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Privacy Policy

Privacy Policy

 

Data controller in accordance with Art. 4(7) GDPR

The data controller (hereinafter “we”) responsible for the lawful processing of your personal data on this website is:

Sprachschule KAPITO GmbH,

as represented by the directors Annegret Paikert and Hansgerd Schomacher,

Servatiiplatz 9

Münster

Tel.: +49 251-981197-0

Fax: +49 251-981197-10

Mail: info@kapito.com

This policy sets out the legal basis on which we process personal data that we collect from you when you access our website. Personal data is all data related to you, e.g. name, address, e-mail addresses and user behavior.

We process your personal data in the following ways:

Collection of personal data when accessing our website for informational purposes only

When you access our website for purely informational purposes, i.e. without registering or otherwise submitting information to us, we only collect the personal data that your browser transmits to our server. When you view our website, we collect data that we need on technical grounds to make our website available to you and to guarantee its stability and security (in accordance with Article 6(1)(1)(f) GDPR). The data we collect is as follows:

  • IP address
  • Date and time of request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of request (the specific page)
  • Access status/HTTP status code
  • Volume of data transmitted
  • Website from which the request originated
  • Browser
  • Operating system and its interface
  • Language and version of browser software.

This data is stored in log files on our server. No other data belonging to you is stored with this data. The legal basis is Art. 6(1)(1)(f) GDPR.

The data is deleted when it is no longer necessary for the purpose for which it was collected. Data collected in order to display the website on your computer is deleted when your session ends. Data stored in the log files is deleted within seven days. Data may be stored for longer. In that case your IP address will be deleted or modified so that it is not possible to link the data to your requesting client computer.

When you use our website, cookies will be stored on your computer. Cookies are small text files stored on your hard drive by the web browser you are using, enabling information to be collected by the website owner who sets the cookie (in this case us). Cookies cannot execute programs or transmit viruses onto your computer. They are designed to make our internet service generally more user-friendly and effective. The legal basis is Art. 6(6)(1)(f) GDPR.

This website uses transient cookies and persistent cookies.

Transient cookies are automatically deleted when you close your browser. These include session cookies. They store a “session ID” which allows requests from your browser to be assigned to a single session so that your computer can then be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.

Persistent cookies are deleted automatically after a specified length of time, which may differ depending on the cookie. You can delete the cookies at any time in your browser’s security settings.

You can configure your browser settings according to your needs and disable third-party cookies or all cookies, for example. However, you may not be able to use all the functions of this website.

Flash cookies are not collected by your browser but by your Flash plugin. We also use HTML5 storage objects, which are stored on your computer. These objects store the data that they require independently of which browser you are using and have no automatic expiry date. If you do not want Flash cookies to be processed, you have to install an appropriate add-on, e.g. Adobe Flash Killer Cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using your browser in private mode.  We also recommend manually deleting cookies and your browser history regularly.

Booking courses and accommodation

If you wish to register an interest in one of our courses, you can contact us via the online contact form in the “Registration” section.

If you wish to book one of our courses, submission of your personal data is required for contract completion and to process your booking. The fields that are a contractual requirement are marked separately. All other information is optional. We use the data submitted by you to process your booking. The legal basis is Art. 6(1)(1)(b) GDPR.

We will submit your data to the host of your accommodation and, should you require transport, to the relevant transfer service provider, as far as contractually required. We also submit your data to the teacher of the language course, as far as is contractually required. In order to process your payment we submit your payment details to our bank as well as to the bank authorized to process your payment, if applicable. The legal basis is Art. 6(1)(1)(b) GDPR.

 In the case of payment default we will disclose, if applicable, the requisite information for debt collection to a debt collection agency instructed by us. The legal basis is Art. 6(1)(1)(b) GDPR. It is in our legitimate commercial interest to collect debts through a debt collection agency.

The data that we collect through the booking form and store for performance of the contract will be erased as soon as storage is no longer required, or, if there are statutory obligations with regard to data retention (e.g. under commercial or tax law), we will restrict processing of the data.

You are neither legally nor contractually obliged to provide us with your personal data. However, we can only accept your booking if all the mandatory fields are filled out.

Contact form and informational material

If you contact us by using the contact form we process the data you have submitted in order to deal with your enquiry.

In order to respond to your enquiry we need you to enter the relevant personal data. Mandatory fields are marked separately. All other fields are optional. You can request information about our language school by using the field marked “Please send me information about KAPITO”.

We only collect personal data that you send us via the contact form or email in order to respond to your enquiry or to send you material, if requested. The legal basis is Art 6(1)(1)(f) GDPR. We have a legitimate commercial interest in making contact with potential customers and interested parties via the contact form or email. Our contact form and the option to request informational material is a service that we provide to enable you as a (potential) customer or candidate to make contact with us quickly and easily, allowing us to offer you excellent customer service. Enquiries via the contact form often lead to a contractual relationship.

The data transmitted by you when you contact us via the contact form or email or that we store in oder to respond to your enquiry will be erased as soon as storage is no longer required, or, if there are statutory obligations with regard to data retention (e.g. under commercial or tax law), restrictions will be placed on the processing of the data.

You are neither legally nor contractually obliged to provide us with your data. However, we can only respond to your enquiry if all the mandatory fields (marked *) are filled out.

Google Analytics

Our website uses Google Analytics, a web analysis service provided by Google Inc. ( “Google”). Google Analytics uses “cookies”, text files that are placed on your computer and help our website analyse how you use the site. The information generated by the cookie about your use of this website will as a rule be transmitted to and stored by Google servers in the USA. IP anonymization has been activated on this website so that Google will shorten IP before transmission from addresses in European Member States or from other states contracting to the European Economic Area. Only in exceptional cases will the full IP address be transmitted to Google servers in the USA and shortened there. On behalf of the operator of this website, Google will use this information to analyze your use of the website to compile reports on website activity and provide other services relating to website activity and internet usage for us.

You can prevent cookies being stored by selecting the corresponding settings in your browser software. We advise, however, that you may not be able to use the full functionality of this website in this case. You may also prevent the gathering of data generated by the cookie relating to your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

We use Google Analytics to analyze and regularly improve the use of our website. Using the statistics obtained, we can improve our service and make it more relevant to you as a user. In the exceptional case where personal data is transmitted to the USA, Google is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for use of Google Analytics is Art. 6(1)(1)(f) GDPR.

Third-party provider information: Google Dublin, Google Ireland Ltd. (hereinafter “Google”), Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. You can find their terms of use and privacy policy on the Google website (www.google.de).

Google Adwords conversion tracking

We use advertising media services provided by Google Adwords to raise the profile of our website on external websites. By evaluating the data collected through advertising campaigns, we can determine how successful our individual advertising activities are. We can then display advertising which is of interest to you, make our website more attractive to you personally and calculate advertising costs fairly.

Google provides these advertising media services via its “ad servers”. We make use of these services through ad server cookies which assess performance parameters such as ads displayed or the number of clicks. If you access our website via a Google ad, Google Adwords places a cookie on your computer. These cookies usually lose their validity after 30 days and are not intended to identify you personally. The values usually stored by this cookie are; a unique cookie ID, the number of ad views per page view (frequency), the last view (relevant for post-view conversions) and opt-out information (the user indicates that they no longer want to be contacted).

These cookies enable Google to determine when your internet browser has already visited a website. If a user visits certain pages of the website of an Adwords customer and the cookie stored on the user’s computer has not yet expired, Google and the customer can see that the user clicked on an advertisement and was forwarded to this page. Each Adwords customer is assigned a different cookie. Cookies therefore cannot be tracked across the websites of Adwords customers. We do not ourselves collect or process any personal data from these advertising activities. We only receive statistical assessments made available by Google. Using these assessments, we can tell which of the advertising activities carried out are most effective. We do not obtain any further data from the use of advertising, nor, in particular, are we able to identify users from this information.

Because of the marketing tools used, your browser automatically forms a direct connection to Google’s server. We have no influence over the amount or further use of the data collected through the use of this tool by Google and therefore can inform you of the situation as far as we know it: by integrating AdWords Conversion, Google receives notification that you have accessed the corresponding part of our website or have clicked on one of our adverts. If you have registered for 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 for a Google's contractual partners, third parties and authorities to find out and store your IP address.

You can prevent yourself from being included in this tracking procedure in various ways, as follows:

a) by managing your browser software settings accordingly, in particular by disabling third party cookies, you will not receive any advertising from third parties;

b) by disabling conversion tracking cookies by setting your browser to block cookies from the www.googleadservices.com domain, www.google.de/settings/ads, although it should be noted that this setting will be deleted if you delete your cookies;

c) by disabling the interest-based ads from providers that are part of the  self-regulatory About Ads campaign at www.aboutads.info/choices, although it should be noted that this setting will be deleted if you delete your cookies;

d) by permanently deactivating this option in Firefox, Internet Explorer or Google Chrome at www.google.com/settings/ads/plugin. We point out that this may mean you are not be able to use all of the functions on our website to their full extent.

The processing of your data is based on Art. 6 (1)(1)(f) GDPR. You can find further information on Google’s data protection on Google’s website (www.google.de). You can also visit the Network Advertising Initiative (NAI) website at www.networkadvertising.org. Google is subject to the EU-US Privacy Shield ( www.privacyshield.gov).

 

Google Maps

This website uses services provided by Google Maps. This enables us to display interactive maps directly on our website and provides you with easy access to the map functions.

If you visit our website, Google receives the information that you have accessed the corresponding page of our website. In addition, the data referred to under the “collection of personal data when accessing our website for informational purposes only” section of this privacy policy will also be transmitted. This occurs whether you have a Google user account that you are logged in to, or whether you do not have such an account. If you are logged in to Google, your information will be directly associated with your account. If you do not wish your profile to be associated with Google, you must log out before clicking on the button. Google stores the data collected about you as a user profile and uses it for the purposes of advertising, market research and/or website design as required. This data (including that of users who are not logged in) is evaluated in order to develop targeted advertising and to inform users of social networks about your activities on our website. You have the right to object to the creation of this user profile and can exercise this right by contacting Google.

Further information on the scope of data collection and processing by the plug-in and its provider and on the purposes for which it is used can be found in Google’s privacy policies. These also contain further information on your associated rights and on the different privacy protection settings that are available to you. Google’s privacy policy can be found on the Google website (www.google.de).  Google processes your personal data in the USA and is subject to the EU-US Privacy Shield (www.privacyshield.gov)

Link to our Facebook page

We maintain a presence on Facebook in order to communicate with interested parties and to provide information about our language school. Our Facebook page is subject to Facebook’s privacy policy.

Facebook Inc., 1601 S. California Ave, Palo Alto, California 94304, USA. Details about data protection at Facebook can be found on the Facebook website (www.facebook.com). Facebook is subject to the EU US Privacy Shield. Further details can be found on the EU US Privacy Shield website (www.privacyshield.gov).

There is a link to Facebook on our website. Visiting our website and then clicking on the link takes you directly to our Facebook page. Please be aware that by using Facebook your personal data may be processed outside the European Union. In that case, exercising rights under the GDPR can become more difficult. Facebook is subject to the Privacy Shield and therefore has a duty to guarantee a level of protection with regard to your personal data that is similar to that of the GDPR. Unless stated otherwise in this Privacy Policy, we only process your data when you communicate with us within the scope of our Facebook presence, e.g. by commenting on a post on Facebook or when you send a message to us. We only process this personal data for communication purposes, e.g. to respond to your enquiry, in accordance with Art. 6 (1)(1)(f) GDPR. We have a legitimate commercial interest in communicating with (potential) customers and interested parties. Details about how Facebook processes your personal data can be found in Facebook’s privacy policy.

Your right to information under Article 15 GDPR as well as the other rights of the individual as listed below can more effectively be asserted against Facebook as Facebook usually has direct access to the data processed and can provide the relevant information or take appropriate action (e.g. deletion). You can of course submit such a request to us directly. Our contact data is provided at the top of this Privacy Policy.

Recipients of your personal data

Any transfer of your personal data to a third party or processor not mentioned above, will only be carried out if the transfer can be justified on legal grounds or under Art. 28 (3) GDPR.

Transfer of your personal data to third countries

Any transfer of your personal data to a third country – in addition to the third countries mentioned above – will only be carried out if the transfer can be justified on legal grounds and in accordance with Art. 44 ff. GDPR.

SSL/TLS Encryption

This site uses SSL/TLS encryption for security reasons and to protect your personal data. You can recognize an encrypted connection by the "https://" and the lock icon displayed in your browser's address bar.

Data storage period

Unless stated otherwise in this Privacy Policy, we erase any data associated with our website as soon as storage is no longer necessary and it is no longer justified on legal grounds, or restrict data processing if there are statutory obligations with regard to data retention (e.g. under commercial or tax law).

Your rights

You have, and can assert against us, the rights set out below with regard to your personal data:

  • Right of access Art. 15 GDPR
  • Right to rectification Art. 16 GDPR
  • Right to erasure/ Right to “be forgotten”  Art. 17 GDPR
  • Right to restriction of processing, Art. 18 GDPR
  • Right to data portability Art. 20 GDPR
  • Right to lodge a complaint with a regulatory authority Art. 77 GDPR

Further details about your rights can be found in the GDPR articles above. If you have any questions about your rights, please feel free to contact us at the address provided at the top of this Privacy Policy.

Right to object to data processing Art. 21 GDPR

Where we process your personal data based on our legitimate commercial interests, in accordance with Art. 6(1)(1)(f),  you may object to the data processing at any time with future effect. You may object by contacting us at the address at the top of this Privacy Policy. If you raise an objection, please state your reasons. If your objection is justified, we will make an assessment and either stop or modify our data processing, or demonstrate to you that we have “compelling legitimate” grounds for the continued processing of your data.

If we process your personal data for direct marketing purposes, you may object at any time with future effect. If you object to our processing your data for marketing purposes we will stop processing your personal data. You can object by contacting us at the address at the top of this Privacy Policy.

Right to revoke consent to the processing of your data at any time Art. 7(3) GDPR

If you have given your consent to the processing of your personal data, you may revoke this consent at any time. You can revoke your consent by contacting us at the address at the top of this Privacy Policy. The lawfulness of the processing carried out owing to prior consent up till the revocation will not be affected by the revocation of consent.

If you wish to inform us that you have revoked your consent, please contact us at the address at the top of this Privacy Policy.