With the following information we would like to give you as a “person concerned” an overview of the processing of your personal data by us and your rights under data protection laws. It is generally possible to use our website(s) without entering personal data. However, if you wish to make use of special services of our company, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we will generally always obtain your consent.
This policy applies to our website and our “Intao” branded services operated by T-shaped Learning Solutions GmbH.
Personal data, such as your name, address or email address, is always processed in accordance with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to “T-shaped Learning Solutions GmbH”. By means of this data protection declaration, we would like to inform you about the scope and purpose of the personal data collected, used and processed by us.
As the data controller, we have implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are also free to transmit personal data to us by alternative means, for example by telephone or post.
2. Data Controller
The data controller within the meaning of the GDPR is:
T-shaped Learning Solutions GmbH, Melanchthonstrasse 23, 10557 Berlin, Germany
Phone: +49 (0) 30 56 79 49 56
Head of the responsible office: Kathrin Krönig
3. Definitions of terms
a. Personal data
Personal data is any information relating to an identified or identifiable natural person. A natural person shall be considered identifiable if he can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one of the more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
b. Data subject
Data subject is any identified or identifiable natural person whose personal data is processed by the data controller (our company).
Processing means any operation or set of operations which is carried out with or without the aid of automated processes and which relates to personal data, such as collection, recording, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or association, qualification, erasure or destruction.
d. Restriction of processing
Restriction of processing is the tagging of stored personal data with the aim of restricting your future processing.
Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movement of that natural person.
Pseudonymisation means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data is not attributed to an identified or identifiable natural person.
g. Data processor
A data processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not that person is a third party. However, authorities which may receive personal data in the course of a specific investigation task under Union law or the law of the Member States shall not be considered as recipients.
i. Third party
Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or processor.
Consent shall mean any voluntary, informed and unambiguous expression by the data subject of his or her will in the particular case, in the form of a statement or other unequivocal confirmatory act, indicating that he or she consents to the processing of his or her personal data.
4. Legal basis of processing
Art. 6 para. 1 lit. a GDPR serves our company as a legal basis for processing operations in which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which you are a party, this is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 para. 1 lit. b GDPR. The same applies to such processing operations that are necessary for the implementation of precontractual measures, such as in cases of inquiries regarding our products or services.
If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 para. 1 lit. c GDPR.
In rare cases, the processing of personal data may become necessary to protect the vital interests of the data subject or another natural person. For example, if a visitor to our facility is injured and his or her name, age, health insurance information, or other vital information needs to be shared with a physician, hospital, or other third party. Then the processing would be based on Art. 6 para. 1 lit. d GDPR.
Ultimately, processing operations could be based on Article 6 para 1 lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the data subject do not predominate. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if you are a customer of our company (recital 47 sentence 2 GDPR).
5. Data security
T-shaped applies appropriate security measures to protect personal data from unauthorized access or alteration, disclosure or destruction. These measures include, but are not limited to, an internal review of our data collection, storage and processing practices and technical and organisational security measures to protect against unauthorised access to systems in which we store such sensitive data. All collected data is stored in Frankfurt/M. – at the AWS location EU (Frankfurt). Thus the strict level of protection of the EU data protection basic regulation and the German Federal Data Protection Act (BDSG) applies. AWS is the cloud provider Amazon Web Services Inc. (410 Terry Avenue North, Seattle WA 98109, USA); this only offers the server platform. AWS is certified according to German IT basic protection by the TÜV Austria Group (https://www.tuv.at/tuev-austria-gruppe/wir-ueber-uns/). Further detailed information on data protection at AWS can be found at https://aws.amazon.com/de/data-protection/ and https://aws.amazon.com/compliance/resources/.
6. Data collection and use
6.1. Contact / Contact form on our website
Within the scope of contacting us (e.g. via contact form or email), personal data is collected. Which data is collected in the case of a contact form, is apparent from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for establishing contact and the associated technical administration. The legal basis for the processing of the data is our legitimate interest in responding to your request pursuant to Art. 6 para. 1 lit. f GDPR. If the purpose of your contact is to conclude a contract, the additional legal basis for processing is Art. 6 Para. 1 lit. b GDPR. Your data will be deleted after the final processing of your request; this is the case if it can be inferred from the circumstances that the facts in question have been conclusively clarified and there are no legal storage obligations to the contrary.
6.2. Invitation to use our app
In order to use the app, we or one of our customers must invite you by entering your email in our system, which then generates an invitation email. This means that your email address must already be known to us or our customer.
If we invite you to use the app, this means that we do so because you have explicitly expressed interest in the app or because you are already our customer.
If one of our customers invites you to use the app, T-shaped acts as an data processor. We are not responsible that our customers have legitimately purchased the emails and are authorized to use them.
Of course, your rights remain unaffected and you can object to us storing your data at any time.
You can register on our platform to use our services. We only use the data entered for this purpose for the purpose of using the respective offer for which you have registered. The mandatory data requested during registration, such as name and email address, must be provided, otherwise the registration cannot be completed.
For important changes, for example in the scope of our services or in the case of technically necessary changes, we will use the email address provided during registration to inform you in this way.
The data entered during registration will be processed on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent at any time. For this purpose, an informal email notification to us is sufficient. The legality of the data processing already carried out remains unaffected by the revocation.
The data collected during registration will be stored by us as long as you are registered for our services and will subsequently be deleted. Legal retention periods remain unaffected.
6.4. Metadata of the Services
When an authorized user interacts with the Services, metadata is generated that provides additional context about the way authorized users work. For example, we log sparks, topics, what content you interact with, and how often you use the app. We work with a third party to collect this information:
100 California Street
San Francisco, CA 94111
We chose Segment because the company is GDPR compliant and enables us to protect the rights of our users. It is not possible to contradict this aspect of data collection. If you do not agree to this, please refrain from using our service.
6.5. Instrument data
T-shaped may collect data about the device on which the Services are being used, including the type of device, operating system used, device settings, application identifiers, unique device names, and crash information. Which of these Other Information we collect often depends on the type of device used and its settings.
6.6. Cookie information
6.7. Log data
As with most Web sites and technology services provided over the Internet, our servers automatically collect information and record it in log files whenever you access or use our Web sites or services. This log data may include, for example, your IP address, the address of the website you visited before using the website or services, browser type and settings, the date and time you used the services, information about your browser configuration and about plug-ins, language settings and cookie data.
7.1. SSL/TLS encryption
Our websites use SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognize an encrypted connection by the fact that in the address line of the browser there is a “https://” instead of a “http://” and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
8.1. General information about cookies
Information is stored in the cookie, which results in each case in connection with the specifically used terminal device. This does not, however, mean that we will immediately become aware of your identity.
In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your terminal for a specific period of time. If you visit our site again in order to use our services, it is automatically recognized that you have already been with us and which inputs and settings you have made so that you do not have to enter them again.
The data processed by cookies are necessary for the purposes mentioned to safeguard our legitimate interests and those of third parties in accordance with Art. 6 para. 1 S. 1 lit. f GDPR.
Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. Complete deactivation of cookies may, however, prevent you from using all the functions of our website.
9. Our activities in social networks
To communicate with you in social networks and to inform you about our services, we are represented there with our own pages. We are not the original provider (responsible) of these pages, but use them only within the framework of the possibilities offered to us by the respective providers.
Therefore we would like to point out as a precaution that your data may also be processed outside the European Union or the European Economic Area. A use can have therefore data protection risks for you, since the protection of your rights can be difficult e.g. on information, deletion, contradiction, etc. and the processing in the social networks frequently takes place directly for advertising purposes or for the analysis of the user behavior by the offerers, without this can be influenced by us. If the provider creates user profiles, cookies are often used or the user behaviour is assigned directly to your own member profile of the social networks (if you are logged in here).
The processing operations of personal data described are carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest and the legitimate interest of the respective provider in order to communicate with you in a modern manner or to inform you about our services. If you have to give your consent to data processing as a user with the respective provider, the legal basis refers to Art. 6 para. 1 lit. a GDPR in conjunction with Art. 6 para. 1 lit. a GDPR. Art. 7 GDPR.
As we do not have access to the data stocks of the providers, we would like to point out that your rights (e.g. to information, correction, deletion, etc.) are best exercised directly by the respective provider. Further information on the processing of your data in the social networks and the possibility of your right of objection or revocation (so-called opt-out) to make use of, we have listed below with the respective provider of social networks used by us:
Responsible for data processing in Europe:
Facebook Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Opt-Out and advertising settings: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
Facebook has joined the EU-U.S. Privacy Shield Agreement: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active https://de-de.facebook.com/about/privacy/
Responsible for data processing in Europe:
LinkedIn Ireland Unlimited Company
Opt-out and advertising settings: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
LinkedIn has joined the EU-U.S. Privacy Shield Agreement: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active
Responsible for data processing in Europe:
Twitter International Company
One Cumberland Place
Dublin 2, D02 AX07
Opt-out and advertising settings:
Twitter has joined the EU-U.S. Privacy Shield Agreement: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active
10. Social Media Plugins
10.1. Facebook Plugin
We have integrated components of the company Facebook on this website. Facebook is a social network. A social network is an Internet-based social meeting place, an online community that usually enables users to communicate with each other and interact in a virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enables the Internet community to provide personal or company-related information. Facebook enables users of the social network to create private profiles, upload photos and network via friend requests.
The operating company of Facebook is Facebook, Inc. 1 Hacker Way, Menlo Park, CA 94025, USA. The person responsible for processing personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland if a person concerned lives outside the USA or Canada.
Each time you access one of the individual pages on this website, which is operated by us and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on your IT system is automatically prompted by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=en_DE. As part of this technical process, Facebook obtains information about which specific subpage of our website is visited by you.
If you are logged in to Facebook at the same time, Facebook recognizes which specific page of our website you are visiting each time you visit our website and for the entire duration of your stay on our website. This information is collected by the Facebook component and assigned to the respective Facebook account by Facebook. If you click on one of the Facebook buttons integrated on our website, for example the “Like” button, or if you make a comment, Facebook assigns this information to your personal Facebook user account and saves this personal data.
Facebook receives information through the Facebook component that you have visited our website whenever you are logged into Facebook at the same time as you visit our website, regardless of whether or not you clicked on the Facebook component. If you do not want this information to be shared with Facebook, you can prevent it from being shared by logging out of your Facebook account before visiting our website.
Facebook’s published data policy, which is available at https://de-de.facebook.com/about/privacy/, provides information about Facebook’s collection, processing and use of personal data. It also explains what settings Facebook offers to protect your privacy. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by you to suppress data transmission to Facebook.
10.2. LinkedIn Plugin
We have integrated components from LinkedIn Corporation on this website. LinkedIn is an Internet-based social network that allows users to connect to existing business contacts and make new business contacts.
Each time you visit a LinkedIn component (LinkedIn plug-in) on our website, the LinkedIn component causes the browser you are using to download an appropriate representation of the LinkedIn component. More information about the LinkedIn plug-ins can be found at https://developer.linkedin.com/plugins. As part of this technical process, LinkedIn will know which specific page on our website you have visited.
If you are logged in to LinkedIn at the same time, LinkedIn recognizes which specific page of our website you are visiting each time you access our website and for the entire duration of your stay on our website. This information is collected by the LinkedIn component and assigned to your LinkedIn account by LinkedIn. If you press a LinkedIn button integrated on our website, LinkedIn assigns this information to your personal LinkedIn user account and saves this personal data.
LinkedIn always receives information via the LinkedIn component that you have visited our website if you are logged in to LinkedIn at the same time as accessing our website; this takes place regardless of whether you clicked on the LinkedIn component or not. If you do not want LinkedIn to receive this information, you can prevent it by logging out of your LinkedIn account before accessing our website.
10.3. Twitter Plugin
We have integrated Twitter components on this website. Twitter is a multilingual, publicly accessible microblogging service on which users can publish and distribute so-called tweets, i.e. short messages limited to 140 characters. These short messages can be accessed by anyone, including people not registered on Twitter. However, the tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter makes it possible to address a broad audience via hashtags, links or retweets.
The operating company of Twitter is Twitter, Inc. 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.
Each time one of the individual pages of this website is opened, which is operated by us and on which a Twitter component (Twitter button) has been integrated, the Internet browser on your IT system is automatically prompted by the respective Twitter component to download a representation of the corresponding Twitter component from Twitter. Further information on the Twitter buttons can be found at https://about.twitter.com/de/resources/buttons. As part of this technical process, Twitter receives information about which specific subpage of our website you are visiting. The purpose of integrating the Twitter component is to enable our users to disseminate the content of this website, to make this website known in the digital world and to increase our visitor numbers.
If you are logged in to Twitter at the same time, Twitter recognizes which specific page of our website you are visiting each time you access our website and for the entire duration of your stay on our website. This information is collected by the Twitter component and assigned to your Twitter account by Twitter. If you press one of the Twitter buttons integrated on our website, the data and information transmitted will be assigned to your personal Twitter user account and stored and processed by Twitter.
Twitter always receives information via the Twitter component that you are visiting our website if you are logged in to Twitter at the same time as accessing our website; this takes place irrespective of whether you click on the Twitter component or not. If you do not want this information to be transmitted to Twitter in this way, you can prevent it from being transmitted by logging out of your Twitter account before accessing our website.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and inform you about your rights of objection. By subscribing to our newsletter, you declare that you agree with the receipt and the described procedures.
11.1. Content of the newsletter
We send newsletters, emails and other electronic notifications containing advertising information (hereinafter referred to as “newsletters”) only with your consent or legal permission. If the contents of the newsletter are specifically described during registration, the consent of the user is authoritative. In addition, our newsletters contain information about our services and us.
11.2. Double-Opt-In and logging
The registration to our newsletter takes place in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after your registration in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise the changes of your data stored with the dispatch service provider are logged.
11.3. Login details
To subscribe to the newsletter, it is sufficient to enter your email address. Optionally we ask you to enter a name in the newsletter for the purpose of a personal address.
The dispatch of the newsletter and the performance measurement associated with it are based on the consent of the recipients in accordance with Art. 6 Para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 Para. 2 No. 3 Act against Unfair Practices (UWG) or, if consent is not required, on our legitimate interests in direct marketing in accordance with Art. 6 Para. 1 lt. f. GDPR in connection with § 7 Abs. 3 Act against Unfair Practices (UWG).
The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and furthermore allows us to provide evidence of consent.
11.4. Termination / Revocation
You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that we have previously given our consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
11.5. Newsletter Drip
The dispatch service provider can use the data of the recipients in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
12. Web analytics
12.1. Google Analytics
On our web pages we use Google Analytics, a web analysis service of Google Ireland Limited (https://www.google.de/intl/de/about/) (Gordon House, Barrow Street, Dublin 4, Irland; hereinafter referred to as “Google”). In this context, pseudonymised user profiles are created and cookies (see section 4) are used. The information generated by the cookie about your use of this website such as
- Browser type/version,
- Operating system used,
- Referrer URL (the previously visited page),
- Host name of the accessing computer (IP address),
- Time of the server request,
are transferred to a Google server in the USA and stored there. This information is used to evaluate the use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage for market research purposes and to tailor these internet pages to meet requirements. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of third parties. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymised so that an allocation is not possible (IP masking).
The use of Google Analytics is in the interest of optimising and tailoring our website to suit your needs. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).
As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting this data by clicking on the following link: Disable Google Analytics. An opt-out cookie is set to prevent your data from being collected in the future when you visit this website. The opt-out cookie applies only to this browser and only to our website and is placed on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.
You can find further information on data protection in connection with Google Analytics in the Google Analytics help (https://support.google.com/analytics/answer/6004245?hl=en).
13. Your rights as a data subject
13.1. Right of confirmation
You have the right to request confirmation from us as to whether personal data concerning you will be processed.
13.2. Right of information Art. 15 GDPR
You have the right at any time to receive free information from us about the personal data stored about you and a copy of this data.
13.3. Right of rectification Art. 16 Art. GDPR
You have the right to request the correction of any inaccurate personal data concerning you. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.
13.4. Deletion Art. 17 GDPR
You have the right to demand that we delete your personal data immediately if one of the statutory reasons applies and if processing is not necessary.
13.5. Restriction of processing Art. 18 GDPR
You have the right to demand that we restrict processing if one of the legal requirements is met.
13.6. Data transferability Art. 20 GDPR
You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. You also have the right to transfer this data to another data controller to whom we have provided the personal data without obstruction, provided that the processing is based on the consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and the processing is carried out using automated procedures, provided that the processing is not necessary for the performance of a task which is in the public interest or which is carried out in the exercise of official authority assigned to us.
Furthermore, when practicing your right to data transferability pursuant to Art. 20 para. 1 GDPR, you have the right to obtain that the personal data be transferred directly from one responsible party to another responsible party, insofar as this is technically feasible and insofar as this does not impair the rights and freedoms of other persons.
13.7. Contradiction Art. 21 GDPR
You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 para. 1 lit. e (data processing in the public interest) or f (data processing on the basis of a weighing of interests) GDPR.
This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 GDPR.
If you file an objection, we will no longer process your personal data unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves the assertion, practice or defense of legal claims.
In individual cases, we process personal data in order to conduct direct advertising. You can object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling as far as it is connected with such direct advertising. If you object to us processing your personal data for direct marketing purposes, we will no longer process your personal data for these purposes.
In addition, you have the right to object to the processing of personal data relating to you, which is carried out by us for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR, for reasons arising from your particular situation, unless such processing is necessary to fulfill a task in the public interest.
You are free to exercise your right of objection in connection with the use of information of the society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.
13.8. Revocation of consent under data protection law
You have the right to revoke your consent to the processing of personal data at any time with effect for the future.
13.9. Complaint to a supervisory authority
You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.
14. Routine storage, deletion and blocking of personal data
We process and store your personal data only for the period of time necessary to achieve the storage purpose or as required by the laws to which our company is subject.
If the storage purpose no longer applies or a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.