6. Web analysis and content delivery services

6.1 Google Analytics

If you have provided your voluntary consent that can be revoked at any time, we shall use Google Analytics on our website, a web analysis service provided by Google Ireland Limited, Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland (“Google”) together with the US parent company Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, in order to analyse your use of this website and improve our website. The obtained statistics help us to improve our website and make it more appealing to you as a user. In exceptional cases, your personal data may also be transferred to the USA and stored there in this regard. The level of data protection in the USA does not conform entirely to the level of data protection guaranteed in the EU, according to the understanding of the European Court of Justice. As such, the USA is not subject to an adequacy decision from the European Commission or suitable guarantees. In particular, in this regard, there is the risk, or it cannot be excluded, that the state authorities – only in the case of limited legal remedies – may obtain access to your data within the framework of the valid laws of the USA. Google has concluded a data protection agreement with the inclusion of the EU standard contractual clauses with Google LLC. More information from Google can be found at: https://privacy.google.com/businesses/compliance/#!#gdpr

We use the services provided by Google Analytics on this website on the basis of your consent as per Art. 6, para. 1, sentence 1, lit. a GDPR.

Google Analytics uses cookies, which are small text files that are saved on your computer and facilitate the analysis of your use of the website. Information generated by the cookie on your use of this website is generally sent to a Google server located in the USA and stored there.

If IP anonymisation has been activated on this website, your IP address shall be truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area beforehand. Only in exceptional cases will your full IP address be sent to a Google server located in the USA and truncated there. You can find our the location of Google data centers at: https://www.google.com/about/datacenters/ Google uses this information on our behalf to analyse your use of the website, to prepare reports on website activity and to perform other services for the website operator related to the use of the website and internet. The IP address disclosed by your browser within the scope of Google Analytics services shall not be merged with any other data from Google, provided you have not otherwise consented thereto in your Google account.

You reserve the right to revoke or amend consent that you have previously granted us at any time with future effect in order to prevent the storage of cookies through your browser settings. We would like to point out that in this case, you will not be able to use all features of this website to the full extent.In order to revoke or amend your consent, you can change the settings in the cookie notice. You also have the option to opt-out entirely there.All personal or pseudonymised data is deleted or anonymised after 14 months.

Please find more details and information in Google’s data protection statement at https://support.google.com/analytics/answer/6004245?hl=en, in Google’s privacy policy at https://policies.google.com/privacy?hl=en and in your Google ad settings at adssettings.google.com/authenticated..    

6.2 Other systems

We use third-party content and services on our website on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our website as per Art. 6, para. 1, sentence 1, lit. f GDPR), such as the embedding of video content or fonts (hereinafter jointly referred to as “Content”). As a prerequisite, the third-party providers of this content require the user’s IP address, without which they are unable to send the content to their browsers. Accordingly, your IP address is required to display this content. We undertake to only use content whereby the respective provider only uses your IP address for the purpose of delivering the content. Furthermore, third-party providers may use pixel tags (invisible graphics, also referred to as web beacons) for statistical or marketing purposes. Pixel tags facilitate the analysis of information on visitor traffic to the various pages of this website. The pseudonymised information may also be stored in cookies on the user's device and, amongst other information, receive technical information such as the browser and operating system, referrer websites, time of visit and other information on the use of our website, and be linked with the same information from other sources.

In the following, we provide an overview of third-party providers and content, including links to the respective privacy policies that contain further information on the processing of data and your options to object (opt out), as partially explained above:

  • Our website may include features provided by the service and platform Twitter (hereinafter referred to as “Twitter”). Twitter is a service provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. These features include the display of our Twitter posts on our website, links to our Twitter profile and the option to interact with the Twitter posts and features. Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.
  • External code for the jQuery JavaScript library , provided by the third-party provider jQuery Foundation, https://jquery.org.
  • Videos/livestreams from the platform “YouTube” provided by the third-party provider Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Privacy policy: https://policies.google.com/privacy, Opt-out: https://adssettings.google.com/authenticated. Privacy-enhanced mode is used for the integration of YouTube videos, which first places a cookie on the user's device when the user plays the respective YouTube video. YouTube states that no personal cookie data is stored when embedded videos are played in privacy-enhanced mode. Read more about data processing and find out information on data protection in place at YouTube (Google) at the following link: google.com/intl/en/policies/privacy/.
  • Maps from the service “Google Maps” provided by the third-party provider Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland are incorporated on this website. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://www.google.com/settings/ads/.
  • We use the platform Brightcove on our website, Brightcove Inc.; 290 Congress Street, Boston, MA 02210, privacy@brightcove.com; +1 617 500 4947, in order to integrate videos and analyse the use thereof. Learn more about Brightcove Player at the following link: https://www.brightcove.com/en/legal/services-privacy-policy.
  • We use the presentation software Prezi and the data visualisation software Infogram, Prezi Inc., 450 Bryant Street, San Francisco, CA 94107 in order to provide content on the ada fellowship and analyse the use thereof (number of views and location of viewers). Learn more about Prezi and Infogram at: https://prezi.com/privacy-policy/201910_NL/ and https://infogram.com/privacy.
  • We use the platform Podigee, Podigee GmbH, Schlesische Straße 20, 10997 Berlin, on our website as a hosting provider in order to integrate podcasts and analyse the use thereof. Learn more about Podigee Web Player at: https://www.podigee.com/de/podcast-player

7. Cookies

Statistic

 
Name  Provider Purpose Expiration Type
collect Google This cookie is used to send Google Analytics information on the user's device and surfing behaviour. It captures information on the visitor across devices and marketing devices. Session Pixel Tracker