Foreword
We, CyberCurriculum GmbH, [hereinafter: “the company”, “we” or “us”] take the protection of your personal data seriously and would like to take this opportunity to inform you about data protection in our company.
As part of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”) in order to ensure the protection of personal data of the person affected by processing (we also refer to you as the data subject as “customer”, “user”, “you”, “you” or “data subject”).
A. General information
(1) Definitions
Following the example of Art. 4 GDPR, this data protection notice is based on the following definitions:
“Personal data” (Art. 4 No. 1 GDPR)
is any information relating to an identified or identifiable natural person (“data subject”). A person is identifiable if they can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to their physical, physiological, genetic, mental, economic, cultural or social identity characteristics. Identifiability can also be achieved by linking such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photos, video or audio recordings may also contain personal data).
“Processing” (Art. 4 No. 2 GDPR)
is any process in which personal data is handled, whether with or without the aid of automated (i.e. technology-based) processes. This includes in particular the collection (i.e. procurement), recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, or alteration of the purposes for which they were originally processed.
“Controller” (Art. 4 No. 7 GDPR)
is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Third party” (Art. 4 No. 10 GDPR)
is any natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data; this also includes other legal entities belonging to the group.
“Processor” (Art. 4 No. 8 GDPR)
is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in particular in accordance with the controller’s instructions (e.g. IT service provider). In particular, a processor is not a third party in terms of data protection law.
“Consent” (Art. 4 No. 11 GDPR)
of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
(2) Name and address of the controller
We are the controller responsible for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR:
CyberCurriculum GmbH
Alt-Moabit 73/73A
10555 Berlin
info@cyber-curriculum.com
Further information about our company can be found at Imprint on our website.
(3) Contact details of the data protection officer
Our company data protection officer is available at all times to answer any questions you may have and to act as your contact person on the subject of data protection. His contact details are:
CyberCurriculum GmbH
Alt-Moabit 73/73A
10555 Berlin
E-mail: dsb@cyber-curriculum.com
(4) Legal basis for data processing
In principle, any processing of personal data is prohibited by law and is only permitted if the data processing falls under one of the following justifications:
Art. 6 para. 1 p. 1 lit. a GDPR (“consent”):
If the data subject has voluntarily, in an informed and unambiguous manner, by means of a statement or other unambiguous confirmatory act, indicated that they consent to the processing of their personal data for one or more specific purposes;
Art. 6 para. 1 p. 1 lit. b GDPR:
If the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
Art. 6 para. 1 p. 1 lit. c GDPR:
If the processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a legal obligation to retain data);
Art. 6 para. 1 p. 1 lit. d GDPR:
Where processing is necessary in order to protect the vital interests of the data subject or of another natural person;
Art. 6 para. 1 p. 1 lit. e GDPR:
If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or
Art. 6 para. 1 p. 1 lit. f GDPR (“legitimate interests”):
If the processing is necessary for the purposes of the legitimate interests (in particular legal or economic interests) pursued by the controller or by a third party, except where such interests are overridden by the interests or rights of the data subject (in particular where the data subject is a minor).
For the processing operations we carry out, we indicate the applicable legal basis in each case below. Processing can also be based on several legal bases.
(5) Data erasure and storage duration
For the processing operations we carry out, we indicate below how long we store the data and when it is deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for storage no longer applies. Your data will only be stored on our servers in Germany, subject to any disclosure in accordance with the provisions in A.(7) and A.(8).
However, data may be stored beyond the specified period in the event of an (impending) legal dispute with you or other legal proceedings or if storage is provided for by statutory provisions to which we are subject as the controller (e.g. Section 257 HGB, Section 147 AO). If the storage period prescribed by the statutory provisions expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.
(6) Data security
We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.
We will be happy to provide you with more detailed information on request. Please contact our data protection officer (see under A.(3)).
(7) Cooperation with processors
As with any large company, we also use external domestic and foreign service providers to handle our business transactions (e.g. for IT, logistics, telecommunications, sales and marketing). They will only act in accordance with our instructions and have been contractually obliged to comply with data protection regulations within the meaning of Art. 28 GDPR.
(8) Requirements for the transfer of personal data to third countries
As part of our business relationships, your personal data may be passed on or disclosed to third-party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing is carried out exclusively to fulfill contractual and business obligations and to maintain your business relationship with us. We will inform you about the respective details of the transfer at the relevant points below.
The European Commission certifies that some third countries have a level of data protection comparable to the EEA standard by means of so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible through binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data, certificates or recognized codes of conduct. Please contact our data protection officer (see A.(3)) if you would like more information on this.
(9) No automated decision-making (including profiling)
We do not intend to use personal data collected from you for automated decision-making (including profiling).
(10) No obligation to provide personal data
We do not make the conclusion of contracts with us dependent on you providing us with personal data beforehand. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case within the scope of the products presented below and offered by us, you will be informed of this separately.
(11) Legal obligation to transmit certain data
We may be subject to a special legal or statutory obligation to provide the lawfully processed personal data to third parties, in particular public authorities (Art. 6 para. 1 sentence 1 lit. c GDPR).
(12) Your rights
You can assert your rights as a data subject with regard to your processed personal data at any time by contacting us using the contact details provided at the beginning under A.(2). As the data subject, you have the right to
in accordance with Art. 15 GDPR
to request information about your data processed by us. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us, and the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;
in accordance with Art. 16 GDPR
to demand the immediate correction of incorrect data or the completion of your data stored by us;
in accordance with Art. 17 GDPR
to demand the deletion of your data stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
in accordance with Art. 18 GDPR
to demand the restriction of the processing of your data if the accuracy of the data is disputed by you or the processing is unlawful;
in accordance with Art. 20 GDPR
to receive your data, which you have provided to us, in a structured, commonly used and machine-readable format or to request the transmission to another controller (“data portability”);
in accordance with Art. 21 GDPR
to object to the processing if the processing is based on Art. 6 para. 1 p. 1 lit. e or lit. f GDPR takes place. This is particularly the case if the processing is not necessary for the performance of a contract with you. If it is not an objection to direct advertising, we ask you to explain the reasons why we should not process your data as we have done when exercising such an objection. In the event of your justified objection, we will examine the situation and either discontinue or adapt the data processing or point out to you our compelling reasons worthy of protection on the basis of which we will continue the processing;
pursuant to Art. 7 para. 3 GDPR
to withdraw your consent once given to us at any time (including before the GDPR came into force, i.e. before May 25, 2018) – i.e. your voluntary, informed and unequivocal consent to the processing of the personal data concerned for one or more specific purposes, made clear by a statement or other unambiguous confirmatory act – if you have given such consent. As a result, we may no longer continue the data processing that was based on this consent in the future and
in accordance with Art. 77 GDPR
to complain to a data protection supervisory authority about the processing of your personal data in our company, for example to the data protection supervisory authority responsible for us:
Berlin Commissioner for Data Protection and Freedom of Information
Friedrichstraße 219, 10969 Berlin
E-mail: mailbox@datenschutz-berlin.de.
(13) Changes to the data protection information
As part of the ongoing development of data protection law and technological or organizational changes, our data protection information is regularly reviewed to determine whether it needs to be adapted or supplemented. You will be informed of any changes, in particular on our German website at www.cyber-curriculum.com. This data protection notice is valid as of December 2022.
B. Visiting websites
(1) Explanation of the function
Information about our company and the services we offer can be found in particular at Cyber-Curriculum.com together with the associated subpages (hereinafter jointly referred to as “websites”). When you visit our website, your personal data may be processed.
(2) Processed personal data
We collect, store and process the following categories of personal data when you use the website for information purposes:
“Log data”:
When you visit our website, a so-called log data record (so-called server log files) is temporarily and anonymously stored on our web server. This consists of:
- the page from which the page was requested (so-called referrer URL)
- the name and URL of the requested page
- the date and time of the call
- the description of the type, language and version of the web browser used
- the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
- the amount of data transferred
- the operating system
- the message whether the call was successful (access status/Http status code)
- the GMT time zone difference
“Contact form data”:
When using contact forms, the data transmitted in this way is processed (e.g. gender, surname and first name, address, company, e-mail address, telephone number and the time of transmission).
(3) Purpose and legal basis of data processing
We process the personal data specified above in accordance with the provisions of the GDPR, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 para. 1 p. 1 lit. f GDPR, the aforementioned purposes also constitute our legitimate interests.
The processing of log data serves statistical purposes and to improve the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR).
The processing of contact form data is carried out to process customer inquiries (legal basis is Art. 6 para. 1 sentence 1 lit. b or lit. f GDPR).
(4) Duration of data processing
Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; the legal bases specified in the context of the processing purposes apply accordingly. With regard to the use and storage duration of cookies, please refer to point A.(5) and the cookie policy.
Third parties used by us will store your data on their system for as long as is necessary in connection with the provision of the services for us in accordance with the respective order. You can find more details on the storage period under A.(5) and the Cookie Policy.
(5) Transfer of personal data to third parties; basis for justification
The following categories of recipients, which are usually processors (see A.(7)), may have access to your personal data:
Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing, IT security). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f GDPR, unless they are processors;
Government agencies/authorities, insofar as this is necessary to fulfill a legal obligation. The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. c GDPR;
Persons employed to conduct our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f GDPR.
For guarantees of an adequate level of data protection when data is transferred to third countries, see A.(8).
In addition, we will only pass on your personal data to third parties if you have given your consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR have given their express consent to this.
(6) Use of cookies, plugins and other services on our website
Cookie
We do not use cookies on our websites.
Cookies are small text files that are assigned to the browser you are using and stored on your hard disk by means of a characteristic string of characters and through which certain information flows to the site that sets the cookie. Cookies cannot run programs or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the website more user-friendly and effective overall, i.e. more pleasant for you.
Cookies may contain data that make it possible to recognize the device used. In some cases, however, cookies only contain information on certain settings that are not personally identifiable. However, cookies cannot directly identify a user.
A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:
Technical Cookies:
These are strictly necessary to navigate the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, nor do they store which websites you have visited;
Performance cookies:
They collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect any information that could identify you – all information collected is anonymous and is only used to improve our website and to find out what interests our users;
Advertising cookies, targeting cookies:
These are used to offer the website user needs-based advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;
Sharing cookies:
These are used to improve the interactivity of our website with other services (e.g. social networks); sharing cookies are stored for a maximum of 13 months.
Any use of cookies that is not absolutely technically necessary constitutes data processing that can only be carried out with your express and active consent in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 p. 1 lit. a GDPR is permitted. This applies in particular to the use of advertising, targeting or sharing cookies. In addition, we will only pass on your personal data processed by cookies to third parties if you have given your consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR have given their express consent to this.
(7) meetergo (make an appointment)
We have integrated meetergo on this website. The provider is meetergo GmbH, Hansaring 61, 50670 Cologne (hereinafter referred to as meetergo).
meetergo provides an online appointment scheduling tool. If you make an appointment with us online, the data you enter for this purpose will be stored on meetergo’s servers in Germany.
Furthermore, meetergo briefly records your IP address, your referrer URL, the time of access and can determine that you have made a request to us; this data is used exclusively for the technical provision of the service and is then automatically deleted again.
The use of meetergo is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in making appointments as uncomplicated as possible. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and Art. 9 para. 1 lit. a; consent can be revoked at any time.
(8) Social media presences
Cyber Curriculum operates presences on various social media platforms (“social media presences”). Users can visit our social media presences and find out about us and our services and use various functions (e.g. “liking” social media presences or communicating directly with us via messages).
When users visit our social media presences, they are on the respective social media platform. The respective provider of the social media platform is the controller within the meaning of Art. 4 No. 7 GDPR for the operation of the social media platform. The overview below shows which company is the provider for which social media platform. The processing of your personal data by the respective providers is not known to us in detail and we have no influence on this. Users can find more detailed information on the processing of personal data in the privacy policies of the respective providers. We have provided a direct link to the data protection declarations of the respective providers in the overview below.
In some cases, however, this also involves commissioned processing by the providers. Details can be found in the special notes on the individual providers. In addition, the respective social media platform may collect personal data about users and we may receive statistical evaluations of the use of our social media presence based on the data collected in this way. We may be the “joint controller” for this data collection together with the operator of the social media platform.
On some social media platforms, it is possible to make contact via the messenger functions provided, which the Cyber Curriculum and users can use to exchange messages. We process this data collected via the Messenger functions exclusively for the purposes of communication with the users either for the fulfillment of a contract or for the implementation of pre-contractual measures (pursuant to Art. 6 para. 1 letter b) GDPR) or on the basis of a balancing of interests pursuant to Art. 6 para. 1 letter f) GDPR. Art. 6 para. 1 letter f) GDPR for our legitimate interest in external communication.
If Cyber Curriculum processes personal data, it will only be stored for the purposes described for as long as is necessary for these purposes or as long as we are legally obliged to store the data.
We currently have a presence on the following social media platforms:
Facebook, Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, https://www.facebook.com/privacy/explanation
Instagram, Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, https://help.instagram.com/519522125107875
Linkedin, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin, Ireland, https://linkedin.com/legal/privacy-policy
YouTube, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, https://policies.google.com/privacy?hl=de&gl=de
(9) Special information on Facebook and Instagram
Facebook and Instagram are Meta services. For this reason, the following explanations refer to both services.
When users visit our Instagram channel or our Facebook fan page, Meta collects certain data about users and provides us with statistical evaluations of the use of our social media channels – so-called page insights.
With regard to the Facebook fan page, the European Court of Justice assumes that we are a “joint controller” with Meta in this respect, even if we only receive data in statistical form and cannot draw any conclusions about the users as natural persons. The content of the agreement between Meta and us on the provision of Page Insights can be found at
https://www.facebook.com/legal/terms/page_controller_addendum.
Meta can be used to users’ personal data is also processed outside the European Union/European Economic Area. With regard to suitable guarantees for the transfer of personal data outside the European Union/European Economic Area in accordance with Art. 44 et seq. GDPR, there are standard contractual clauses between the meta companies.
There is no data protection adequacy decision by the European Commission for the USA and a large number of other countries outside the European Union/European Economic Area. There is a risk for users that government agencies may access personal data without us and/or the users being aware of this. The possibility of access by government agencies arises primarily from legislation on foreign reconnaissance, counter-espionage, terrorism and criminal prosecution.
The legal basis for the processing of personal data is a balancing of interests in accordance with. Art. 6 para. 1 letter f) GDPR (our legitimate interest is the needs-based design of our social media presence).
(10) YouTube with enhanced data protection
This website embeds videos from YouTube. The operator of the pages is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the transfer of data to YouTube partners is not necessarily excluded by the extended data protection mode. YouTube establishes a connection to the Google DoubleClick network regardless of whether you are watching a video.
As soon as you start a YouTube video on this website, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.
Furthermore, YouTube may store various cookies on your end device after starting a video or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to record video statistics, improve user-friendliness and prevent fraud attempts.
After the start of a YouTube video, further data processing operations may be triggered over which we have no influence.
The use of YouTube is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR represent. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
You can find more information about data protection at YouTube in their privacy policy at: https://policies.google.com/privacy?hl=de.
(11) Minors
This website and the offers are not intended for persons under the age of 18. They should only transmit personal data with the consent of the parents or legal guardians.
(12) Amendment of the privacy policy
We reserve the right to adapt our security and data protection measures at any time due to the constant further development of our website, our offers and technical developments. Please therefore note the current version of our data protection notice.
