This Privacy Policy informs you of the extent to which we process your personal data (hereinafter referred to as “data”).
The data controller as defined in the provisions of the General Data Protection Regulation (GDPR) is:
Berlitz Deutschland GmbH
Hahnstraße 68-70
60528 Frankfurt, Germany
Tel.: +49 (0)69 666 08 90
Web: www.berlitz.com/en-de
Email: info@berlitz.de
Email: datenschutz@berlitz.de
We process data in the course of operating our business and our website.
This also includes disclosure by means of transmission to third parties and, if applicable, to “third countries” outside of the European Union (“EU”) and the European Economic Area (“EEA”). We have provided appropriate notices below in cases where we transfer data outside of the EU or EEA. The European Commission has not issued an adequacy decision for transfers of data to the United States. Information on the respective guarantees to ensure an adequate level of data protection can be found with the respective services.
The data concerned, processing purposes, legal bases, recipients and transfers to third countries are listed below:
We log your visit to our website. We process the following data in this context:
• Name(s) of the web page(s) you have accessed;
• Date and time of access;
• The quantity of data transmitted;
• Browser type and version;
• Your operating system;
• Referrer URL (the previously visited website);
• Your IP address;
• Requesting provider.
According to Art. 6(1)(f) GDPR, the legal basis for this data processing is our overriding legitimate interest in the continuous operation and security of our website.
Log files are deleted after seven days unless they are needed in order to verify or investigate specific legal infringements occurring during the retention period.
In order to operate our website, we use the services of web hosting providers who process the data referred to above (log file when you visit our website) and all other data to be processed in connection with the operation of our website on our behalf.
According to Art. 6(1)(f) GDPR, the legal basis for this data processing is our overriding legitimate interest, thus permitting us to operate the website in the first place.
If you contact us, we will process the following data exclusively for the purpose of processing and responding to your inquiry: salutation, first name, last name, email address, postal code, telephone, and other information if you have provided it, and your message.
The legal basis for this data processing is our obligation to satisfy a contract and/or to satisfy pre-contractual obligations according to Art. 6(1)(b) GDPR and/or our overriding legitimate interest in processing your inquiry according to Art. 6(1)(f) GDPR.
Data is transferred to the Salesforce customer management system if a web-based form is used (see point e). In addition to the aforementioned data, your IP address and details of your website visit are also affected. All data collected by Berlitz is processed within the EU.
Data is transferred to the Salesforce customer management system if a web-based form is used (see point e). The Zapier service provided by US-based Zapier Inc. is used for certain landing pages. As part of this process, information provided to us is automated and transferred to our Salesforce management software. In addition to the aforementioned data, your IP address and details of your website visit are also affected. This also results in the transfer of data to the United States. Zapier ensures adequate levels of data protection via the EU standard contractual clauses. A copy of the relevant EU standard contractual clause will be provided upon request.
We offer a live chat service on our website. If you contact us in this way, we process the following Data from you for the purpose of handling and fulfilling your request: name, contact details (if provided by you), date and time of access, browser type and version, IP address, operating system used, URL of the previously visited web page, volume of Data transferred and your message. It is possible that Data may also be transmitted to Amazon Web Services, Inc. in the USA
.The legal basis for the data processing is our obligation to perform a contract and/or to comply with our obligations prior to entering into a contract in accordance with point (b) of Article 6(1) GDPR and/or our overriding legitimate interest in handling your request in accordance with point (f) of Article 6(1) GDPR.
For data transfers to the USA, there is no adequacy decision by the European Commission. In this case, an adequate level of data protection is ensured by means of EU standard contractual clauses. We can provide a copy of the standard contractual clauses on request. To obtain this, please contact datenschutz@berlitz.de.
We process your order data within the scope of performing contracts between you and us.
The legal basis for this data processing is Art. 6(1)(b) GDPR when fulfilling our contractual obligations and, in specific cases, Art. 6(1)(c) GDPR when fulfilling our legal obligations.
We transmit your address data to the company hired to carry out the delivery. Where required for the fulfillment of the contract, we will also forward your email address or your telephone number to agree a delivery date (advice note) with the dispatcher.
We will transfer your transaction data (name, order date, payment method, date of dispatch and/or receipt, payment amount and recipient and, where applicable, bank details or credit card details) to the payment services provider entrusted with processing the payment. The following payment service providers are used in this context:
• Adyen: Payment for all products and services purchased in the online store at www.berlitz.com/de-de/can be made by credit card, online bank transfer via Giropay or via SEPA direct debit.Payment processing is performed by the following service provider: Adyen, Adyen Headquarters; Simon Carmiggeltstraat 6–50; 1011 DJ Amsterdam, Netherlands.
• Chargebee: For some products, we offer the option of monthly payments and installment payments via Chargebee Inc, 340 S Lemon Avenue, #1537, Walnut, CA 91789, United States. In such cases, relevant data is transferred to Chargebee in the United States. Chargebee ensures adequate levels of data protection via the EU standard contractual clauses. A link to these standard contractual clauses will be provided upon request.
• Bookacamp: When you book a language camp on our website, we will save and process your data from the booking forms with our German partner Bookacamp. The data from the booking forms is necessary to organize our camps and for the supervision during the camp. The data transfer is completely encrypted and is only stored in European data centers. You can read in detail how Bookacamp handles your data in the Bookacamp privacy policy (https://bookacamp.de/de/privacy).
For purposes of providing efficient customer support, we use the Salesforce customer management system, represented in Germany by Salesforce.com Germany GmbH, Erika-Mann-Strasse 63, 80636 Munich, Germany (“Salesforce”). We use Salesforce to collect, link and evaluate form data (contact details, customer account, order data, etc.) processed on our website. This data is transferred to the Salesforce servers in the course of processing.
Processing in this context is performed on the basis of our overriding legitimate interest in providing our customer service in accordance with Art. 6(1)(f) GDPR.
Salesforce is a corporation with offices around the world. The Group’s parent company is salesforce.com, in Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, United States. All data collected by Berlitz is processed within the EU.
Berlitz anonymizes your data (e-mail address) so that they can no longer be linked to your person. You are no longer identifiable. This anonymization is done for the purpose of creating interest categories and thereby targeting new customers. Data processing is based on our overriding legitimate interest in providing our customer service in accordance with Article 6(1)(f) GDPR.
In order to be able to regularly provide you with information on our company and our services, you can subscribe to our email newsletter. We process any data you provide (email address and other information provided voluntarily) when you register for our newsletter.
To do this, we require your consent, as follows:
“[ ] I would like to subscribe to the newsletter of Berlitz Deutschland GmbH. I can withdraw my consent at any time by sending an email to datenschutz@berlitz.de or by using the unsubscribe link provided in the newsletter.”
In order to prevent misuse, we will send you an email upon receipt of your registration, requesting you to confirm your subscription (double opt-in procedure). Your registration will be logged in order to be able to verify your registration in a legally compliant manner. This relates to the times of registration and confirmation as well as your IP address.
The legal basis for sending the newsletter is your consent pursuant to Art. 6(1)(a) GDPR. The legal basis for sending the confirmation email for your registration, as well as associated data logging and data processing, is our legitimate interest according to Art. 6(1)(f) GDPR in properly verifying your registration.
We use service providers to whom we submit the data described above in order to send our newsletter. As described in section 4e), we use Salesforce as well as other providers who process this data on our behalf.
When opening a customer account, you automatically consent to the storage of your contact details (name, address, email address, bank details) and your usage data (user name and password). In doing so, we are able to identify you as a customer and you are able to manage your orders. In this context, we will obtain the following consent from you:
“[ ] I would like to create a customer account. Please save my data for this purpose. I can withdraw my consent at any time by sending an email to datenschutz@berlitz.de.”
Based on this consent, your data will be processed pursuant to Art. 6(1)(a) GDPR.
We use service providers to whom we transmit the data referred to above for the administration of customer accounts. For this, we use Salesforce as described in section 4e).
If you want to use our form for scheduling appointments, your data (name, contact details and selected language) will be used to process and handle your request. To provide this service, we work together with service providers to whom we transfer the above mentioned data. The specified data is processed by us on the basis of Art. 6(1)(b) GDPR or Art. 6(1)(f) GDPR in order to execute your request.
Your data (name and contact details as well as company name and role in the event of participation on behalf of a company) must be disclosed if you want to take part in our prize draws. To process the prize draw, we sometimes use service providers to whom we transfer the specified data. The data is processed on the basis of your consent given pursuant to Art. 6(1)(a) GDPR or on the basis of our overriding legitimate interest in the marketing of our services pursuant to Art. 6 (1)(f) GDPR.
When contacting us in order to send us your job application, your data (e.g. name, email address, preferred workplace, if provided), your message and the submitted application documents will be used solely for the purpose of processing and handling your job application request. This is done via the softgarden platform. Here, the primary legal basis for processing your data is section 26 BDSG in conjunction with Art. 88 GDPR. According to this, it is permitted to process data that is required in connection with a decision on, or the conclusion of, an employment relationship.
If the data is still required after the completion of the application procedure, for instance for prosecution purposes, we are permitted to process the data for the protection of our legitimate interests pursuant to Art. 6(1)(f) GDPR, i.e. for the assertion and/or defense of claims.
We use “cookies” on our website. Cookies are small text files that are placed on your device (PC, smartphone, tablet, etc.) and stored by your browser. We only use technically necessary session cookies on our website.
We use “cookies” on our website. Cookies are small text files that are placed on your device (PC, smartphone, tablet, etc.) and stored by your browser.
Information about the specific cookies we use, their providers and purposes can be found in our consent banner. There, you can give your consent to the respective services, revoke it or modify your settings at a later point in time.
We use a consent banner in order to document your choices related to certain data processing operations and to fulfill our data protection-related legal obligations. Your cookie preferences are queried via a banner when you visit our website. We then place a cookie in which data on any consent that has been given or revoked is stored. Data processing in this context is performed for the fulfillment of our legal obligations according to Art 6(1)(c) GDPR.
We use a consent management tool provided by OneTrust Technology Limited, 82 St John St, Farringdon, London EC1M 4JN, United Kingdom (UK), (“OneTrust”), in order to properly manage consent. Data generated in this context is stored on servers in Germany.
We use a variety of services on our website provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as “Google”). It is possible that data will also be transmitted to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, in the United States as a result.
The European Commission has not issued an adequacy decision for transfers of data to the United States. Google ensures adequate levels of data protection via the EU standard contractual clauses. A copy of the relevant EU standard contractual clause will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.
We use the Google tracking tool “Google Analytics” on our website. We use Google Analytics in order to evaluate your use of the website, to compile reports on website activities on our website, and to provide other services associated with website use and to improve user-friendliness.
Interactions between website visitors are collected and automatically analyzed, primarily with the aid of cookies, by virtue of the use of Google Analytics.
We use Google Analytics with the extension “_anonymizeIp()”. IP addresses within the member states of the EU or EEA are shortened as a result. Only in exceptional cases will your complete IP address be transferred and shortened at the destination if sent to a Google server in the United States. This usually excludes a direct personal reference. In particular, an assignment to the called-up computer and/or end device of the website visitor is no longer possible.
The following data will be processed in connection with the use of Google Analytics:
• 3 bytes of the IP address of the accessing user’s system (anonymized IP address)
• The web page viewed
• The website from which the user reached the page accessed on our website (referrer)
• The sub-pages accessed via the website
• Length of stay on the website
• Frequency of visiting the website
According to information provided by Google, Google will not associate your IP address with any other data held by Google in any case.
We use Google Ads, an online advertising program by Google Inc. on our website. So-called conversion tracking is used in this context. A cookie is stored on your computer if you click on an advertisement serviced by Google. This cookie expires after 30 days and is not used to personally identify users. If you visit certain pages of the website and the cookie has not yet expired, Google and the website can tell that you clicked on the ad and proceeded to that page.
The data obtained using conversion cookies is used to create statistics for Ads customers who have opted into conversion tracking.
To optimize our Google ads, we use Google's offline conversion tracking service on our website. With conversion tracking, we can record your click behavior after you have clicked on our ads. By importing offline conversion events, we can track keywords, location and time (e.g. geography or time of day) to improve our Google ads. We can use this information to target customers more effectively in the future.
To improve the measurement of our online conversions, we use the Google Enhanced Conversion service on our website. The data collected help us to target visitors more effectively, track conversions that would otherwise not have been recorded, and optimize our offers.
We use the Google Consent Mode service on our website. We use this function to determine your consent to use cookies for our advertising purposes. Depending on your confirmation or rejection, conversion tracking is continued or rejected.
The legal basis for data processing connected to the Google services described above is your prior consent pursuant to Art. 6(1)(a) GDPR.
You can withdraw your consent at any time with future effect by adjusting your preferences in our consent banner.
We use Microsoft Advertising on our website, an advertising service provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, United States. So-called conversion tracking is used in this context. A cookie is stored on your computer if you click on an advertisement serviced by Microsoft. If you visit certain pages of the website and the cookie has not yet expired, Microsoft and the website can tell that you clicked on the ad and proceeded to that page. This cookie is not used to personally identify users. The data obtained using conversion cookies is used to create statistics for Advertising customers who have opted into conversion tracking.
The legal basis for this data processing is your consent pursuant to Art. 6(1)(a) GDPR.
You can withdraw your consent at any time with future effect by deactivating the cookie via your web browser under user settings or by modifying your preferences in our cookie settings.
Microsoft ensures adequate levels of data protection via the EU standard contractual clauses.
A link to the relevant EU standard contractual clauses will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.
On our website, we use WiredMinds, a service provided by WiredMinds GmbH, Lindenspürstrasse 32, 70176 Stuttgart, Germany (“WiredMinds”) to analyze visitor behavior. The use of WiredMinds may involve the installation of cookies, which may also collect personal data and transfer such data to the WiredMinds servers.
On the basis of this data, usage profiles are created under a pseudonym. Where possible and appropriate, these usage profiles are completely anonymized. Where IP addresses are collected, these will be directly anonymized by deletion of the last block of numbers. The data obtained in this way is not used to personally identify the user of the website without the separate consent of the affected party and it is not linked to personal data on the bearer of the pseudonym.
We process this data on the basis of your consent pursuant to Art. 6(1)(a) GDPR.
You can withdraw your consent at any time by setting an opt-out cookie by clicking on the following link: https://test.wiredminds.de/track/cookie_mgr.php?mode=dont_track_ask&websitesel=6febe419a06fcffe&lang=de or by modifying your preferences in our cookie settings.
We use a so-called tracking pixel from Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, a subsidiary of Facebook Inc. 1601, Willow Road Menlo Park, CA 94025, United States, on our website. We use the Facebook pixel to track the success of our own Facebook advertising campaigns and to optimize the draw of Facebook advertising campaigns to interested target groups.
When you click on a Facebook ad or visit our website, the pixel integrated into our website places a cookie on your device. The cookie processes data about whether you reached our website via a Facebook ad and allows us to analyze the user’s behavior until a purchase is completed. This allows us to track the success rate of our Facebook advertising campaigns. In addition, the pixel processes data concerning the circumstance that you have visited our website and enables us to tailor advertising displayed on Facebook based on your interests.
The Facebook pixel integrated into our website establishes a direct connection to Facebook’s servers when you visit our website. The information generated by the cookie about your use of our website (including your IP address) is transmitted to Facebook in the United States.
The European Commission has not issued an adequacy decision for transfers of data to the United States. Facebook ensures adequate levels of data protection via the EU standard contractual clauses. A link to the relevant EU standard contractual clauses will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.
The collected data is anonymous and cannot be used to draw any conclusions about users’ identities. If you are registered with Facebook, Facebook may associate information collected as part of this process with your account. Even if you do not have a Facebook account, or are not logged in when you visit our website, Facebook may process and store your IP address and other identification data.
You can withdraw your consent to data processing via the Facebook pixel for our web domain at any time with future effect by adjusting your preferences in our consent banner.
The legal basis for data processing is your consent pursuant to Art. 6(1)(a) GDPR.
We use the FullStory analytics service, provided by FullStory Inc., 120 Ottley Dr., NE, Ste 100, Atlanta, GA 30324, United States (“FullStory”), to analyze user behavior on our website. FullStory records information about the behavior of website visitors, enabling us to analyze this behavior and to improve the user experience on our website. FullStory processes information such as clicks, mouse movements, input (with the exception of sensitive information), scroll movements, browser used, device type, IP address, pages visited and session duration.
The legal basis for data processing is your consent pursuant to Art. 6(1)(a) GDPR.
You may withdraw your consent at any time with future effect by clicking the following opt-out link: https://www.fullstory.com/optout
FullStory ensures adequate levels of data protection via the EU standard contractual clauses. A link to the relevant EU standard contractual clauses will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.
In order to continuously improve our website, we use the Optimizely web analytics service on our website provided by Optimizely Inc., 631 Howard Street, Suite 100, San Francisco, CA 94105, United States (“Optimizely”). Optimizely uses cookies. They process information about the page accessed, the date and time of access, the referrer URL (the previously visited website), your browser, your use of the website and your IP address. Please note that Optimizely is used on our website with IP anonymization. This shortens IP addresses before they are sent to a server in the United States. A direct personal reference in connection with the stored data is thus usually excluded. Only in exceptional cases is the full IP address transmitted to a server in the United States and shortened there.
The legal basis for data processing is your consent pursuant to Art. 6(1)(a) GDPR.
You can withdraw your consent to data processing at any time with future effect by modifying your cookie settings.
Optimizely ensures adequate levels of data protection via the EU standard contractual clauses. A link to the relevant EU standard contractual clauses will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.
To continually improve our online services, on our website, we use the service AB Tasty, Rosenstraße 2, 10178 Berlin, Germany (“AB Tasty”). AB Tasty uses cookies. This company processes statistical information about your visit to our website, the referrer URL, the device and browser you are using, your geolocation, language settings, number and location of clicks, and your IP address.
The legal basis for this data processing is your consent pursuant to Article 6(1)(a) GDPR.
You can withdraw your consent to this data processing at any time with effect for the future by customizing your preferences in our cookie settings. When using AB Tasty, personal data are transferred to third countries.
We use matelso Call Tracking on our website, a service of matelso GmbH, Heilbronner Str. 150, 70191 Stuttgart, Germany (hereinafter referred to as “matelso”). matelso stores and processes information about your user behavior on our website through the use of cookies. We use matelso for marketing and optimization purposes, in particular to analyze the use of our website and to continuously improve certain functions, services and the user experience.
The legal basis for this data processing is your prior consent, in accordance with Article 6(1)(1a) GDPR.
You can withdraw your consent to this data processing by matelso at any time with effect for the future by customizing your preferences in our consent management tool.
We use dynamic content (“content”) from external sources to optimize the presentation of our website and what it offers. When visiting our website, an application programming interface automatically submits a request to the server of the respective content provider as part of which certain log data (e.g. the user’s IP address) is transmitted. The dynamic content is then transferred to our website and displayed there.
We use external content in connection with the following features:
We have integrated videos from YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066, United States (“YouTube”) on our website. The controller for YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”). However, when you play the videos, log data will be transferred to YouTube’s servers in the United States. Processing in this manner is performed on the basis of our overriding legitimate interest in the optimum marketing of our website in accordance with Art. 6(1)(f) GDPR.
The European Commission has not issued an adequacy decision for transfers of data to the United States. Google ensures adequate levels of data protection via the EU standard contractual clauses. A link to the relevant EU standard contractual clauses will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.
We use Mapbox Inc.’s Mapbox service on our website in order to provide you interactive maps. When the map is displayed, data, including your IP address, browser, and device information of your location, is transferred to Mapbox’s servers and stored there. Processing in this manner is performed on the basis of our overriding legitimate interest in the optimum marketing of our website in accordance with Art. 6(1)(f) GDPR. The controller for Mapbox is Mapbox Inc., 740 15th Street NW, 5th Floor, Washington DC 20005, United States (hereinafter “Mapbox”).
The European Commission has not issued an adequacy decision for transfers of data to the United States. Mapbox ensures adequate levels of data protection via the EU standard contractual clauses. A copy of the relevant EU standard contractual clauses will be provided upon request. Please contact datenschutz@berlitz.de if you are interested in receiving these contractual clauses.
We will only store personal data for as long as is required for the purpose for which it is processed or until you withdraw your consent to the processing of such data. Where statutory retention obligations must be complied with, the storage period for certain data may be up to 10 years, regardless of the processing purposes.
On request, we will provide you with information on the personal data stored on you, at any time and free of charge.
If you no longer consent to the storage of your personal data or if your personal data is no longer accurate, we will initiate the erasure or blocking of your data at your request or ensure that your data is updated accordingly (to the extent possible in accordance with the applicable laws and regulations). The same applies if you want your data only to be processed subject to certain restrictions in the future. You have the right to object in particular in cases in which your data is necessary for the performance of a task carried out in the public interest or on the basis of our legitimate interest, as well as profiling based on this. You also have such a right to object in the case of data processing for the purpose of direct advertising.
You can withdraw your given consent at any time with future effect. The withdrawal of your consent will, however, in no way affect the lawfulness of the processing of your data before the time of withdrawal.
You have the right to data portability in cases where data is processed on the basis of a contract, pre-contractual negotiations, consent or by means of an automated process. On request, we will provide you with your data in a structured, commonly used and machine-readable format so that you can transfer the data to another competent party, where required.
Data which cannot be used to identify the affected party, for example which has been anonymized for analytical purposes, is not affected by the above rights. The provision of information, erasure, blocking, rectification or transfer of data to another company may be possible if you provide us with additional information which enables an identification by us.
If you have any questions regarding your personal data, the provision of information, rectification, blocking, objection or the erasure of data or want your data to be transferred to another company, please contact datenschutz@berlitz.de. You also have the option to complain to a supervisory authority on account of your rights as a data subject.
