Data Protection Notice and Cookies

The following information shall inform users of our website about how we process personal data. These information serve us to comply with our duties imposed under the General Data Protection Regulation (GDPR). Personal data means any information relating to you by which you can be identified, directly or indirectly.

1. Who is accountable for the use of my data?

The
Bertelsmann SE & Co. KGaA
Carl-Bertelsmann-Straße 270
33311 Gütersloh
Tel: +49 (0) 5241-80-0
Fax: +49 (0) 5241-80-62321
E-mail: info@bertelsmann.de

The above indicated company is accountable for the use of personal data on this website. Every processing of personal data on this website is conducted in compliance with the GDPR as well as possibly applicable other legislation.
You can contact the company by the means indicated above and by reference of your query. Where you want to contact the responsible data protection officer directly, add “Attention Data Protection Officer” to the address.

2. What data are concerned?

If you browse our websites by your PC certain information are collected simply for technical reasons of data flows (technical data). These technical data contain server log files, infor-mation about your browser (type, version and information of access status – success or fail), operating system, your internet service provider and your IP address, date and time of the access and from where you accessed the website (prior website or search engine). Save the IP address these information do not allow an identification of you. Where the IP address is used, we comply with the provisions of the GDPR.
If you use features of our website, a pseudonymized user profile will be created and, where you provide information by your use (e.g. search words, log in data, ratings, contract details, clicks, etc.), such data will be collected.
Some services require the provision of personal data. In these situations the respective ser-vice requested by you will be the leading purpose of our use of your data (Newsletter, member zone).

3. Which cookies are used?

This website uses cookies. Cookies are small text files which are stored on your computer when you browse our website. Upon revisit and as well during your stay on our website, the cookie enables us to (re-)identify you. Depending on the nature of the cookie, they can be persistent or non-persistent, what means they are in case of the former deleted as soon as you close your browser or, in case of the latter, remain stored even after closing your browser. All cookies have an expiration date, after which they will stop responding to browser requests and, depending on your settings, will be deleted. You can also steer how cookies are treated on your computer by adjusting the settings of your internet browser. Please note, however, that if you disable all cookies that way, you might not be able to use all our website features properly.
In principle, cookies are only an online identification without personal reference. Cookies are personalized when other data is combined in addition to the information generated by the cookies. A distinction can be made between cookies, which are necessary for the provision of the website, and cookies, which are necessary for further purposes such as analysis of user behaviour or advertising.
In the following, we provide you with information about the cookies we use on our website.

Cookies used to identify or authenticate users;
Cookies that temporarily store certain user inputs (e.g. content of a shopping basket or an online form);
Cookies that store certain user preferences (e.g. search or language settings);
Cookies that store data to ensure the trouble-free playback of video or audio content.

Cookies, which are necessary for further purposes of the website, include the analysis cookies in order to record and statistically evaluate the usage behaviour of our users (e.g. clicked advertising banners, pages visited, search queries made).

4. Which data are used for which purpose?

The purposes for processing personal data can be found in technical, contractual, and obligations by law, as well as your consent.
We use the data listed above in sec. 2 for the following purposes:

provision of our website including measures to assure a undisturbed service, prevent fraud and hacking and to ensure the security of our systems.
to measure the geographical reach of our website, in order to streamline our technical support and the website operation.
to answer contact inquiries;
to send E-mail newsletters;
for the administration of programs booked by participants; and
for communication among each other within groups of participants

You can find further information about each used feature as well as the underlying purposes in the following sections.

4.1 Technical provision
4.1.1 Description and extent of the processing

For the provision of our website, including regular performance and security checks, server log files are stored as part of the information when our website is accessed. These log files contain the information and possibly personal data as indicated in section 2 above. Log files are used for the purposes of technical provision only and they are not merged with any other data. Part of the technical provision is a regular reviewing procedure that is designed to detect fraud, hacking and other forms of disruptive behavior.

4.1.2 Purposes and legal basis for the use of personal data

The legal basis for the use of server log files is to be found in Art. 6 sec. 1 lit. f GDPR. Our interest is the undisturbed, resilient and performant operation of our website.

4.1.3 Duration of storage

After accessing our website we store the server log files, including your IP address, for 7 days. Any analyses of these data are conducted only in case of a disruptive event involving these data.

4.1.4 Right to object

4.2 Contact form, E-mail or phone contact
4.2.1 Description and extent of the processing

On our website you are offered different means to get in contact with us (Contact form, E-mail address, tel.). If you use one of them, data affiliated with that means respectively (e.g. your E-mail address where you use the contact form or your phone number if you chose to call us) and of course your request will be recorded, so that we can provide you with a solution. The same applies for your query; if you use one of that means to address some question to us, we will store and use that request in a form that is linked to you as long as we need it to process it properly. Where this is necessary, some or all of the data collected under this clause can be transmitted to other entities, provided we need their support to answer your request. In that situation we ensure that the recipient has implemented a proper level of protection as well.

4.2.2 Purposes and legal basis for the use of personal data

The legal basis for using data in this regard is to be found in Art. 6 sec. 1 lit. f GDPR. Our shared interest is that you receive an adequate answer. Hence, for the time necessary for this endeavor, there is no overriding interest that prevails and excludes the data processing. Where your contact is directed towards the conclusion of a contract, the processing is based on Art. 6 sec. 1 lit. b GDPR instead.

4.2.3 Duration of storage

After responding to your request and the end of possibly further communication, your information provided for the purpose of the query will be erased unless your query was directed towards the conclusion of a contract or where you contacted us in order to exercise one of your data subjects rights. In that situation we will keep records as long as necessary for the performance of a contract or as long as we have to demonstrate our compliance with your request for your rights.

For contracts the storage period is usually between 6 and 10 years.

4.2.4 Right to object

You are entitled to object the use of your personal data pursuant to Art. 21 GDPR on grounds that relate to your particular situation. If you want to exercise that right contact the Data Protection Officer via the means of contact indicated in section 1 above. Where you object the use of your data, we might not be able to respond to your request anymore, unless it is necessary for the performance of a contract or you want to exercise one of your rights.

4.3 E-mail Newsletter
4.3.1 Description and extent of the processing

The website offers the possibility to subscribe to a newsletter maintained by us free of charge via E-mail. The newsletter offers further training opportunities and other offers for employees and interested members of staff. Your data from the registration form will be transmitted to the company and (with the help of service providers) processed further for sending the offers via E-mail. When registering, you will be asked for consent to the data processing described here via a double-opt-in procedure. You can access our data protection information at any time during this process via a link in the footer. Your data will not be passed on to third parties. Your E-mail address, name, first name and salutation (collectively "access data")is mandatory for receiving the newsletter. It is also necessary to process your access data in order to be able to prove that you have given your consent.

If you subscribe to our newsletter, we would like to know how you use the Newsletter so that we can optimize it, our products and content. For this purpose, we use so-called pixels in the newsletters, which measure whether a newsletter is opened, whether it actually reaches the email recipient, what content is displayed and which buttons, links or other features in the newsletter are clicked on. We collect your IP address, system data (operating system, screen resolution, browser version, language settings, time settings, battery status, end device, etc.) and (sub)page views. We evaluate the data collected in this way exclusively in the form of aggregated user statistics in order to gain more precise insights into the general use of our newsletters and the attractiveness of the respective content.

4.3.2 Purposes and legal basis for the use of personal data

Data processing in the context of sending a newsletter is necessary for the transmission of information and communication to you. The subsequent evaluation of user behavior with regard to the newsletter serves to optimize the creation and sending of the newsletter and to increase the attractiveness of the newsletter. The legal basis for processing is your consent to the sending of the newsletter and newsletter tracking in accordance with Art. 6 para. 1 lit. a GDPR.

4.3.3 Duration of storage

The data is stored during the subscription period of the newsletter. After the cancellation, the data will only be stored to prove that the company has obtained your consent for sending the newsletter for a period of 3 years. The same applies if you have withdrawn your consent or if you unsubscribe from the newsletter. The legal basis for the (continued) storage of consent is Art. 6 para. 1 lit. c in conjunction with Art. 5 para. 1 lit. a, para. 2, Art. 7 para. 1 GDPR and Art. 6 para. 1 lit. f GDPR In all other respects, the data will be deleted by us or on our instruction by our service provider.

4.3.4 Right to object

You can withdraw your consent to receive newsletters at any time by notifying the company of your withdrawal via the E-mail address university@bertelsmann.de with the subject "Newsletter withdrawal" or via the following link or within every newsletter by clicking at the Unsubscribe Button.

4.4. Google Analytics (Webtracking)
4.4.1 Description and extent of the processing

This website uses Google Analytics (GA). Provider of GA is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. GA is configured by use of the ‘_anonymizeIP’-code in a way that it deletes the last octet of your IP address, hence only creating pseudonymous user profiles, which cannot identify you as a person. These non-personal user profiles will be subject to analysis and evaluation. Due to the IP anonymization on this website, your IP address will be shortened by Google within member states of the EU or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. If you give your consent, you agree to the processing of the data collected about you by Google in the manner described above and for the aforementioned purpose.

Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You can find more information about the data processing by Google, including GA, in Google’s Data Protection Statement: https://policies.google.com/privacy?hl=de

4.4.2 Purposes and legal basis for the use of personal data

The legal basis for the collection and evaluation of your pseudonymous user profile is Art. 6 para. 1 lit. a GDPR. By granting your consent to data processing within our cookie consent tool, we are authorized to process your data in the manner and for the purposes stated.

4.4.3 Duration of storage

The data that is collected and evaluated when using Google Analytics is usually stored until you withdraw its use. The analysis cookies are stored for a maximum of 24 months.

4.4.4 Right to object

You can object to the use of Google Analytics at any time by changing your browser settings or by revoking or adjusting your consent to the processing by Google Analytics at any time for the future via the corresponding data protection setting in our cookie consent tool under the heading Data protection settings or Privacy Center.

4.5 Member Area
4.5.1 Description and extent of the processing

Bertelsmann University uses a password-protected member area for selected programs to prepare and follow up the programs offered. Only nominated employees have access to this area. A personal registration by third parties is not possible. In this respect, the participant area is a non-public area and therefore a non-public part of the website. To create a user profile, the name, first name and E-mail address of the nominated employee is required. In addition, the position, company and a photo of the employee can be submitted voluntarily. The aforementioned personal data will be used exclusively for the administration of the programs and for communication within groups of participants for which you have registered.

4.5.2 Purposes and legal basis for the use of personal data

The legal basis for the collection of the required registration data is Art. 6 sec. 1 lit. b GDPR. However, voluntary information are based on Art. 6 sec. 1 lit. a GDPR. You can give your consent for the above-mentioned data in your profile area.

4.5.3 Duration of storage

You will retain access to the password-protected participant area for all nomination programs you attend at Bertelsmann University. In order to support networking with other participants of the program in the long term, we store your data for a period of 5 years after your first login. If you wish your data to be deleted from the Bertelsmann University website before the expiry date, please send an E-mail to university@bertelsmann.de.

4.5.4 Right to object

Consent for the described data processing can be withdrawal in your personal profile at any time.

4.6 YouTube (Webtracking)
4.6.1 Description and extent of the processing

Bertelsmann University uses the provider YouTube of YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA, to embed videos. YouTube is represented by Google (Google Ireland Limited). The videos embedded on the website are embedded in enhanced privacy mode so that, according to official YouTube information, no information about visits to the website is stored unless the user actively watches videos on the website. There is also no personalization or display of personalized advertising due to the activation of the extended data protection mode. YouTube uses cookies to collect information about visitors to the website. These are used to collect video statistics, prevent fraud and improve user-friendliness, among other things, and some of them have a lifespan of several years. This also leads to a connection being established with the Google DoubleClick network. Clicking on the video buttons may trigger data processing operations over which we have no control. For this purpose, device-specific information (operating system, unique device identifiers and others) and log data (crashes, browser type and language, IP address and others) may be processed for various purposes determined by YouTube.

Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.

4.6.2 Purposes and legal basis for the use of personal data

The legal basis for enabling the playout of videos with the help of YouTube and the collection of video statistics and improvement of user-friendliness that also takes place in this context is Art. 6 para. 1 lit. a GDPR. By granting your consent to data processing within our cookie consent tool, we are authorized to process your data in the manner and for the purposes mentioned.

4.6.3 Duration of storage

The data collected by us when using YouTube is generally stored until the underlying purpose of the processing no longer applies or you object to its use or revoke your consent to processing for YouTube. As a rule, due to the extended data protection mode and the pseudonymous collection of your data for us, deletion is initiated after you leave the website. For information on the storage duration and criteria due to further processing by Google for YouTube, over which we have no influence, please refer to: https://policies.google.com/privacy.

4.6.4 Right to object

You can object to the use of YouTube on the website at any time by changing your browser settings or by revoking or adjusting your consent to the processing by Google for the YouTube service at any time for the future via the corresponding data protection setting in our cookie consent tool under the heading Data protection settings or Privacy Center. To object to further data processing by YouTube, over which we have no influence, please contact us at: https://policies.google.com/privacy.

4.7 Links to other websites / areas

This website contains links to websites of other website owners. By clicking on the links you reach the respective website (e.g. Facebook, Twitter). With the exception of your login data to supply the other website, no data will be transmitted from you to the website operators. The links are not plugins.

The data protection references exclusively to the web page of the Bertelsmann University Website. For the data protection references of other websites the company is not responsible. Nevertheless, it is recommended to carefully read their data protection information when visiting the linked websites.

4.8. Photos and videos at events
4.8.1 Description and scope of data processing.

Bertelsmann University hosts a number of exciting and interesting events for both employees of our Group and external parties. In order to capture the atmosphere, content and event circumstances for participants and interested parties, we take photos and videos (image, sound and video recordings) at our events. We intent and reserve the right to publish these recordings in whole or in part on our website, within the Group (e.g. BENET), individual or all social media accounts (e.g. Instagram, Facebook, Twitter) and/or in printed materials. This publication is associated with both a general availability for third parties and a retrievability of the recordings from countries outside the EU/EEA. In this respect, we would like to point out that we have no possibility to influence or prevent the data processing by these third parties.

4.8.2 Purposes and legal basis of data processing

We pursue different purposes with the production of photo, audio and/or video recordings as well as their publication. In addition to documentation for the participants, we aim to use the publication to present the various formats of Bertelsmann University to the outside world, including raising awareness and promotional use. In terms of data protection law, the collection and processing of personal data in the recordings is based on Art. 6 Para. 1 lit. a DSGVO in conjunction with. § Section 23 of the German Copyright Act (KUG), in that all participants are informed before the start of the event and before entering the venue that recordings are being made and that they can be removed.

4.8.3 Duration of storage or criteria for determination

Publication shall be unlimited in terms of subject matter, space and time for the respective publication types selected.

4.8.4 Options to object and remove images

The consent given explicitly or implicitly for the creation and publication can be revoked at any time. In this case, we will take appropriate measures in accordance with the type of publication in order to comply with the data subject's request. With regard to digital publications, for example on our website or social media accounts, this usually means deleting the image or pixelating the affected section of the image. However, we stress that the measures taken by us do not extend to the data processing activities of third parties who may have come into possession of the recordings without our knowledge

5. Who obtains my data?

Within our company, only those departments will have access to your data who need them in order to fulfil the aforementioned purposes. This applies accordingly to any involved Processors, if any, who might process data on our behalf (e.g. hosting and operations, mail delivery, etc.). All our Processors are contractually bound to our instructions which adheres to the high standard of data protection set out under the GDPR.

Data is forwarded to other recipients such as advertising partners or providers of social media services (so-called "third parties") if this is required by law or if you have given your consent. The following third parties are included in the data transfer:

Measurement and web analytics providers who measure the reach of the websites for their own purposes and create usage profiles.

Further information on the transfer of data to the respective third party can be found in the individual purposes in sections 3 and 4.

6. Are my data transferred outside of the EU (Third country transfer)?

Insofar as the service providers and/or third parties outside the EU or the EEA mentioned in Section 5 process your data for the purposes set out in Section 4, this may result in your data being transferred to a country where a level of data protection appropriate to the EU or the EEA cannot be guaranteed. However, such a level of data protection can be ensured with a suitable guarantee. Suitable guarantees include standard contractual clauses provided by the EU Commission. You can request a copy of these guarantees using the contact details provided in section 1. Any guarantees may be waived in exceptional cases, for example if you consent or if the third country transfer is necessary for the performance of your contract with the company. The EU Commission has also recognized certain third countries as safe third countries, so that the company can also dispense with suitable guarantees in this regard.

The following service providers process your data outside the EU or the EEA:

Google and YouTube (as a service of Google) use servers located in the EU for their services wherever possible. However, it cannot be ruled out that data may also be transferred to the USA. In this case, we ensure that the service providers contractually or otherwise guarantee an equivalent level of data protection. For example, this may be the conclusion of a data protection contract stipulated by the EU Commission (so-called EU standard contractual clauses). You can request a copy of the respective guarantees using the contact details given above under point 1. By giving your consent to the collection of your data by Google for Google Analytics within the cookie consent tool, you have consented to the transfer of your data to third countries, in particular the USA. Please note that data transfer outside the European Union may result in your data being transferred to a country that does not guarantee the same data protection standard as the European Union. You can revoke your consent at any time for the future in accordance with the implementation under point 4.

Some or most of the social media providers named in section 4 are located outside the EU. Data transfer to third countries, in particular to the USA, is therefore realistic. These third country transfers are permitted on the basis of your prior consent. Please note that data transfer outside the European Union may result in your data being transferred to a country that does not guarantee the same data protection standard as the European Union. We have no influence on the data collected by social media providers and data processing procedures, nor are we aware of the full scope of data collection, the purposes of processing and the storage periods. We also have no information on the deletion of the data collected by social media providers.

7. What are my rights?

You have all rights under Chapter III of the GDPR. They can be exercised towards every Controller handling your data. These rights are:

Right to access: You can request information about all data stored about you and how they are processed by the accountable Controller.
Rectification: You can request rectification, where data concerning you are wrong or outdated.
Erasure and to be forgotten: You can request that the Controller deletes your data. Where a deletion is conducted, the Controller shall inform any recipient about that to whom the data have been disclosed (Right to be forgotten).
Restriction: You can request a restriction of the data for the reasons set out by GDPR.
Data Portability: Where the conditions of the law are met, you can request to receive a copy of your data in a structured, machine readable and commonly used format.
Object: You can object the processing of your data for reasons that relate to your particular situation, if the processing is based on Art. 6 sec. 1 lit. f – legitimate interests – GDPR.

If you have given us your consent for the processing of your data, you can at any time withdraw this consent with effect for the future. Please address your withdrawal to the attention of our Data Protection Officer indicated in Sec. 1 above.

Your rights also apply to the above indicated cookies.

You also have the option of contacting a data protection authority and lodging a complaint there. The authority responsible for the company is the

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestr. 2-4
40213 Düsseldorf
Telefon: 0211/38424-0
Fax: 0211/38424-10
E-mail: poststelle@ldi.nrw.de

You can also contact the data protection authority responsible for your place of residence.

8. From where are my data collected?

All data processed by us for the purposes indicated above (see section 4) are directly collected from you. We hereby provide you with the mandatory information pursuant to Art. 13 GDPR. We do not merge these data with any information we might possibly hold from other instances.

9. Is there any automated decision-making (including profiling)?

For the purposes indicated in Section 4 above, we do not use automated decision making (including profiling).

10. Final information / Version

This website is subject to constant improvement and change. This may affect the herein given information about any processing of personal data.

Date of the data protection information: April 2024

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