§1 Information on the collection of personal data
(1) In the following, we inform you about the collection of personal data when using our website and within the scope of our services. Personal data is all data that can be related to you personally, e.g. name, address, e-mail addresses, user behavior.
(2) The responsible party pursuant to Art. 4 (7) EU General Data Protection Regulation (GDPR) is
Spiced Education GmbH
You can find further contact details in our provider identification (" Imprint ").
You can reach our company data protection officer at the aforementioned contact details with the addition of the letter "Der/die Datenschutzbeauftragte" or by e-mail at email@example.com.
(3) When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, name and telephone number, if applicable) will be stored by us in order to answer your questions. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
(4) If we use contracted service providers for individual functions of our offer or would like to use your data for advertising purposes, we will inform you in detail about the respective processes below. In doing so, we will also state the defined criteria for the storage period.
§2 Your rights
(1) You have the following rights against us regarding the personal data concerning you:
- Right to information
- Right to rectification or deletion,
- Right to restriction of processing,
- Right to object to the processing,
- Right to data portability
(2) You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us.
§3 Collection of personal data when visiting our website
(1) In the case of mere informational use of the website, i.e. if you do not register or otherwise transmit information to us, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security (legal basis is Art. 6 para. 1 p. 1 lit. f GDPR):
- IP address
- Date and time of the request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status / HTTP status code
- The amount of data transferred in each case
- Website from which the request comes
- Operating system and its interface
- Language and version of the browser software.
(2) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive associated with the browser you are using and through which the body that sets the cookie (here by us), certain information flows. Cookies cannot execute programs or transfer viruses to your computer. They serve to make the Internet offer as a whole more user-friendly and effective.
Cookies are used to make the website more user-friendly, to optimize the functions and services of the website and to provide you with content tailored to your needs.
The user data collected through technically necessary cookies are not used to create user profiles.
In addition, with your separate consent, cookies may be used for the provision of external media such as movies and maps, as well as for the analysis of the use of the website and other functions.
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 (1) lit. f GDPR, whereby the legitimate interest of the controller is the secure, stable, efficient provision of the functions of the website and the information that can be accessed via it. If the responsible party fulfills a contractual obligation to you with the respective function, the legal basis is Art. 6 (1) lit. b GDPR.
The legal basis for the processing of personal data using cookies for analysis purposes as well as for other processing purposes that are not technically necessary is, if the user has given his consent in this regard, Art. 6 (1) lit. a GDPR in conjunction with Section 25 TTDSG.
§4 Further functions and offers of our website
(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you usually have to provide further personal data, which we use to provide the respective service and for which the aforementioned data processing principles apply.
(2) In some cases, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly monitored.
(3) Furthermore, we may pass on your personal data to third parties if we offer participation in promotions, competitions, conclusion of contracts or similar services together with partners. You will receive more information about this when you provide your personal data or below in the description of the offer.
(4) If our service providers or partners are located in a country outside the European Economic Area (EEA), we will inform you about the consequences of this circumstance in the description of the offer.
§5 Objection or revocation against the processing of your data
(1) If you have given your consent to the processing of your data, you may revoke this consent at any time. Such revocation affects the permissibility of processing your personal data after you have expressed it to us.
(2) Insofar as we base the processing of your personal data on the balance of interests, you may object to the processing. This is the case if the processing is not necessary, in particular, for the fulfillment of a contract with you, which is presented by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will review the situation and either discontinue or adjust the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing.
(3) Of course, you can object to the processing of your personal data for purposes of advertising and data analysis at any time. You can inform us of your objection to advertising using the contact details provided above.
§6 Analysis tools
(1) Use of Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Ireland Limited ("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.
The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.
This website uses Google Analytics with the extension "_anonymizeIp()". This means that IP addresses are processed in abbreviated form, which means that personal references can be ruled out. Insofar as the data collected about you is related to a person, this is therefore immediately excluded and the personal data is thus immediately deleted.
We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained allow us to improve our offer and make it more interesting for you as a user.
For the possible cases in which personal data is transferred to the USA, Google complies with the data protection requirements for data transfer to third countries pursuant to Art. 44 et seq. GDPR. For this purpose, so-called EU standard contractual clauses have been concluded. You can view these here: https://policies.google.com/privacy/frameworks?hl=de
(2) TikTok Pixel
We use TikTok Pixel, a conversion tracking tool for advertisers, on our website. The service provider is the Chinese company TikTok. The company TikTok Technology Limited (10 Earlsfort Terrace, Dublin, D02 T380, Ireland) is responsible for the European region.
TikTok also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be associated with various risks for the legality and security of the data processing.
As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. in particular in the USA) or a data transfer there, TikTok uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 GDPR). Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through these clauses, TikTok undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the US. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eurlex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
The legal basis for the processing of your personal data is your consent (Art. 6 para. 1 a GDPR in conjunction with § 25 TTDSG).
(3) LinkedIn Insight Tag
The data is encrypted, anonymized within seven days and deleted within 90 days. LinkedIn does not share the personal data with us, the operator of this website. LinkedIn only provides aggregate reports on website audience and ad performance. LinkedIn also provides retargeting for website visitors so that you can be shown ads from us on the websites you visit.
If you have consented to the processing of your personal data by using the LinkedIn Insight Tag and you wish to withdraw your consent at a later date, you can do so by changing the settings of the cookie banner or your browser settings.
LinkedIn members can alternatively also control the use of their personal data for advertising purposes via their account settings. To do so, follow this link to the LinkedIn page: https://www.linkedin.com/start/join?session_redirect=https%3A%2F%2Fwww%2Elinkedin%2Ecom%2Fpsettings%2Fadvertising%2Factions-that-showed-interest&trk=login_reg_redirect.
§7 Usage-based advertising content
(1) Google Ads
We use "Google Ads" (formerly Google AdWords) on our website, a service provided by Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google"). Google Ads enables us to draw attention to our attractive offers with the help of advertising media on external websites. This enables us to determine how successful individual advertising measures are. These advertising media are delivered by Google via so-called "AdServers". For this purpose, we use so-called AdServer cookies, which can be used to measure certain parameters for measuring success, such as display of the ads or clicks by users. If you access our website via a Google ad, Google Ads will store a cookie on your PC. These cookies usually lose their validity after 30 days. They are not intended to identify you personally. The following information is usually stored as analysis values for this cookie: unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions), opt-out information (marking that the user no longer wishes to be addressed). These cookies allow Google to recognize your web browser. If a user visits certain pages of an Ads customer's website and the cookie stored on their computer has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to that page. A different cookie is assigned to each Ads customer. Cookies can therefore not be tracked across Ads customers' websites. 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 tools; in particular, we cannot identify users on the basis of this information. Due to the marketing tools used, your browser automatically establishes a direct connection with Google's server. We have no influence on the scope and further use of the data collected by Google through the use of Google Ads. According to our knowledge, Google receives the information that you have called up the relevant part of our website or clicked on an ad from us. If you have a user account with Google and are registered, Google can assign the visit to your user account. Even if you are not registered with Google or have not logged in, there is the possibility that Google learns your IP address and stores it.
We use Google Ads for marketing and optimization purposes, in particular to serve relevant and interesting ads to you, to improve campaign performance reports and to achieve a fair calculation of advertising costs. This is also our legitimate interest in the processing of the above data by the third-party provider. The legal basis is Art. 6 para. 1 p. 1 lit. f) GDPR and, insofar as we obtain your consent, Art. 6 para. 1 lit. a GDPR.
You can prevent the installation of cookies by deleting existing cookies and deactivating the storage of cookies in the settings of your web browser. We would like to point out that in this case you may not be able to use all functions of our website to their full extent. It is also possible to prevent the storage of cookies by setting your web browser to block cookies from the domain "www.googleadservices.com" (https://www.google.de/settings/ads). We would like to point out that this setting will be deleted when you delete your cookies. In addition, you can deactivate interest-based ads via the link https://optout.aboutads.info. We would like to point out that this setting will also be deleted when you delete your cookies.
Third-party information: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland
Further information on data use by Google, on setting and objection options, and on data protection can be found on the following Google web pages:
Google website statistics: https://services.google.com/sitestats/de.html
(2) Google Tag Manager
(3) Facebook Pixel
This website uses the visitor action pixel from Facebook for conversion measurement. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the collected data is also transferred to the USA and other third countries.
In this way, the behavior of page visitors can be tracked after they have been redirected to the provider's website by clicking on a Facebook ad. This allows the effectiveness of the Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimized.
The collected data is anonymous for us as the operator of this website, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, according to the Facebook data usage policy. This allows Facebook to enable the placement of advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator.
The use of Facebook Pixel is based on Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in effective advertising measures including social media. If a corresponding consent has been requested (e.g. consent to store cookies), the processing is based exclusively on Art. 6 (1) lit. a GDPR; the consent can be revoked at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381
You can also disable the Custom Audiences remarketing feature in the Ad Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.
If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/
As part of the application of Google Analytics, this website uses the DoubleClick web analytics service, which enables recognition of the user's browser when visiting other websites. The data collected is only evaluated for statistical purposes and in anonymous form. The information generated by the cookie about your visit to the Bodensee-Therme Konstanz website will be transmitted to and stored by Google on servers in the United States. The IP address is shortened before transmission within the Member States of the European Union or in other contracting states to the Agreement on the European Economic Area by activating IP anonymization.
Only in exceptional cases will the IP address be transferred in full to a Google server in the USA before being shortened there. The anonymized IP address transmitted by the user's browser as part of Google Analytics is not merged with other Google data. DoubleClick cookies do not contain any personal data.
The information generated is used to compile reports on the activities on this website and to provide other services related to the use of this website. If required by law, Google may transfer this information to third parties or to the extent that third parties process this data on Google's behalf.
The legal basis of any processing of personal data is the consent of the user in accordance with Art. 6 para. 1 lit. a GDPR. The user has the option at any time to object to the tracking web analysis for the future or to deactivate the DoubleClick cookie. The browser extension required for this can be downloaded and installed on the corresponding Google website. If several end devices or browsers are used by the user, the opt-out must be performed for each end device or browser. For this purpose, the user can click on the following link: http://google.com/ads/preferences/html/opt-out.html
(5) Microsoft Advertising
On our website, the service Microsoft Advertising (formerly Bing Ads) is used to analyze and optimize the economic operation. Microsoft Advertising is a conversion and tracking service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft").
ATTENTION: Within the scope of this service, data is transferred to the USA or such transfer cannot be ruled out. We would like to point out that, according to the European Court of Justice, there is currently no adequate level of data protection in the case of data transfer to the USA and that there are therefore various risks (such as possible access by US secret services).
Microsoft Advertising sets cookies on users' devices that analyze user behavior on our website. This assumes that the user has reached our website via an ad from Microsoft Advertising. This provides us with information on the total number of users who clicked on such an ad, were redirected to our website and previously reached a specific landing page (so-called conversion measurement). In the process, no IP addresses are stored and no personal information about the identity of our users is communicated.
The processing of your data is based on your consent within the meaning of Art. 6 para. 1 lit. a GDPR. You can revoke this consent at any time with effect for the future.
For more information about Microsoft Advertising's analytics services, please visit Microsoft's website at https://help.ads.microsoft.com/#apex/3/de/53056/2.
(6) Reddit Ads
The processing is based on your consent pursuant to Art. 6 para. 1 lit. a GDPR, § 25 TTDSG. You can revoke your consent for future remarketing at any time in the privacy settings.
§8 Newsletter and email messages
(1) With your consent, you can subscribe to our newsletter (if offered), with which we inform you about our current interesting offers. The advertised services and benefits are named in the declaration of consent.
(2) For the registration to our newsletter we use the so-called double-opt-in procedure. This means that after your registration, we will send you an email to the email address you provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your respective IP addresses used and times of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.
(3) The only mandatory information for sending the newsletter is your e-mail address. The provision of further, separately marked data is voluntary and will be used to address you personally. After your confirmation, we store your e-mail address for the purpose of sending the newsletter. The legal basis is Art. 6 para. 1 p. 1 lit. a GDPR.
(4) You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in each newsletter email or by sending a message to the contact details provided in the imprint.
(5) We would like to point out that we can evaluate your user behavior when sending the newsletter. For this evaluation, the sent emails then contain so-called web beacons or tracking pixels, which are single-pixel image files that are stored on our website. For the evaluations, we link the data mentioned in § 3 and the web beacons with your e-mail address and an individual ID. Links received in the newsletter also contain this ID. With the data obtained in this way, we create a user profile in order to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletters, which links you click on in them and infer your personal interests from this. We link this data to actions you have taken on our website.
You can object to this tracking at any time by clicking on the separate link provided in each email or by informing us via another contact channel. The information is stored for as long as you are subscribed to the newsletter. After unsubscribing, we store the data purely statistically and anonymously. Moreover, such tracking is not possible if you have deactivated the display of images by default in your e-mail program. In this case, the newsletter will not be fully displayed to you and you may not be able to use all functions. If you display the images manually, the above-mentioned tracking will take place.
(7) The email addresses of our newsletter recipients, as well as their other data described in the context of 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, according to its own information, MailChimp may use this data to optimize or improve its own services, e.g. to technically optimize the dispatch and display 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 itself or to pass them on to third parties.
§9 Linked content / sharing functions
Our website contains links to third-party websites. The respective data protection declarations and data protection notices of the respective operators of the linked websites apply. We point out that we are not responsible for the data processing practices on third-party platforms outside our own sphere of influence.
§10 Data protection during applications and the application process
The data controller collects and processes the personal data of applicants for the purpose of handling the application process. Concerns, on the one hand, applications related to employment and other activities for the responsible party and, on the other hand, the application for the study programs, workshops and boot camps offered by the responsible party.
The processing of personal data within the scope of the application procedure is in any case usually carried out electronically.
The following applies to employment relationships and other activities for the person responsible: If the person responsible concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the person responsible does not conclude an employment contract with the applicant, the application documents are automatically deleted four months after notification of the rejection decision, provided that no other legitimate interests of the person responsible oppose deletion. Other legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG). The legal basis for the processing of personal data of applicants is Section 26 of the Federal Data Protection Act (BDSG) in conjunction with Art. 6 para. 1 lit. b, 88 GDPR, furthermore, insofar as the processing is carried out to meet legal requirements, Art. 6. para. 1 lit. c GDPR and, insofar as consent of the data subject is the basis of the processing, Art. 6 para. 1 lit. a GDPR in conjunction with Section 26 BDSG.
For study programs, workshops and boot camps, the following applies: if the application is successful, a contractual relationship is established regarding the services of the responsible party for the respective applicant and the consideration to be provided by the respective applicant. The personal data processed in this context will be stored for the duration of the contractual relationship and beyond that until the expiry of the regular statutory limitation periods, unless legal obligations, in particular tax and commercial law retention obligations, require longer storage.
If the application is not successful, the personal data will be deleted after a period of four months. With the separately obtained consent of the data subject, the data may be stored for a further twelve months so that the application can be considered again in the event of a vacancy for a course or any offers that may be considered for the applicant.
The legal basis of the processing is Art. 6 (1) lit. b GDPR, insofar as the processing is carried out for the purpose of initiating, implementing and settling the contractual relationship, Art. 6 (1) lit. f GDPR, insofar as the legitimate interests of the responsible party in proper documentation of its business transactions, in providing evidence in the context of any disputes and in the management, maintenance and expansion of the business relationship between the responsible party and its contractual partner and, via these, Art. 6 (1) lit. c GDPR, insofar as the processing is carried out for the purpose of fulfilling statutory provisions. If the processing is based on the consent of the data subject, Art. 6(1)(a) is the legal basis of the processing.
For application procedures, we use the services and performance of Teamtailor AB, Östgötagatan 16. SE-116 25 Stockholm, which provides platform services on our behalf for the administration and implementation of application procedures, whereby personal data is processed exclusively in the European Union.
Unless otherwise specified in the respective individual information, the controller processes personal data in accordance with the statutory provisions for the purposes presented here in each case and only for as long as personal identification of the data subject is required for the respective purpose. Subsequently, the data is deleted or neutralized/anonymized in accordance with data protection.
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