Data Protection Policy

We are very pleased about your interest in our organisation. Data protection is highly important to DVV International.

DVV International is the Institute for International Cooperation of the German Adult Education Association (DVV). DVV represents the interests of the approximately 900 Adult Education Centres and their associations at Länder level, these being the largest further education providers in Germany.

It is possible as a matter of principle to use our websites without providing personal data. Your personal data will only be processed if you decide to use one of the services offered on our website. Personal data will be handled in accordance with the statutory provisions.

The use of our online services is optional.

1. Definitions

Our Data Protection Policy is intended to be simple and understandable for everyone. As a rule, the Data Protection Policy uses the official terms contained in the General Data Protection Regulation (GDPR).

The official definitions are explained in Art. 4 GDPR.

2. Name and address of the controller

The controller within the meaning of Art. 4(7) GDPR (General Data Protection Regulation) is:

Deutscher Volkshochschul-Verband e. V. (DVV)
Königswinterer Straße 552b
53227 Bonn
Germany

Tel.: +49 (0)228 975690
e-mail: info@dvv-vhs.de
Website: http://www.volkshochschule.de

3. Name and address of the data protection officer

The controller’s data protection officer is:

Alexandra Horn, steep GmbH
e-mail: dsb@dvv-vhs.de or DSB_DVV@steep.de

4. Cookies

Our website uses “cookies” in order to be able to continually optimise its Internet presentation.

Cookies are small text files which are stored on the user’s computer when specific websites are visited.

Some cookies are important for the pages to function properly, and are automatically activated by us when a user visits them. Using cookies enables us to extend the range of functions of our website so that a visit to our website can be made as convenient for you as possible. This means that data are stored on your computer when you use our website, for example to set the language selection for use, or to save your personal settings.

You can find out how to prevent your browser from accepting new cookies, how to set your browser to notify you when you receive a new cookie, or how to disable cookies altogether, by clicking on the “Help” menu in your browser’s menu bar.

If you deactivate the storage of cookies or delete cookies that have already been stored, this may limit the scope and functionality of our website.

What cookies do we use and for what purpose?

We use cookies to track how you use our website during a visit, and to store the information that you have provided and the choices that you have made (e.g. your language selection) while you are viewing the pages. These are called “session cookies”.

Session cookies are only kept on your computer for the duration of your visit to our website.

We also use cookies known as “persistent cookies”. These are saved beyond your individual visit, and enable serve us to recognise you the next time you visit our website.

5. Processing of personal data

General data

Our website collects a series of general data and information each time a data subject or an automated system visits the website. These general data and information are stored in the server’s logfiles. It is possible to record

(1) the browser types and versions used,

(2) the operating system used by the system accessing the site,

(3) the website from which an accessing system reaches our website (“referrer”),

(4) the sub-websites which are addressed by a system accessing the site,

(5) the date and time of access to the website,

(6) an Internet protocol address (IP address),

(7) the Internet service-provider of the system accessing our site, and

(8) other similar data and information serving the prevention of dangers in the event of attacks on our information technology systems.

We do not draw any conclusions regarding the data subject when using these general data and information.

Contact form and e-mail

If you contact us by e-mail, we will process your data in order to deal with the request. Your personal data are explicitly input on a voluntary basis. We process your personal data on the basis of your consent (Article 6(1)(a) GDPR).

When you contact us via a contact form, we will store the data that you provide (your e-mail address, where appropriate your name and your telephone number) in order to answer your enquiry.
We erase the data generated in this connection in accordance with the legal requirements if they no longer need to be stored, or restrict processing if there are legal obligations to retain data.

Newsletter

With your consent, you can subscribe to our newsletter.

We use the “Double-Opt-In procedure” to sign you up to our newsletter. This means that after you register, we will send you an e-mail to the e-mail address that you have provided, asking you to confirm that you would like to receive the newsletter.

If you do not confirm your registration, your information will be blocked and automatically erased. In addition, we store the IP addresses that you have used and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data.

Only stating your e-mail address is mandatory for sending the newsletter.

After you have confirmed, we will store your e-mail address for the purpose of sending the newsletter to you. The legal basis is constituted by Art. 6(1), first sentence, (a) GDPR.

You can revoke your consent to receive the newsletter at any time and unsubscribe from it. You can revoke your consent by sending an e-mail to DSB@dvv-vhs.de, by letter to Deutscher Volkshochschul-Verband e. V., Königswinterer Straße 552b, D-53227 Bonn, or by using the unsubscribe link contained in the e-mails.

If you receive our Annual Report on a regular basis, we will process your address and communication data in order to send you this product.

6. Transfer to third parties

Under no circumstances will the personal data be transferred to or processed by third parties.

Your personal data will only be transmitted to third parties

  • if we have explicitly pointed this out in the description of the respective data processing,
  • if you have given your express consent to this in accordance with Art. 6(1), first sentence, (a) GDPR,
  • if transfer is necessary in accordance with Art. 6(1), first sentence, (f) GDPR for the establishment, exercise or defence of legal claims, and there is no reason to presume that you have an overriding legitimate interest in your data not being disclosed,
  • in the event that transfer is necessary for compliance with a legal obligation in accordance with Art. 6(1), first sentence, (c) GDPR, and
  • insofar as this is necessary in accordance with Art. 6(1), first sentence, (b) GDPR for the performance of a contract with you.

Your personal data will not be transmitted to countries outside the EU. In addition, we use external service-providers which we have carefully selected and commissioned in writing to provide our services. Where necessary, contracts for processing have been concluded with these service-providers in accordance with Art. 28 GDPR.

7. Erasure of your personal data

We erase your personal data as soon as the purpose for which we have processed the data ceases to apply. Storage only takes place beyond this point in time if this is required in accordance with laws, regulations or other legal provisions of the European Union, or of a Member State of the European Union, to which we are subject.

8. The legal basis for processing

1. Insofar as you have given us your consent to the processing of your personal data, this constitutes the legal basis for processing (Art. 6(1)(a) GDPR).

2. Art. 6(1)(b) GDPR forms the legal basis for the processing of personal data for the purposes of initiation or performance of a contract with you.

3. Insofar as the processing of your personal data is necessary for compliance with our legal obligations (e.g. to retain data), we are entitled to do so in accordance with Art. 6(1)(c) GDPR.

4. We furthermore process personal data for the purposes of our legitimate interests and the legitimate interests of third parties in accordance with Art. 6(1)(f) GDPR. Such legitimate interests include maintaining the functionality of our IT systems, but also marketing our own and third-party products and services, and the legally-required documentation of business contacts.

9. Rights of data subjects

You have the following rights with regard to personal data concerning you.

Right to information, Art. 15 GDPR

You have the right to obtain the following information from the controller:

  • the purposes of the processing of the personal data,
  • the categories of personal data processed,
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed,
  • the envisaged period for which the personal data concerning you will be stored, or, if it is not possible to provide concrete information in this regard, the criteria used to determine the storage period,
  • whether the data concerning you are transmitted to a third country or to an international organisation – in this context you may obtain information on the appropriate safeguards under Art. 46 GDPR in relation to the transmission.

Right to rectification, Art. 16 GDPR

You have the right to rectification and/or completion of your personal data if they are stored inaccurately or incompletely by the controller. The controller must effect the rectification without undue delay.

Right to erasure (“right to be forgotten”), Art. 17 GDPR

You may obtain the erasure of your personal data without undue delay. The controller is obliged to erase these data without undue delay under certain circumstances if one of the following reasons applies:

  • Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • You withdraw the consent on which the processing of your personal data was based, and there is no other legal ground for the processing.
  • The personal data concerning you have been processed unlawfully.

Right to restriction of processing, Art. 18 GDPR

You may obtain restriction of processing of the personal data concerning you under the following conditions:

  • If the accuracy of the personal data concerning you is contested by you, for a period enabling the controller to verify the accuracy of the personal data.
  • If the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead.
  • The controller no longer needs your personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • You have objected to processing in accordance with Article 21(1) GDPR pending verification of whether the legitimate grounds of the controller override yours.

If the processing of personal data concerning you has been restricted, such data, apart from being stored, may then only be processed under certain conditions.

Right to data portability, Art. 20 GDPR

You have the right to receive the personal data concerning you which you have provided to the controller in a structured, commonly-used and machine-readable format.

Right to object to processing, Art. 21 GDPR

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR; this also applies to profiling based on these provisions.

The controller will no longer process your personal data unless it is able to demonstrate compelling legitimate grounds for the processing which override your rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

Right to revoke your consent, Art. 7(3) GDPR

You have the right to revoke your consent under data protection law at any time – this withdrawal does not affect the lawfulness of the previous processing.

Please address all requests for information, requests for details or other requests to our data protection officer.

The right to lodge a complaint with the supervisory authority

In accordance with Article 77(1) GDPR, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes the provisions of the GDPR.

The responsible supervisory authority is the North Rhine-Westphalia Commissioner for the Protection of Data and Freedom of Information
Kavalleriestraße 2-4
40213 Düsseldorf
Tel.: 0211 384249
poststelle@ldi.nrw.de

10. Data protection for applications and in the application process

We process applicants’ personal data for the purpose of the proper execution of the application procedure.

Processing may also be carried out by electronic means. This is particularly the case if an applicant submits the relevant application documents to us by electronic means, for example by e-mail.

If an employment contract is concluded with an applicant, the data transmitted are stored for the purpose of implementing the employment relationship in compliance with the statutory provisions.

If the controller does not conclude an employment contract with the applicant, the application documents will be automatically erased two months after notification of the rejection decision, insofar as no other legitimate interests of the controller preclude such erasure. Another legitimate interest in this sense is for example a burden of proof in proceedings in accordance with the German General Equal Treatment Act (Allgemeines Gleich­be­handlungs­gesetz – AGG).

Beyond that, we only store your data for a longer period of time if you have expressly consented to longer storage (e.g. for inclusion in our pool of applicants). In this case, you have the right to withdraw your consent at any time for the future. Withdrawal does not affect the lawfulness of the processing that has taken place up to this point in time.

11. Links to other websites

As the provider of our website, we are responsible for the content of our own online presentation. It may be necessary to distinguish between these own contents and links to the content provided by other providers, for which we cannot assume any responsibility and the content of which we do not espouse. However, we have no influence on whether the website operators linked to us comply with the relevant data protection regulations. This data protection declaration therefore does not apply to websites of other providers. This is also the case if they are accessed through links on our website.

Please therefore note the respective data protection regulations of the other providers. We therefore accept no liability for the content of external websites. Only the respective third-party provider is liable for damage caused by incorrect or illegal contents of its website.

12. Statistical evaluations with Matomo

This website uses Matomo, an open source software product for statistical analysis of visitor access. Matomo uses “cookies”, these being text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is stored on the provider’s server in Europe. No personal data are stored; your IP address in particular is automatically truncated, and thus made anonymous. It is therefore not possible to attribute a determined usage pattern to a specific terminal device.

You may reject the installation 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.

We base the use of the aforementioned analysis tool on Art. 6 (1)(f) GDPR: The processing is carried out in order to determine statistical benchmark figures regarding the use of our website, and is therefore necessary in order to safeguard our legitimate interests.

13. Social Media Plug-Ins

(1) We have deliberately decided not to use social media plug-ins. This means that your user data are not automatically transmitted to the servers of social networks such as Facebook, Twitter or similar when you visit our website.

(2) Instead of social media plug-ins, we have opted for links so that data are not passed on to social media services in advance.

(3) You can connect to social networks through our websites by linking to them if you so wish. However, this only happens if you deliberately click on this link.

Facebook fanpage

(1) We operate Facebook fanpages with joint responsibility with Facebook in order to communicate with users there and to indicate interesting offers related to our range of services.

Visitors to our Facebook pages gain access to the technical platform and services of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, for the information service offered here.

Please note that you use these Facebook pages and their functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. commenting, sharing, rating). Alternatively, you can also retrieve the information offered via this page on our website at: https://www.dvv-international.de/.

When you visit our Facebook pages, Facebook records your IP address and other information that is stored on your PC as cookies. This information is used to provide us, as the operator of the Facebook pages, with statistical information about the use of the Facebook pages. Facebook provides further information on this via the following link:

https://de-de.facebook.com/help/pages/insights

The data collected in this context concerning you will be processed by Facebook Ltd., and may thus be transferred to countries outside the European Union. Facebook describes in general terms in its guidelines on data use what information Facebook receives, and how it is used. There you will also find information on how to contact Facebook, and on the settings available for advertisements. The guidelines on data use are available by following the link below:

https://de-de.facebook.com/about/privacy

You can find the complete Facebook data guidelines here:

https://www.facebook.com/about/privacy    

Facebook does not conclusively and clearly state in what way Facebook uses the data from visits to Facebook pages for its own purposes, to what extent activities on the Facebook page are attributed to individual users, how long Facebook stores such data, and whether data from a visit to the Facebook page are passed on to third parties, and we do not have this information.

The IP address assigned to your device is transmitted to Facebook when you access a Facebook page. According to Facebook, this IP address is anonymised (in the case of “German” IP addresses), and is deleted after 90 days. Facebook also stores information about its users’ devices (e.g. as part of the “Login notification” function); Facebook is thus able to attribute IP addresses to individual users if necessary.

If you are currently logged in to Facebook as a user, a cookie with your Facebook identification is stored on your device. This enables Facebook to identify that you have visited this page and how you have used it. This also applies to all other Facebook pages. Via Facebook buttons integrated into websites, Facebook is able to record your visits to these websites and attribute them to your Facebook profile. These data can be used to offer content or advertising that is tailored to you.

If you wish to prevent this happening, you should log out of Facebook and turn off the “Keep me logged in” feature, delete the cookies on your device, then close and restart your browser. This will delete Facebook information that can be used to directly identify you. This allows you to use our Facebook pages without revealing your Facebook identification. When you access interactive features of the site (Like, Comment, Share, Messages, etc.), a Facebook login screen will appear. After you have logged in, you will again be recognisable to Facebook as a specific user.

(2) Using Facebook Insights

When operating our Facebook pages, Facebook provides us with so-called page insights. The processing of the Insights data is based on an agreement for the joint processing of personal data which we have entered into with Facebook Ireland Limited (“Facebook”).

a) The purposes of processing

The processing of personal data generated by Insights is intended to enable us to obtain statistics that Facebook compiles on the basis of visits to our Facebook pages. This enables us to learn about the profiles of visitors who like our Facebook pages, or who use our applications, in order to be able to provide them with relevant content and develop features that might be of greater interest to them.

We are able in particular to obtain demographic and geographical data about our target group which can inform us for example about where specific advertising campaigns should be carried out, and very generally enable us to make the information that we offer as targeted as possible. The visitor statistics compiled by Facebook are only transmitted to us in anonymised form. We also use the Facebook page to communicate with Facebook users or prospective users, and to inform them about offers and activities. If we receive personal data in this context, they will be exclusively processed for the purpose of the respective communication and interaction.

b) The legal basis for processing

The purposes mentioned above also give rise to our legitimate interest in data processing on the basis of Article 6(1)(f) GDPR.

c) Processing of data outside the EU

It is possible that user data may also be processed outside the area of the European Union by Facebook, Inc., based in the USA.

d) Facilities for lodging objections

Facebook users can change the settings for advertising preferences in order to influence the extent to which their user behaviour may be recorded when visiting our Facebook pages. Further options are offered by the Facebook settings or in the form for the right to object. General information can be found in Facebook’s data policy.

e) Rights of data subjects

Since only Facebook has complete access to your user data, we recommend that you contact Facebook directly if you have requests for information or other concerns regarding your rights as a data subject. If you no longer wish the data processing described here to take place in the future, please remove the link between your user profile and our site by using the functions “Unlike” and/or “Unfollow”.

You can find information on the following Facebook support pages on how to manage or delete existing information concerning you:

https://de-de.facebook.com/about/privacy

As the provider of the information service, we do not process any other data from your use of our service.

Twitter account

We process personal data ourselves via our Twitter accounts (see below under 2), and at the same time data are processed by Twitter (see immediately under 1).

1. Data processed by Twitter

We use the technical platform and services of Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A. for the short messaging service offered here. Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, is responsible for the data processing of persons living outside the United States.

Please note that you use the Twitter short messaging service offered here and its functions on your own responsibility. This particularly applies to the use of the interactive functions (e.g. sharing, rating).

Please refer to Twitter’s Privacy Policy to find out which data are processed by Twitter, and for what purposes they are used:

https://twitter.com/de/privacy

We have no influence on the type and scope of the data processed by Twitter, the type of processing and use, or the transfer of these data to third parties. Nor do we have any effective means of control in this respect.

When you use Twitter, your personal data will be collected, transferred, stored, disclosed and used by Twitter, Inc., and will be transferred, stored and used in the United States, Ireland and any other country where Twitter, Inc. does business, regardless of your place of residence.

Twitter processes your voluntarily entered data such as name and user name, e-mail address, telephone number or the contacts in your address book when you upload or synchronise them.

Twitter however also evaluates the content that you share, based on what topics you are interested in. It stores and processes confidential messages that you send directly to other users, and can determine your location based on GPS data, wireless network information or your IP address in order to send you advertising or other content.

Twitter, Inc. may use analysis tools such as Twitter or Google Analytics for evaluation purposes under certain circumstances. We have no influence on the use of such tools by Twitter, Inc., and have also not been informed about such potential use. If tools of this kind are used by Twitter, Inc. for our accounts, we have neither commissioned nor approved this or supported it in any other way. Nor will the data obtained during the analysis be made available to Twitter. Only specific, non-personal information about Tweeting activity, such as the number of profile or link clicks through a particular Tweet, can be viewed by us via our accounts. Furthermore, we have no way of preventing or deactivating the use of such tools on our Twitter accounts.

Finally, Twitter also receives information when you view content, for example, even if you have not created an account. These “log data” may include your IP address, browser type, operating system, information about the website and pages you previously visited, your location, your mobile operator, the device you are using (including device ID and application ID), the search terms that you used, and cookie information.

Twitter buttons or widgets integrated into websites, and the use of cookies, enable Twitter to record your visits to these websites and attribute them to your Twitter profile. These data can be used to offer content or advertising tailored to you.

You can limit the processing of your data in the general settings of your Twitter account, as well as in the section on “Privacy and safety”. In addition, for mobile devices (smartphones, tablet computers), you can restrict Twitter’s access to contact and calendar data, photographs, location data, etc., in the settings there. This however depends on the operating system used.

More information on these points is available on the following Twitter support pages:

https://support.twitter.com/articles/105576#

https://help.twitter.com/de/search?q=datenschutz

You can find out here about the possibility of viewing your own data on Twitter:

https://support.twitter.com/articles/20172711#

You can find information here about the conclusions drawn by Twitter about you:

https://twitter.com/your_twitter_data

You can find information here on the available personalisation and data protection settings (with further references):

https://twitter.com/personalization

You also have the option of requesting information via the Twitter data protection form or the archive requirements:

https://support.twitter.com/forms/privacy

https://support.twitter.com/articles/20170320#

2. Data processed by the DVV

The DVV also processes your data.

a) Purpose and legal basis

The processing is carried out for the purposes of our public relations work, namely to inform the public about the activities of the DVV (Article 6(1)(f) GDPR).

b) Recipients

The recipient of the data is initially Twitter, where they may be passed on to third parties for their own purposes and under the responsibility of Twitter. The recipient of publications is also the public, i.e. potentially anyone.

c) Categories of personal data

We do not collect any data about our Twitter accounts ourselves. Nor does the integration of our tweets on our website result in the IP addresses of visitors to the site being transmitted to Twitter, Inc.

However, the data that you enter on Twitter, in particular your user name and the content published under your account, will be processed by us to the extent that we retweet or reply to your tweets, if applicable, or that we write tweets from us that refer to your account. The data that you freely publish and distribute on Twitter are thus included by us in our website and made accessible to our followers.

d) Rights, documentation

You may assert your rights to information, restriction of processing, objection, rectification or erasure of data by contacting our data protection officer.

14. Data protection regulations for the use of YouTube and Google Maps

Integration of YouTube videos

The controller has integrated components of YouTube on this website. YouTube is an Internet video portal enabling video publishers to post video clips free of charge, and other users to view, rate and comment on them, also free of charge.

YouTube allows the publication of all kinds of videos, so that both complete film and television programmes, as well as music videos, trailers or videos made by users themselves, are available via the Internet portal.

YouTube is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Every time someone visits one of the individual pages of this website which is operated by the controller and on which a YouTube component (YouTube video) has been integrated, the browser on the data subject’s IT system is automatically instructed by the respective YouTube component to download an image of the relevant YouTube component from YouTube.

More information about YouTube is available at www.youtube.com/intl/en/yt/about/. YouTube and Google learn as part of this technical procedure what specific sub-page of our website the data subject has visited.

If the data subject is logged in to YouTube at the same time, YouTube recognises each time the data subject visits a sub-page which contains a YouTube video what specific sub-page of our website the data subject visits. This information is collected by YouTube and Google and traced to the respective YouTube account belonging to the data subject.

YouTube and Google always receive information via the YouTube component that the data subject has visited our website if the data subject is at the same time logged in to YouTube when visiting our website; this takes place regardless of whether or not the data subject clicks on a YouTube video. If the data subject does not wish this information to be transmitted to YouTube and Google, he or she can prevent such transmission by logging out of their YouTube account before visiting our website.

The Privacy Policy published by YouTube, which is available at https://policies.google.com/privacy?hl=dengl=en, provides information on the collection, processing and use of personal data by YouTube and Google.

Google Maps

We use the services of Google Maps on this website.

This allows you to search for our locations. Interactive maps are displayed directly on the website, making it convenient for you to use the map function. When you visit the website, Google is informed that you have accessed the relevant subpage of our website.

In addition, the data will be transmitted that are mentioned in this Policy regarding your visit to the website and purpose of data use. This takes place regardless of whether Google provides a user account through which you are logged in, or no user account exists. If you are logged in to Google, your data will be attributed directly to your account.

If you do not wish to be linked to your profile on Google, you must log out before activating the button. Google stores your data as user profiles, and uses them for the purposes of advertising, market research and/or the appropriate design of the Google website. Such evaluation is carried out in particular (even for users who are not logged in) in order to provide advertising tailored to your needs, 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, in which case you must contact Google in order to exercise this right.

Further information on the purpose and scope of the collection and processing of data by the plug-in provider can be found in the Privacy Policy of the provider Google. There you will also find further information concerning your rights and settings to protect your privacy: policies.google.com/privacy

15. Automated decision-making

As a responsible organisation, we do not use automated decision-making or profiling.

16. Amendments to our Data Protection Policy

We herewith reserve the right to amend or update this Data Protection Policy where necessary in accordance with the applicable data protection regulations.

This enables us to adapt them to current legal requirements and to take account of changes in our services, for example when introducing new services. The most recent version applies to each visit by you.

DVV International operates worldwide with more than 200 partners in over 30 countries.

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