Privacy Policy

Personal data (hereinafter referred to as “data” for the most part) is processed by us only as necessary and for the purpose of providing a functional and user-friendly website, including its content and the services offered there.

Pursuant to Art. 4 No. 1. of Regulation (EU) 2016/679, i.e. the General Data Protection Regulation (hereinafter referred to only as “GDPR”), “processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

With the following privacy policy, we inform you in particular about the nature, scope, purpose, duration and legal basis of the processing of personal data, insofar as we decide either alone or jointly with others on the purposes and means of processing. In addition, we inform you below about the third-party components used by us for optimization purposes as well as to increase the quality of use, insofar as third parties process data through this, again under their own responsibility.

Our data protection declaration is structured as follows:

  1. Information about us as the responsible party
  2. rights of users and data subjects

III. Information on data processing

  1. Information about us as the responsible party

The responsible provider of this website in the sense of data protection law is:

Dialoge – Bodensee Sprachschule GmbH

Postal address:

Am Bahnhof 1b

88131 Lindau (Lake Constance) – Germany

Contact:

Phone: +49 8382 / 94323-0

Fax: +49 8382 / 94323-23

E-Mail: info@dialoge.com

Represented by:

Christine Buck-Zimmermann

Registered at: Local Court Kempten i.A., HRB 14623

 

If you have any questions about data protection, please send us an e-mail or contact the person responsible for data protection in our organization directly:

datenschutzbeauftragte@dialoge.com

  1. Rights of users and data subjects

With regard to the data processing described in more detail below, users and data subjects have the right to

– To confirmation as to whether data concerning them is being processed, to information about the data being processed, to further information about the data processing and to copies of the data (cf. also Art. 15 DSGVO);

– to correction or completion of incorrect or incomplete data (cf. also Art. 16 DSGVO);

– to the immediate erasure of the data concerning them (cf. also Art. 17 DSGVO), or, alternatively, insofar as further processing is necessary pursuant to Art. 17 (3) DSGVO, to the restriction of processing in accordance with Art. 18 DSGVO;

– to receive the data concerning them and provided by them and to transfer this data to other providers/controllers (cf. also Art. 20 DSGVO);

– to lodge a complaint with the supervisory authority if they are of the opinion that the data concerning them is being processed by the provider in breach of data protection provisions (cf. also Art. 77 GDPR).

In addition, the Provider is obliged to inform all recipients to whom data has been disclosed by the Provider about any correction or deletion of data or restriction of processing that takes place on the basis of Articles 16, 17 (1), 18 DSGVO. However, this obligation does not exist insofar as this notification is impossible or involves a disproportionate effort. Notwithstanding the above, the user has a right to information about these recipients.

Likewise, according to Art. 21 DSGVO, users and data subjects have the right to object to the future processing of data concerning them, insofar as the data is processed by the provider in accordance with Art. 6 para. 1 lit. f) DSGVO. In particular, an objection to data processing for the purpose of direct marketing is permitted.

III. Information on data processing

Your data processed when using our Internet presence will be deleted or blocked as soon as the purpose of the storage no longer applies, the deletion of the data does not conflict with any statutory retention obligations and no other information on individual processing procedures is provided below.

In the course of using this website, we process the following personal data:

Server data

For technical reasons, in particular to ensure a secure and stable Internet presence, data is transmitted by your Internet browser to us or to our web space provider. These so-called server log files are used to collect, among other things, the type and version of your Internet browser, the operating system, the website from which you accessed our website (referrer URL), the website(s) of our website that you visit, the date and time of the respective access, as well as the IP address of the Internet connection from which the use of our website takes place.

The data collected in this way is stored temporarily, but not together with other data about you.

This storage takes place on the legal basis of Art. 6 para. 1 lit. f) DSGVO. Our legitimate interest lies in the improvement, stability, functionality and security of our website.

The data is deleted again after seven days at the latest, unless further storage is required for evidence purposes. Otherwise, the data is exempt from deletion in whole or in part until final clarification of an incident.

Cookies

  1. a) Session cookies/Session cookies

We use so-called cookies with our Internet presence. Cookies are small text files or other storage technologies that are placed and stored on your terminal device by the Internet browser you use. Through these cookies, certain information from you, such as your browser or location data or your IP address, is processed to an individual extent.

This processing makes our website more user-friendly, effective and secure, as the processing enables, for example, the reproduction of our website in different languages or the offer of a shopping cart function.

The legal basis for this processing is Art. 6 para. 1 lit b.) DSGVO, insofar as these cookies data are processed for contract initiation or contract execution.

If the processing does not serve the purpose of initiating or executing a contract, our legitimate interest lies in improving the functionality of our website. The legal basis is then Art. 6 para. 1 lit. f) DSGVO.

When you close your internet browser, these session cookies are deleted.

  1. b) Third-party cookies

Where applicable, cookies from partner companies with which we cooperate for the purposes of advertising, analysis or the functionalities of our website are also used with our website.

The details of this, in particular the purposes and legal basis for the processing of such third-party cookies, can be found in the following information.

  1. c) Removal option

You can prevent or restrict the installation of cookies by setting your internet browser. Likewise, you can delete already stored cookies at any time. However, the steps and measures required for this depend on your specific Internet browser used. If you have any questions, please use the help function or documentation of your Internet browser or contact its manufacturer or support. In the case of so-called Flash cookies, however, processing cannot be prevented via the browser settings. Instead, you must change the settings of your Flash player. The steps and measures required for this also depend on the specific Flash player you use. If you have any questions, please also use the help function or documentation of your Flash player or contact the manufacturer or user support.

However, if you prevent or restrict the installation of cookies, this may mean that not all functions of our website can be fully used.

Contract processing

The data you provide for the use of our goods and/or services are processed by us for the purpose of contract execution and are necessary to this extent. Conclusion and processing of the contract are not possible without the provision of your data.

The legal basis for the processing is Art. 6 para. 1 lit. b) DSGVO.

We delete the data with complete contract execution, but must observe the retention periods under tax and commercial law.

In the context of contract processing, we pass on your data to the transport company commissioned with the delivery of goods or to the financial service provider, insofar as the transfer is necessary for the delivery of goods or for payment purposes.

The legal basis for the transfer of data is then Art. 6 para. 1 lit. b) DSGVO.

Newsletter

If you subscribe to our newsletter distribution list, your e-mail address , optionally also your name and address, as well as the newsletter you have selected will be stored by us on a server.

In addition, the following data is collected by the system during registration:

– IP address of the calling computer;

– Date and time of registration.

For the processing of the data, your consent is obtained during the registration process and reference is made to this privacy policy. The processing of the data is based on your consent according to Art. 6 para. 1 lit. a DSGVO and within the scope of legitimate interest according to Art. 6 para. 1 lit. f DSGVO.

We use this data exclusively for sending the newsletter. The registration system with an additional confirmation message containing a link to the final registration (double opt-in) ensures that the newsletter was requested by you and not by a third party. During registration, your data is stored on our servers and a confirmation message with a link to the final registration is generated to the specified e-mail address. Only by confirming the link in the e-mail, your data will be stored for the newsletter dispatch for the duration of the use of our offer.

Insofar as you no longer agree to the storage of data for this purpose and thus no longer wish to use our offer, you can unsubscribe from our newsletter at any time. For this purpose, you will find a corresponding link in each newsletter. The personal data you provided for the newsletter subscription will then be deleted.

Use of the dispatch service provider “MailChimp”.

Our newsletter is sent by means of “MailChimp”, an application of Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The email addresses of the recipients of our newsletter, as well as their other data described in this privacy notice, are stored on the servers of the Rocket Science Group in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. Furthermore, MailChimp will use this data, according to its own information, to optimize its own offer. However, MailChimp does not use the personal data of the recipients of our newsletter to contact them itself or to pass them on to third parties. Mailchimp has committed itself to comply with the EU data protection regulations.

Statistical collection and analyses

Our newsletters contain a so-called “web-beacon”, i.e. a file that is retrieved from MailChimp’s server when the newsletter is opened. As part of this retrieval, technical information such as information about the browser you are using and your system, as well as your IP address and retrieval time are collected. This information is used for the technical improvement of the services. The statistical surveys also include the determination of whether and when the newsletters are opened and which links are activated.

Unsubscribing from the newsletter

You can unsubscribe from our newsletter at any time. This will simultaneously terminate your consent to its dispatch via MailChimp and the statistical analyses. 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.

The legal basis for the processing of personal data in the context of the newsletter dispatch via Mailchimp is Art. 6 para. 1 lit. a DSGVO.

 

Contact requests / contact possibility

1) Contacting by e-mail

Contacting our company by e-mail is possible via the e-mail addresses published on our website.

If you use this contact method, the data you provide (e.g. surname, first name, address), but at least the e-mail address, as well as the information contained in the e-mail together with any personal data you may have provided will be stored for the purpose of contacting you and processing your request. In addition, the following data is collected by our system:

– IP address of the calling computer;

– Date and time of the e-mail.

The legal basis for the processing of personal data in the context of e-mails transmitted to us is Art. 6 para. 1 lit. b or lit. f DSGVO.

  1. contact via website contact form

Insofar as you use the contact form provided on our website for communication, it is necessary to provide your name and first name as well as your e-mail address. Without this data, your request transmitted via contact form cannot be processed. The specification of the address is optional and allows us, if desired by you, to process your request by mail.

In addition, the following data is collected by our system:

– IP address of the calling computer;

– Date and time of registration.

The legal basis for the processing of personal data within the scope of e-mails transmitted to us is Art. 6 Para. 1 lit. b or lit. f DSGVO.

Your data will be deleted if your inquiry has been answered conclusively and the deletion does not conflict with any statutory retention obligations, such as in the case of any subsequent contract processing.

Google Analytics

(1) This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymization is activated on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, 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 to the website operator.

(2) The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

(3) You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google, as well as 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.

(4) This website uses Google Analytics with the extension “_anonymizeIp()”. This means that IP addresses are processed in abbreviated form, thus excluding the possibility of personal references. If the data collected about you is related to a person, this is immediately excluded and the personal data is deleted immediately.

(5) We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained enable us to improve our offer and make it more interesting for you as a user.

(6) Information of the third party provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User conditions: http://www.google.com/analytics/terms/de.html, overview of data protection: http://www.google.com/intl/de/analytics/learn/privacy.html, as well as the data protection declaration: http://www.google.de/intl/de/policies/privacy.

(7) This website also uses Google Analytics for a cross-device analysis of visitor flows, which is performed via a user ID. You can deactivate the cross-device analysis of your usage in your customer account under “My data”, “Personal data”.

(8) Use of the Google Tag Manager application: The Google Tag Manager is an application with which website tags can be managed via an interface. The Google Tag Mana-ger application itself (which implements the tags) is a cookie-less domain and does not collect any personal data. The application provides for the triggering of other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at cookie or do-maine level, this remains in place for all tracking tags implemented with Google Tag Manager. http://www.google.de/tagmanager/use-policy.html

The legal basis for the processing of personal data using Google Analytics and Google Tag Manager is Art. 6 (1) lit. a DSGVO.

YouTube

We have integrated YouTube videos into our online offer, which are stored on http://www.YouTube.com and can be played directly from our website. These are all integrated in “extended data protection mode”, which means that no data about you as a user is transmitted to YouTube if you do not play the videos. Only when you play the videos, the data mentioned in paragraph 2 are transmitted. We have no influence on this data transmission.

By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the above-mentioned server data is transmitted. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want the assignment with your profile at YouTube, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

Further information on the purpose and scope of data collection and its processing by Y-ouTube can be found in the privacy policy. There you will also find further information about your rights and setting options to protect your privacy: https://www.google.de/intl/de/policies/privacy.

Google AdWords with conversion tracking

(1) We use the offer of Google AdWords to draw attention to our attractive offers with the help of advertising media (so-called Google AdWords) on external websites. We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. In this way, we pursue the interest of displaying advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs.

(2) These advertising materials are delivered by Google via so-called “ad servers”. For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as display of the ads or clicks by users, can be measured. If you access our website via a Google ad, Google Adwords will store a cookie on your PC. These cookies usually lose their validity after 30 days and are not intended to identify you personally. For this cookie, the unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values.

(3) These cookies enable Google to recognize your internet browser. If a user visits certain pages of the website of an Adwords customer and the cookie stored on his computer has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page. A different cookie is assigned to each Adwords customer. Cookies can therefore not be tracked via the websites of Adwords customers. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. Based on these evaluations, we can see which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising media; in particular, we cannot identify users on the basis of this information.

(4) 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 AdWords Conversion, Google receives the information that you have called up the relevant part of our website or clicked on an ad 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, there is a possibility that the provider may obtain and store your IP address.

(5) You can prevent participation in this tracking procedure in various ways:

(a) by adjusting your browser software accordingly; in particular, the suppression of third-party cookies will result in you not receiving ads from third-party providers;

  1. b) by disabling conversion tracking cookies by setting your browser to block cookies from the domain “www.googleadservices.com”, https://www.google.de/settings/ads, which setting will be deleted when you delete your cookies;
  2. c) by disabling the interest-based ads of the providers that are part of the “About Ads” self-regulatory campaign, via the link http://www.aboutads.info/choices, this setting being deleted when you delete your cookies; d) by permanent

deactivation in your Firefox, Internetexplorer or Google Chrome browsers at the link http://www.google.com/settings/ads/plugin. We would like to point out that in this case you may not be able to use all functions of this offer in full.

(6) The legal basis for the processing of your data is Art. 6 para. 1 p. 1 lit. a DS-GVO. Further information on data protection at Google can be found here: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org.

 

*DSVGO/GDPR: General Data Protection Regulation

Sample privacy policy of the law firm Weiß & Partner (in excerpts)

Please note: in the event of disputes about the meaning or interpretation of a provision of any translated version of these privacy policiy terms and conditions, the German version shall prevail.