Privacy Policy and Cookies Policy

This Privacy Policy satisfies the disclosure requirements according to Art. 12 ff. of the EU General Data Protection Regulation (“GDPR”) and provides a summary of the processing of your personally identifiable information (“personal data”, “personal information”) on this website.

1. Who is accountable for processing my personal data?

Bertelsmann SE & Co. KGaA
Carl-Bertelsmann-Straße 270
33311 Gütersloh
Telefon: +49 (0) 5241-80-0
Fax: +49 (0) 5241-80-62321
E-Mail: info@bertelsmann.de

is responsible for processing your data on this website (hereinafter referred to as “we”). We process personally identifiable information (“personal data”) in accordance with GDPR provisions and the German Federal Data Protection Act (BDSG).
You can contact our designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to: datenschutz@bertelsmann.de.

2. What data is collected?

When you visit our website, the data of the computer you use to access our website is automatically logged (“access data”). This access data includes server log files that generally consist of information pertaining to your web browser type and version, your operating system, your internet service provider (ISP), the date and time you used the website, the websites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information contained in the server log files is not personally identifiable. An IP address is personally identifiable when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.

Some features of our website require that you divulge personal information to us. In this case, the information provided by you is used to provide the service requested by you or process a matter submitted by you (e.g. search queries, entries made in forms or contracts, click data).

3. What cookies are used?

Cookies are used on our website. Cookies are small text files that are saved to your computer when visiting a website. The cookies that are saved can be attributed to the web browser used by you. When the website is visited again, the web browser returns the content of the cookies, thus enabling you, the user, to be recognized. Certain cookies are deleted when you log out or end the browser session (“transient cookies” or “session cookies”). Other cookies are saved for a specific period of time (“temporary cookies”) or indefinitely (“persistent cookies”). These cookies are automatically deleted when the defined period lapses. The privacy and security settings of your browser enable cookies to be deleted at any time and also enable you to configure the use of cookies in accordance with your preferences. However, you may not be able to use all the features of our website if you delete the cookies used by our website.
As a general principle, cookies enable online recognition without reference to a specific person. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies themselves. Here a distinction is made between cookies that are necessary for the provision of website features, and cookies that are required for other purposes, e.g. marketing reach measurement, web analysis and market research.

The cookies that are required for the provision of website features include the following in particular:

  • Cookies that are used to identify or authenticate the user;
  • Cookies used to temporarily store user input (e.g. the content of a shopping cart or online form);
  • Cookies used to store user preferences (e.g. search or language settings);
  • Cookies that store data to enable the trouble-free rendering of video or audio content.

Cookies that are needed for other purposes of the website include analytics cookies to record the usage behaviour of our users and evaluate it in the form of statistics (e.g. advertising banners clicked, sub-pages visited, search queries conducted).

4. What data is collected and for what purpose?

The purpose of data processing may be based on technical, contractual or statutory requirements or result from consent having been given by the user.
We use the data described in section 2 for the following purposes:

  • To provide website features and content and ensure technical security in troubleshooting technical issues and also to ensure that unauthorized persons do not gain access to our website systems;
  • To conduct marketing reach measurements and web analyses in order to make our website more efficient and interesting for you, and for market research purposes;
  • To ensure that the cookie settings selected by website visitors are taken into account;
  • For communication, completion of precontractual procedures, and customer care purposes

For information on other data processing purposes, please refer to the sections below of this Privacy Policy.

4.1 Provision of the website

4.1.1 Description and scope of data processing

In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see section 2). The content of the server log files is not merged with other data. We use the server log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper functioning of our website.

4.1.2 Purpose and legal basis of data processing

The legal basis for the creation of server log files follows from Art. 6(1)(f) GDPR. Our legitimate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.

4.1.3 Duration of storage or criteria applied in defining this period

When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless there is a denial of service or other attack.

4.1.4 Options for lodging an objection and having your data removed

You have the right to lodge an objection to the processing of your data contained in the server log files provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.

4.2 Contact form, email and telephone contact information

4.2.1 Description and scope of data processing

On our website you have the option of contacting us by way of a contact form, by email or by telephone using the designated email address and phone number. If you take advantage of this option, the information you enter in the contact form, your email address and/or your phone number are disclosed to us. Depending on the reason you are contacting us (questions about our products and services, pursuing your rights as a data subject, e.g. submitting a request for information) your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).

4.2.2 Purpose and legal basis of data processing

The legal basis for processing your contact details follows from Art. 6(1)(f) GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to enter into a contract with our company, the legal basis for processing your contact details follows from Art. 6(1)(b) GDPR.

4.2.3 Duration of storage or criteria applied in defining this period

Your contact details are deleted once your request has been processed and further communication has been discontinued. This does not apply if the purpose of your establishing contact with us is to conclude a contract or you wish to exercise your right as a data subject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled and statutory retention periods (currently 6 to 10 years) do not prevent this information from being deleted.

4.2.4 Options for lodging an objection and having your data removed

You have the right to lodge an objection to the processing of your contact information provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for completing precontractual procedures, fulfilling a contract or exercising your rights as a data subject.

4.3. Cookies

4.3.1 Functional Cookies

On our website, we use cookiebot, a webservice developed and administered by Cybot A/S, Havnegade 39, 1058 Copenhagen (hereinafter: cookiebot.com). We use this service to collect, store and respect your cookie preferences in compliance with the GDPR. In order to do so, your browser will submit your IP-Address to cookiebot.com and cookiebot.com will assign you a cookie-ID which contain your cookie choices. The legal basis for this processing of personal data is Art. 6 (1) f GDPR, whereas the our legitimate interest is to store your privacy and cookie choices in a format which suits our technical setup. You can find further information, such as your rights as a data subject and information on deletion under: https://www.cookiebot.com/de/privacy-policy/. You can surpress the aforementioned processing of personal data by deactivating the execution of scripts in your browser or use a script blocker such as: www.noscript.net oder www.ghostery.com.

4.3.2 Consent-based cookies

We use the following cookies in case you provided us your consent according to art. 6 par. 1 lit. a GDPR. Without your consent, you can access the website without these cookies.

4.3.2.1. Google Analytics and Google Tag Manager

We use the web analysis services of Google Inc. ("Google") to analyze the use of the websites, in particular: Google Analytics. A cookie is set for this purpose. The information generated by this cookie about your use of this website (including your IP address) is transferred to a Google server in the USA and stored there. 
The website uses Google Analytics exclusively with the setting of IP anonymization, so that IP addresses are only processed in a shortened form in order to exclude references to individual website visitors. Through the IP-anonymization on this website, your IP address will be shortened by Google within member states of the EU or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. 
Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. If you provide your consent, you agree to the processing of the data collected about you by Google in the manner and for the purpose described above.
Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
For more information on data processing related to Google Analytics, refer to the Google’s privacy policy: https://policies.google.com/privacy?hl=en .

4.3.2.2. Google Double Click

This website uses the online marketing tool DoubleClick from Google. Double-Click uses cookies to serve ads relevant to web site visitors, to improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Google uses a cookie ID to identify which ads are served on which browser, so it can prevent them from being shown more than once. DoubleClick may also use cookie IDs to track conversions related to ad requests. This is the case, when a user sees a DoubleClick ad and then visits the advertiser's site on the same browser to make a purchase. According to Google, DoubleClick cookies do not contain any personally identifiable information.
Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of DoubleClick, Google receives the information that you have visited the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider will identify and save your IP address.
In addition, DoubleClick's floodlight cookies allow us to understand whether you perform certain actions on our site after you view or click on one of our display/video ads on Google or another platform through DoubleClick (conversion tracking). DoubleClick uses this cookie to understand the content that you have interacted with on our sites so that we can later send you targeted advertisements. For more information about DoubleClick by Google, please visit www.google.de/doubleclick  and support.google.com/adsense/answer/2839090 , and for general information about privacy at Google, please visit https://policies.google.com/privacy?hl=en . Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org .
Right of objection: The collection and storage of data by Google Analytics can be objected to at any time with effect for the future. You have the possibility to install a browser plug-in published by Google. This is available for various browser versions and can be downloaded here.
You can object to the use of the aforementioned web tracking services at any time by changing your browser settings and/or clicking the following link to download and install the available browser plug-ins: 

Google Analytics: https://tools.google.com/dlpage/gaoptout 

You can prevent and object to this tracking procedure in various ways:

  • by changing the settings in the cookie settings section of this website; 
  • by adjusting your browser software settings accordingly, in particular the suppression of third-party cookies means that you will not receive ads from third parties;
  • by disabling cookies for conversion tracking by setting your browser to block cookies from the domain "www.googleadservices.com", https://www.google.de/settings/ads , this setting will be cleared when you delete your cookies;
  • by permanently disabling cookies in your Firefox, Internet Explorer or Google Chrome browsers at http://www.google.com/settings/ads/plugin .

Please note that in this case you may not be able to use all functions of this website.

5. Who comes into possession of my personal data?

Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.
No sharing of information with other recipients such as advertising partners, providers of social media services or credit institutions (“third parties”) takes place.

6. Is my personal data processed outside of the EU or EEA (‘transfer to a third country’)?

The use of Google Analytics as described in section 4.4 above causes personal data to be transferred to a third country since the data centers of Google Inc. are located outside of the European Union and the European Economic Area (“EU or EEA”). Such transfers of personal data to third countries may result in your personal information being transmitted to a country which does not provide for the same standard of data protection as the EU or EEA.

7. What data privacy rights do I have?

You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data portability). 

If you have given your consent to the processing of your personal information for specific purposes, you can revoke that consent at any time for the future. Your notice of revocation is to be addressed to us by writing to the contact address indicated in section 1. 

Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situation to raise an objection to the processing of your data that is done on the basis of Art. 6(1)(f) GDPR. You also have the right to lodge an objection to the processing of your personal information for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website. 

You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is: 

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestr. 2-4
40213 Düsseldorf, Germany
Phone: 0211/38424-0
Fax: 0211/38424-10
Email: poststelle@ldi.nrw.de 

You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.

8. To what extent does automated decision-making take place?

We do not use any fully automated decision-making processes for any of the purposes set out in section 4.

9. Is profiling done?

No profiling takes place for any of the purposes set out in section 4.

Date of this Privacy Policy: October, 27th 2020

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